Redhawk Wealth Advisors, Inc. (“Redhawk” or “Firm”) is an SEC-registered investment advisor with its principal place of business based in Minneapolis, Minnesota. Redhawk began conducting business in 2008. Below are the Redhawk’s principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Daniel Edward Hunt, CEO Redhawk provides investment management and financial planning services to individuals, high net worth, trusts, estates, partnerships, charitable organizations, foundations, endowments, corporations, captive insurance companies (“CIC” or “CICs”), qualified retirement plans, or other businesses not listed above (collectively referred to herein as “Client” or “Clients”). Redhawk’s services include the review of Client investment objectives and goals, recommending investment products such as cash, stocks, mutual funds, exchange-traded-funds (“ETFs”), bonds, annuities, alternative investments, US government treasuries, cash and equivalents and preparing a written Investment Policy Statement (“IPS”). Redhawk’s investment advice is tailored to meet the Clients’ needs and investment objectives. Clients may impose restrictions on investing in certain securities or types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a signed and dated written notification, of which an e-mail is also an acceptable form of notification. Redhawk provides investment advisory and other financial services through independent financial advisors who have either: a. affiliated with Redhawk; or b. have an investment Sub-Advisory Agreement with the independent financial advisor’s registered investment advisory firm; or c. have a Solicitors agreement with the independent financial advisor’s registered investment advisory firm (“Financial Advisor” or collectively “Financial Advisors”). Redhawk provides discretionary and non-discretionary investment advisory services to its Clients through various managed account programs. Redhawk and the Financial Advisor will assist Clients in determining the investments that are in the best interest of the Client. The Financial Advisor is compensated based on a percentage of assets and the account is assessed other brokerage and account transaction fees. Redhawk and the Financial Advisor, as appropriate, will be responsible for the following:
• Perform due diligence to select the investments.
• Perform ongoing monitoring and replacement oversight of the investments.
• Provide a Client risk profile assessment.
• Provide research and analytics on investment product options, as needed.
• Recommend investments that are in the best interest of the Client based on: - Risk profile assessment - Age - Retirement date - Investible assets - Financial goals
• Prepare a customized IPS for the Client.
• Provide ADV Part 2A (Firm Brochure) and Form CRS.
• Obtain the investment management agreement from the Client with the required IPS and investment selection for each new account or change in investment.
• Perform Client best interest compliance review for new accounts including account documentation, IPS, and investment selections. Redhawk’s Financial Advisors may also provide a comprehensive financial plan for Clients. As part of the plan, the Financial Advisor will advise the Client on how to achieve their short-term and long-term financial goals. This may include saving for education, planning for retirement, managing taxes, and insurance. The following elements are addressed, and revised as necessary:
• Develop a retirement strategy for accumulating the retirement income needed.
• Develop a comprehensive risk management plan that may include a review of life and disability insurance, personal liability coverage, property and casualty coverage, and catastrophic coverage.
• Develop a long-term investment plan that includes a customized plan based on specific investment objectives and a personal risk tolerance profile.
• Develop a tax reduction strategy for minimizing taxes as allowed by the tax code.
• Develop an estate plan for the benefit and protection of heirs. As of 12/31/2023, Redhawk disclosed $1,815,167,245 in total assets under management all of which are discretionary assets under Redhawk’s management (“AUM”). Additionally, Redhawk advises on $663,530,206 in Assets under Advisement (“AUA”). AUM shall mean assets that are invested under either a(n):
• Risk-Guard Platform Investment Management Agreement (or “RGP”); or
• Standard Open Investment Platform Discretionary Investment Management Agreement (or “SOIP”); or
• Trading Open Investment Platform Discretionary Investment Management Agreement (or “TOIP”); or
• Held Away Open Investment Platform Management Agreement (or “HOIP”) whereby Redhawk or Financial Advisor is managing the account; or
• ERISA 3(38) Investment Management Agreement; or
• Standard Captive Insurance Company Investment Management Agreement; or
• ET Group of Companies Captive Insurance Company Investment Management Agreement; or
• Cash Balance Investment Management Agreement; or
• Section 529 Account Investment Management Agreement; or
• 403(b) / 457(b) Investment Management Agreement. AUA shall mean all other Client assets under advisement by a Financial Advisor that may be invested in a(n):
• Held Away Open Investment Platform Management Agreement (or “HOIP”) whereby the account is not being managed by Redhawk or Financial Advisor; or
• Retirement Plan ERISA 3(21) Investment Advisor Agreement; or
• ERISA retirement plan whereby the Financial Advisor is the advisor of record for the plan and Redhawk is not serving as an ERISA 3(21) Investment Advisor or a 3(38) Investment Manager. Additional information regarding Redhawk’s investment advisory services to wealth management and retirement plan Clients are described below. Wealth Management As part of the financial planning process, the Financial Advisor conducts a personal discussion with the Client and completes a risk tolerance assessment to determine the Client's goals and objectives. The Financial Advisor then determines the appropriate investment or investments that is in the best interest of the Client. Under this arrangement, the Client retains individual ownership of all securities. Redhawk’s investment recommendations are not limited to any specific product or service offered by a broker dealer, registered investment advisor, or insurance company and will generally include advice regarding the following securities, all of which are considered asset allocation categories for the Client's investment strategy:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Options
