HH provides investment management, wealth advisory, financial planning, and consulting services. Prior
to engaging HH to provide any of the foregoing investment advisory services, the client is required to
enter into one or more written agreements with HH setting forth the terms and conditions under which HH
renders its services (collectively the “Agreement”).
HH has been in business as an SEC registered investment adviser since October 13, 1988. Halbert
Hargrove Holdings, LLC, is the principal owner of HH.
HH has $2,735,028,599 of assets under management as of December 31, 2022. $2,586,640,355 of
these assets are managed on a discretionary basis and $148,388,244 are managed on a non-
discretionary basis. This Disclosure Brochure describes the business of HH. Certain sections will also
describe the activities of Supervised Persons. Supervised Persons are any of HH’s officers, partners,
directors (or other persons occupying a similar status or performing similar functions), or employees, or
any other person who provides investment advice on HH’s behalf and is subject to HH’s supervision or
control.
Wealth Advisory and Financial Planning Services
HH can be engaged to provide its clients with a broad range of wealth advisory and financial planning
services. A primary focus of HH is providing wealth advisory and financial planning services to individuals
and families. Advice is rendered in the areas of cash flow and debt management, risk management,
college funding, retirement planning, estate planning, investment tax planning, asset allocation,
investment selection, intergenerational wealth planning and charitable gifting.
In performing its services, HH is not required to verify any information received from the client or from the
client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such
information. HH can recommend the services of itself, and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists if HH recommends its own
services. Clients are advised that it remains their responsibility to promptly notify HH if there is ever any
change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or
revising HH’s previous recommendations and/or services.
Consulting Services
HH also provides consulting services on a non-discretionary basis for clients. HH’s consulting team
specializes in manager and broad market research, due diligence, asset allocation and portfolio
monitoring, analysis, and reporting.
The client is under no obligation to act upon any of the recommendations made by HH under a separate
consulting engagement or to engage the services of any such recommended professional, including HH
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itself. The client retains absolute discretion over all such implementation decisions and is free to accept
or reject any of HH’s recommendations.
Investment Management Services
Clients can engage HH to manage all or a portion of their assets on a discretionary basis. Wealth
advisory services are typically provided as a bundled service for discretionary accounts. Non-
discretionary accounts may be considered.
HH primarily allocates clients’ investment management assets among Independent Managers (as defined
below), mutual funds (including closed-end funds such as interval funds and tender offer funds),
exchange-traded funds (“ETFs”), structured products, and individual debt and equity securities in
accordance with the investment objectives of the client. The Firm also recommends that certain clients
invest in tender offer funds and privately placed securities (including debt, equity and/or pooled
investment vehicles) that are limited to “accredited investors” as defined under Rule 501 of the Securities
Act of 1933, as amended, and/or “qualified purchasers” as defined under the Investment Company Act of
1940, as amended, and/or “qualified clients” as defined under the Investment Advisers Act of 1940. In
addition, HH can recommend to clients a socially responsible investing solution that integrates multiple
strategies to balance risk, return, and positive social impact when consistent with the client’s investment
objectives. HH also provides advice to certain clients about other investments held in clients' portfolios,
but clients should not assume that these assets are being continuously monitored or otherwise advised
on by the Firm unless specifically agreed upon.
HH also renders non-discretionary investment management services to clients relative to variable
life/annuity products that they own, their individual employer-sponsored retirement plans, or other
products that are not be held by the client’s primary custodian. In so doing, HH either directs or
recommends the allocation of client assets among the various investment options that are available with
the product. Client assets are maintained at the specific insurance company or custodian designated by
the product.
HH tailors its advisory services to the individual needs of clients. HH consults with clients initially and on
an ongoing basis to develop an investment policy statement based on the client’s needs, risk tolerance,
time horizon and other factors. HH attempts to match clients’ investments with their investment needs,
goals, objectives and risk tolerance.
Clients are advised to promptly notify HH if there are changes in their financial situation or investment
objectives or if they wish to impose any reasonable restrictions upon HH’s management services. Clients
may impose reasonable restrictions or mandates on the management of their account (e.g., require that a
portion of their assets be invested in socially responsible funds) if, in HH’s sole discretion, the conditions
will not materially impact the performance of a portfolio strategy or prove overly burdensome to its
management efforts.
