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Part 2A of Form ADV: Firm Brochure
Hobbs Group Advisors, LLC
1727 Laurel Street
Columbia, SC 29201
Telephone: 803-540-3034
Email: info@hobbsgroupadvisors.com
Web Address: www.hobbsgroupadvisors.com
March 28, 2025
This brochure provides information about the qualifications and business practices of Hobbs Group
Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 803-
540-3034 or info@hobbsgroupadvisors.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority.
Registration with the SEC or with any state securities authority does not imply a certain level of skill or
training.
Additional information about Hobbs Group Advisors, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. Our firm's CRD number is 157274.
Item 2 Material Changes
This Firm Brochure provides you with a summary of Hobbs Group Advisors LLC's advisory
services and fees, professionals, certain business practices and policies, as well as actual or
potential conflicts of interest, among other things. This Item is used to provide our clients
with a summary of new and/or updated information; we will inform of the revision(s) based
on the nature of the information as follows.
1. Annual Update: We are required to update certain information at least annually, within
90 days of our firm’s fiscal year end (FYE) of December 31. We will provide you with
either a summary of the revised information with an offer to deliver the full revised
Brochure within 120 days of our FYE or we will provide you with our revised Brochure
that will include a summary of those changes in this Item.
2. Material Changes: Should a material change in our operations occur, depending on its
nature we will promptly communicate this change to clients (and it will be summarized in
this Item). "Material changes" requiring prompt notification will include changes of
ownership or control; location; disciplinary proceedings; significant changes to our
advisory services or advisory affiliates – any information that is critical to a client’s full
understanding of who we are, how to find us, and how we do business.
The following summarizes new or revised disclosures based on information previously
provided in our Firm Brochure dated 03/27/2024:
• No material changes
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Item 3 Table of Contents Page
Item 1 Cover Page
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Item 2 Material Changes
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Item 3
Table of Contents
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Item 4 Advisory Business
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Item 5
Fees and Compensation
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Item 6
Performance-Based Fees and Side-By-Side Management
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Item 7
Types of Clients
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9 Disciplinary Information
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Item 10 Other Financial Industry Activities and Affiliations
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Item 12 Brokerage Practices
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Item 13 Review of Accounts
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Item 14 Client Referrals and Other Compensation
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Item 15 Custody
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Item 16
Investment Discretion
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Item 17 Voting Client Securities
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Item 18 Financial Information
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Item 19 Requirements for State-Registered Advisers
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Item 4 Advisory Business
Hobbs Group Advisors, LLC is a registered investment adviser with the Securities and
Exchange Commission. Its principal place of business located in Columbia, South Carolina.
Hobbs Group Advisors, LLC began conducting business in 2007.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities
controlling 25% or more of this company).
• Mark T. Hobbs, President
• Peter A. Pigeon, Chief Executive Officer
• Garet Strange, Chief Operating Officer
Hobbs Group Advisors, LLC offers the following advisory services to our clients:
INVESTMENT SUPERVISORY SERVICES ("ISS")
INVESTMENT MANAGEMENT AND WEALTH MANAGEMENT
Our firm provides continuous advice to a client regarding the investment of client funds based
on the individual needs of the client. Through personal discussions in which goals and
objectives based on a client's particular circumstances are established, we develop a client's
personal investment policy and create and manage a portfolio based on that policy. During
our data-gathering process, we determine the client’s individual objectives, time horizons, risk
tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior
investment history, as well as family composition and background.
Hobbs Group Advisors, LLC, in providing the services agreed upon with the client, may
recommend hereafter ("the sub-adviser"), an investment adviser registered under applicable
securities laws, as a sub-adviser to manage all or a portion of the managed assets in the
Client's account. If this occurs, Hobbs Group Advisors, LLC will be responsible for the
continuing supervision of the Client's account, and the actions of the sub-adviser in connection
with the Client's account and the managed assets. Hobbs Group Advisors, LLC also will be
responsible for the payment of any advisory fee or other charges of the sub-adviser with
respect to the managed assets unless it has been stated differently in writing with the Client.
Hobbs Group Advisors, LLC agrees that upon proper notice by the Client, Hobbs Group
Advisors, LLC will refrain from the appointment of, or terminate as permitted under applicable
contracts, any sub-adviser appointed pursuant to this authority.
Investment Management (Digital Platform)
HGA utilizes Betterment for digital investment management, wherein an asset allocation
strategy will be provided by a Sub-Advisor for asset management services that is
consistent with the Client’s investment objectives. HGA will utilize risk tolerance and
data gathering questionnaires to determine the most appropriate asset allocation
strategy. On an ongoing basis, HGA will monitor the performance of a client’s portfolio
and Sub-Advisor will rebalance as necessary to conform to the recommended allocation.
Clients typically grant HGA and Sub-Advisor a limited power of attorney over their
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brokerage accounts to determine the amount of securities purchased or sold for their
accounts. Adviser may provide performance reports to clients quarterly, semi-annually
or annually.
Investment Management (Traditional)
HGA will design a customized asset allocation strategy or recommend the services of a Sub-
Advisor for asset management services that is consistent with the Client’s
investment objectives. HGA will utilize risk tolerance and data gathering questionnaires
to determine the most appropriate asset allocation strategy. On an ongoing basis, HGA will
monitor the performance of a client’s portfolio and will rebalance as necessary to
conform to the recommended allocation. Clients typically grant HGA and Sub-Advisor, if
applicable, a limited power of attorney over their brokerage accounts to determine the
amount of securities purchased or sold for their accounts. HGA may provide
performance reports to clients quarterly, semi-annually or annually.