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• Exchange Traded Funds (“ETFs”)
• Unit Investment Trusts (“UITs”)
• Collective Investment Trust (“CITs”)
• United States governmental securities
• Structured products
• Cash and equivalents Redhawk continuously monitors the performance of accounts managed by third-party money managers and will assume discretionary authority to hire or fire the money manager where such action is deemed appropriate and in the best interest of the Client. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the Client's stated investment objectives, tolerance for risk, liquidity, and best interest. To ensure that the initial determination of an appropriate portfolio remains in the best interest of the Client and that the account continues to be managed in a manner consistent with the Client's financial circumstances, the Financial Advisor will: 1. Conduct a Client review, at least annually, to determine whether there have been any changes in the Client's financial situation or investment objectives, and whether the Client wishes to impose investment restrictions or modify existing restrictions. 2. Ensure that they be available to consult with the Client. 3. Maintain Client suitability information and the IPS in each Client's file. Financial Advisors have several choices for Client accounts and can utilize several investment platforms that are in the best interest of their Client including: Sub-Advisory Services – Redhawk may enter into agreements with unaffiliated registered investment advisors (hereafter referred to as an “Independent RIA”) whereby Redhawk oversees and manages on a discretionary basis some or all of the Independent RIA’s Client assets according to the investment strategy chosen by the Client. For Clients who enter into agreements with the Independent RIA in a joint capacity with Redhawk, both advisors oversee and manage, on a discretionary basis, some or all of the Client assets according to the investment management agreement(s). In these situations, the Client remains a Client of the Independent RIA and Redhawk. The decision as to what investment strategy(s) Client assets are invested in is based on suitability information gathered and reviewed by the Independent RIA. Redhawk manages these assets based on its investment strategies and not based on overall Client suitability. Strategies are managed on an ongoing basis. The Independent RIA is responsible for the administrative paperwork and servicing the accounts. Redhawk facilitates the billing on behalf of the Independent RIA. The Client will enter into a Risk-Guard Platform Investment Management t (“RGP”) agreement. There are no trading or transaction costs for individual stocks and ETFs. Client pays all transaction and trading costs for mutual funds, any regulatory fees, and there is not a minimum account balance that is required for this account. The minimum account balance for this type of account is $1,000. Legacy Account – An account that is customized for the Client. Redhawk executes the trades based on direction from either the Financial Advisor or Client. The Client will enter into a Risk-Guard Platform Investment Management agreement. There are no trading or transaction costs for individual stocks and ETFs. Client pays all transaction and trading costs for mutual funds, any regulatory fees, and there is not a minimum account balance that is required for this account. Managed Account – Includes various third-party money managers, mutual funds, and ETFs selected and monitored by Redhawk. Redhawk has full oversight over the investments and Redhawk executes the trades on behalf of the Client based on direction from the appointed Redhawk advisor. The Client will enter into a Risk-Guard Platform Investment Management agreement. There are no trading or transaction costs for individual stocks and ETFs. Client pays all transaction and trading costs for mutual funds, any regulatory fees, and the minimum account balance for a managed account is $1,000. Standard Open Investment Platform (“SOIP”) – An account that enables the Financial Advisor to have full- discretion and fiduciary oversight of the Client’s account. The Financial Advisor must execute the Redhawk IAR OIP Agreement with Redhawk, and the Financial Advisor is responsible to execute the Redhawk Standard Open Investment Platform Discretionary Investment Management Agreement with each Client. This agreement will give Redhawk the authority to deduct the Redhawk administration fee and Financial Advisor fee monthly. For this account, the Financial Advisor is responsible for executing trades and managing the account on behalf of the Client. There are no trading or transaction costs for individual stocks and ETFs. Client pays all transaction and trading costs for mutual funds and any regulatory fees. Trading Open Investment Platform (“TOIP”) – An account that enables the Financial Advisor to manage their own portfolios and Redhawk executes the trades on behalf of the Client based on direction from the Financial Advisor. The Financial Advisor must execute the Redhawk IAR OIP Agreement with Redhawk, and the Financial Advisor is responsible to execute the Redhawk Trading Open Investment Platform Discretionary Investment Management Agreement with each Client. This agreement will give Redhawk the authority to execute the trades and deduct the Redhawk administration fee and Financial Advisor fee monthly. There are no trading or transaction costs for individual stocks and ETFs. Client pays all transaction and trading costs for mutual funds and any regulatory fees. Managed Held Away Accounts Open Investment Platform (“HOIP”) – An account that is “held away” and custodied at an outside financial institution. For this type of account, the Financial Advisor is managing the account and providing financial planning oversight for the account. The Client gives authorization to Redhawk to access their account information, using a third-party service provider’s Order Management System and the account information is uploaded to Redhawk’s platform daily. This allows for Redhawk or the Financial Advisor to manage and trade the held away account. The third-party service provider is approved by Redhawk. The Financial Advisor must execute