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Use of Independent Managers
As mentioned above, HH generally recommends that certain clients authorize the active discretionary
management of a portion of their assets by and/or among certain independent investment managers
(“Independent Managers”), based upon the stated investment objectives of the client. The terms and
conditions under which the
client engages the Independent Managers are set forth in a separate written
agreement between HH or the client and the designated Independent Managers. HH renders services to
the client relative to the discretionary recommendation or selection of Independent Managers. HH also
monitors and reviews the account performance and the client’s investment objectives. HH receives an
annual advisory fee from the client which is based upon a percentage of the market value of the assets
being managed by the designated Independent Managers.
When selecting an Independent Manager for a client, HH reviews information about the Independent
Manager such as its disclosure brochure and/or material supplied by the Independent Manager or
independent third parties for a description of the Independent Manager’s investment strategies, past
performance and risk results to the extent available. Factors that HH considers in recommending an
Independent Manager include the client’s stated investment objectives, the manager’s management style,
performance, reputation, financial strength, reporting, pricing, and research. The investment
management fees charged by the designated Independent Managers, together with the fees charged by
the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in
addition to, HH’s investment advisory fee set forth below. As discussed above, the client will incur
additional fees to those charged by HH, the designated Independent Managers, and corresponding
broker-dealer and custodian.
In addition to HH’s written disclosure brochure, the written disclosure brochure of the designated
Independent Managers, or current prospectus in the case of mutual funds and certain other investment
products, is available. Certain Independent Managers may impose more restrictive account requirements
and varying billing practices than HH. In such instances, HH may alter its corresponding account
requirements and/or billing practices to accommodate those of the Independent Managers.
Retirement Asset Disclosures
The following discussion is limited to the Firm’s services to retirement assets subject to ERISA or the
Internal Revenue Code.
Fiduciary Acknowledgment
When HH provides investment advice to clients regarding their retirement plan account or individual
retirement account, HH is a fiduciary within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way HH makes money creates some conflicts with client interests, so HH operates under a
special rule that requires it to act in the client’s best interest and not put HH's interest ahead of the clients.
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Under this special rule’s provisions, HH must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put HH's financial interests ahead of the client’s when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that HH gives advice that is in the client’s best
interest;
• Charge no more than is reasonable for HH's services; and
• Give clients basic information about conflicts of interest.
Conflict of Interest: Rollover Recommendation
As discussed in this Disclosure Brochure and HH's Relationship Summary, the way HH makes money
creates some conflicts with client interests. A conflict of interest exists when HH recommends its own
services. Additionally, HH's financial professionals are compensated based on revenue the Firm earns
from the financial professional’s advisory services or recommendations, which creates a conflict of
interest. The compensation results in an incentive to take steps to maximize revenue to the Firm by
increasing the size of the client’s account and/or relationship with HH. Therefore, a Rollover
Recommendation creates a conflict of interest by recommending HH’s own services and increasing the
size of the client’s account and/or relationship with HH. A Rollover Recommendation includes the
following: (i) rollover from plan-to-IRA, (ii) transfer of an IRA from another financial institution, (iii) rollover
from a plan-to-plan, and (iv) rollover from an IRA-to-plan.
Development of Rollover Recommendation from plan-to-IRA
In order to develop a recommendation that is in the client’s best interest, HH needs to consider
information about the client’s plan’s investments, services and expenses. As a result, it is important that
client provides HH with actual information about the plan and account. The easiest way to do that is for
the client to give HH copies of the plan’s 404a-5 investment disclosures and of a recent quarterly
statement about the account. (The plan gives clients a “404a-5 disclosure” every year and a copy is
available from the client’s employer and the plan’s website. It is also called by a number of other names,
for example, Investment Comparative Chart, and it is a description of the plan’s investment options and
their expenses, and other information.) If client does not give HH that information, the Firm will need to
use estimates or other information that may not be accurate and that could, as a result, cause HH to
make a recommendation that may not properly represent that actual facts or preferred outcome. So, it is
in client’s interest to make sure that HH has the actual plan information.
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However, if client does not provide the information, HH will use alternative sources, such as
benchmarking data for plans of a similar type and size or plan reports (such as Forms 5500) that may be
from several years ago. In evaluating possible sources of alternative data, HH has considered the
reliability of the data provider and its processes, and believes that the information that the Firm will use
will be accurate based on, e.g., robust information about plans of the size and type of client’s plan. While
HH expects that it will be accurately representative of client’s plan’s features, there can and will be
differences which could affect the Firm’s recommendation.