the Redhawk IAR OIP Agreement with Redhawk, and the Financial Advisor is responsible to execute the Redhawk Held Away Open Investment Platform Management Agreement with each Client. The Client instructs Redhawk to either invoice them directly monthly or to take the fees out of a non-qualified account held at Redhawk monthly. There is not a minimum account size for this type of account. Redhawk uses a third-party platform to facilitate management of held away assets such as defined contribution plan participant accounts, with discretion. These are primarily 401(k) accounts, 403(b) accounts, 529 plans, Thrift Savings Plans (“TSP”), variable annuities, and other assets not held with the recommended custodian. The platform allows Redhawk to avoid being considered to have custody of Client funds since Redhawk does not have direct access to Client log-in credentials to affect trades. Redhawk is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the platform, Redhawk will review the current account allocations. When deemed necessary, Redhawk will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends using Risk-Guard as described in Item 8 below. Non-Managed Held Away Accounts Open Investment Platform (“HOIP”) – An account that is “held away” and custodied at an outside financial institution. For this type of account, the Financial Advisor is providing financial planning oversight on the account. The Client gives authorization to Redhawk to access their account information, using a third-party service provider’s data aggregation application and the account information is uploaded to Redhawk’s platform daily. The third-party service provider is approved by Redhawk. The Financial Advisor must execute the Redhawk IAR OIP Agreement with Redhawk, and the Financial Advisor is responsible to execute the Redhawk Held Away Open Investment Platform Management Agreement with each Client. The Financial Advisor pays for the data aggregation fees. There is not a minimum account size for this type of account. Standard Captive Insurance Company Accounts (“SCIC) – A CIC is created and wholly owned by one or more non-insurance companies to insure the risks of its owner (or owners). A CIC is essentially a form of self-insurance whereby the insurer is owned wholly by the insured. They are typically established to meet the risk-management needs of the owners or members. Once established the captive operates like any commercial insurance company and is subject to state regulatory requirements including reporting, capital, and reserve requirements. Redhawk has full oversight over the investments for the CIC and the account is invested in an asset allocation strategy managed by Redhawk. The minimum account size is $250,000. The Client will enter into a Standard Captive Insurance Company Investment Management Agreement and the Client pays for all trading and transaction costs. ET Group of Companies Captive Insurance Company Accounts (“ECIC) – ET Group of Companies is a part owner of Alink Captive Insurance Services. Alink Captive Insurance Services offers CICs to business owners of the companies that are part of ET Group of Companies. A CIC is created and wholly owned by one or more non- insurance companies to insure the risks of its owner (or owners). A CIC is essentially a form of self-insurance whereby the insurer is owned wholly by the insured. They are typically established to meet the risk-management needs of the owners or members. Once established the captive operates like any commercial insurance company and is subject to state regulatory requirements including reporting, capital, and reserve requirements. Redhawk has full oversight over the investments for the CIC and the account is invested in an asset allocation strategy managed by Redhawk. The minimum account size is $250,000. The Client will enter into an ET Group of Companies Captive Insurance Company Investment Management Agreement and the Client pays for all trading and transaction costs. Section 529 Plan Accounts – Are accounts that are established to save for future educational expenses. Redhawk has full oversight over the investments for these accounts and the accounts are invested in an asset allocation strategy managed by Redhawk. The Client will enter into a Section 529 Account Investment Management Agreement and the Client does not pay for trading and transaction costs. There is not a minimum account size for this type of account. 403(b) and 457(b) Retirement Accounts – Are accounts that are part of a tax-deferred retirement savings programs provided by certain employers. Employers such as public educational institutions (public schools, colleges, and universities), certain non-profits, and churches or church-related organizations may offer 403(b) plans. Employers such as state and local government agencies and certain non-profit organizations may offer 457(b) plans. Some employers may offer both 403(b) and 457(b) plans and allow contributions to both plans. Redhawk has full oversight over the investments for the 403(b) and 457(b) accounts and the accounts are invested in an asset allocation strategy managed by Redhawk. The Client will enter into a 403(b) and 457(b) Investment Management Agreement and the Client, depending on the custodian, may or may not pay for trading and transaction costs. There is not a minimum account size for this type of account. Retirement Plans ERISA Section 3(21) Investment Advisor and 3(38) Investment Management Services For employer-sponsored retirement plans, including cash balance plans, Redhawk provides its investment advisory services as an investment advisor as defined under Section 3(21) and as an investment manager as defined under Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). When serving as an ERISA 3(21) investment advisor, the plan sponsor and Redhawk share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the investments and may accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Investment Advisor Agreement between Redhawk and the plan sponsor. Redhawk provides the following services to the plan sponsor:
• Screen investments and make recommendations.
• Monitor the investments and suggests replacement investments when appropriate.
• Provide a monthly or quarterly monitoring report.
• Assist the plan sponsor in developing an IPS. When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of most of their fiduciary responsibilities for the investment decisions made by Redhawk. Redhawk is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Investment Management Agreement or a Cash Balance Investment Management Agreement between Redhawk and the plan sponsor. Redhawk provides the following services to the plan sponsor:
• Select the investments.
• Monitor the investments and replace investments when appropriate.
• Provide a monthly or quarterly monitoring report.
• Develop a customized IPS. Redhawk’s goal in identifying the plan’s investment options is to provide a range of options that will enable plan participants to invest according to varying risk tolerances, savings, time horizons, or other financial goals. The plan's investment options may consist of ETFs, CITs, mutual funds, portfolios, or other similar investment funds. The investment funds from which Redhawk will select from will be those that are available on the plan recordkeeper’s investment platform. Redhawk will prepare an IPS for the plan. The purpose of the IPS is to provide guidelines for making investment- related decisions in a prudent manner. It outlines the underlying philosophies and processes for the selection, monitoring, and replacement of the investment options offered by the plan. On a monthly or quarterly basis, Redhawk will perform on-going monitoring of the investment options within the plan. The ongoing monitoring of investments is a regular and disciplined process. Monitoring confirms that the criteria remain satisfied and that an investment option continues to be appropriate. The process of monitoring investment performance relative to specified guidelines will be consistently applied and Redhawk will provide the Client with a monitoring report. Disclosure Regarding Rollover Recommendations Redhawk is a fiduciary under the Investment Advisers Act of 1940 and when Redhawk provides investment advice to a Client regarding their retirement plan account or individual retirement account, Redhawk is also 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. Redhawk must act in the Client’s best interest and not put Redhawk’s interest ahead of the Client’s. At the same time, the way Redhawk makes money creates some conflicts with the Client’s interests. An employee leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). Redhawk may recommend a former employee roll over plan assets to an IRA for which Redhawk provides investment advisory services. As a result, Redhawk and its representatives may earn an asset-based fee. In contrast, a recommendation that a former employee leave their plan assets with their previous employer or roll over the assets to a plan sponsored by a new employer will generally result in no compensation to Redhawk. Redhawk therefore has an economic incentive to encourage a former employee to roll plan assets into an IRA that Redhawk will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that Redhawk will consider before recommending a rollover, including but not limited to: (i) the investment options available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals versus those of Redhawk, (iv) protection of assets from creditors and legal judgments, (v) required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any. Redhawk’s Chief Compliance Officer remains available to address any questions that a former employee has regarding the oversight. Financial Planning Through the financial planning process, the Financial Advisor engages with the Client to determine their goals, objectives, priorities, vision, and legacy (both for the near term as well as for future generations). With the unique goals and circumstances of each Client in mind, the Financial Advisor will offer financial planning ideas and strategies to address the Client’s holistic financial picture, including estate, income tax, charitable, cash flow, wealth transfer, and Client legacy objectives. The Financial Advisor partners with the Client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a coordinated effort of all parties toward the Client’s stated goals. Such services include various reports on specific goals and objectives or general investment and/or planning recommendations, guidance to outside assets, and periodic updates. Redhawk’s specific services in preparing the financial plan may include:
• Review and clarification of the Client’s financial goals.
• Assessment of Client’s overall financial position including cash flow, balance sheet, investment strategy, risk management, and estate planning.
• Creation of a unique plan for each goal, including personal and business real estate, education, retirement or financial independence, charitable giving, estate planning, business succession, and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors to the Client around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This includes IRA and qualified plans, taxable, and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer, including liquidity as well as various insurance and possible company benefits.
• Development and implementation of, in conjunction with the Client’s estate and/or corporate attorneys as tax adviser, an estate plan to provide for the Client’s heirs in the event of an incapacity or death. A written evaluation of the Client's initial situation and financial plan is provided to the Client. The Financial Advisor will review the financial plan with the Client based on the terms of the financial planning agreement.