Wealth Management
Wealth Management combines elements from our Investment Management and
Financial Planning Services into one comprehensive engagement. HGA will design a
customized asset allocation strategy or recommend the services of a Sub-Advisor for
asset management services that is consistent with the Client’s investment objectives.
HGA will utilize risk tolerance and data gathering questionnaires to determine the most
appropriate asset allocation strategy. On an ongoing basis, HGA will monitor the
performance of a client’s portfolio and will rebalance as necessary to conform to the
recommended allocation. Clients typically grant HGA and Sub-Advisor, if applicable, a
limited power of attorney over their brokerage accounts to determine the amount of
securities purchased or sold for their accounts. HGA may provide performance reports
to clients quarterly, semi-annually or annually. HGA will also provide financial planning
services including but not limited to: retirement projections, cash flow analysis, net worth
analysis, evaluation of Clients existing or potential investments, investment
management strategies, gifting strategies, and estate planning. Adviser may also
provide specific financial planning advice for targeted areas as needed by the client.
Additional Information
We manage these advisory accounts on a discretionary or non-discretionary basis. Account
supervision is guided by the client's stated objectives (i.e., maximum capital appreciation,
growth, income, or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered
by a broker-dealer or insurance company and will generally include advice regarding the
following securities:
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• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
•
Interests in partnerships investing in real estate
•
Interests in partnerships investing in oil and gas interests
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 suitability.
Hobbs Group Advisors, LLC utilizes the services of another Independent Registered
Investment Advisor for participation in its periodic Investment Committee meetings.
PENSION CONSULTING SERVICES
HGA provides pension consulting services separately or in combination with other services.
While the primary clients for these services will be pension, profit sharing and 401(k) plans,
we offer these services, where appropriate, to individuals and trusts, estates and charitable
organizations. Pension Consulting Services are comprised of the distinct services listed
below. Clients may choose to use any or all of these services.
Plan Design
We will meet with the client (in person or over the telephone) to discuss the major plan
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goals, identify the key employees, options for contributions and income tax considerations.
HGA will determine an appropriate investment strategy that reflects the plan sponsor's
stated investment objectives for management of the overall plan. HGA may then prepare a
written IPS detailing those needs and goals, including an encompassing policy under which
these goals are to be achieved. The IPS would list the criteria for selection of investment
vehicles as well as the procedures and timing interval for monitoring of investment
performance.
Designing the Investment Lineup
HGA will design an investment lineup that meets the plan sponsor’s goals and objectives.
HGA will monitor the investments for potential changes and analyze ways for the plan
sponsor to minimize compliance risk. HGA assists plan sponsors in constructing
appropriate asset allocation models. We will then review various mutual funds (both index
and managed) to determine which investments are appropriate to implement the client's
desired strategy. The number of investments to be recommended will be determined by the
client, based on the needs of the client.
Administration of the Plan
HGA assists with informing the plan sponsor of the rules concerning employee
communication, funding contributions, and staying compliant. HGA is also available for
support questions regarding enrollment, contributions, rollovers, employee terminations and
coordination with the plan’s Third-Party Administrator. We monitor client investments
continually, based on the procedures and timing intervals delineated in the Investment Policy
Statement. Although our firm is not involved in any way in the purchase or sale of these
investments, we supervise the client's portfolio and will make recommendations to the client
as market factors and the client's needs dictate.
Service
HGA creates a service schedule for servicing plan fiduciaries and participants. HGA may
provide education meetings to the participants regarding the plan. Fiduciary meetings with
the plan sponsor occur at least annually, with the frequency determined depending on the
needs of each plan.
Education
HGA creates an education plan for the participants of the plan, with a focus of retirement
outcomes for the participants. For pension, profit sharing and 401(k) plan clients with
individual plan participants exercising control over assets in their own account (''self-directed
plans''), we also provide quarterly educational support and investment workshops designed
for the plan participants when the plan sponsor engages our firm to provide these services.
The nature of the topics to be covered will be determined by us and the client under the
guidelines established in ERISA Section 404(c). The educational support and investment
workshops will NOT provide plan participants with individualized, tailored investment advice
or individualized, tailored asset allocation recommendations.
Fiduciary Support
If acting as an ERISA 3(38) fiduciary, HGA will have the discretion to make fund decisions,
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such as hiring and firing service providers, reviewing proposals from service providers,
investment selection and monitoring decisions.
FINANCIAL PLANNING
We provide financial planning services. Financial planning is a comprehensive evaluation of
a client’s current and future financial state by using currently known variables to predict
future cash flows, asset values and withdrawal plans. Through the financial planning
process, all questions, information, and analysis are considered as they impact and are
impacted by the entire financial and life situation of the client. Depending on the scope of the
financial services, clients purchasing financial planning services may receive a written report
which provides the client with a detailed financial plan designed to assist the client achieve
his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate
information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning
for past, current and future years; then illustrate the impact of various investments on
the client's current income tax and future tax liability.
•
INVESTMENTS: We analyze investment alternatives and their effect on the
client's portfolio.
•
INSURANCE: We review existing policies to ensure proper coverage for life,
health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the
client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs
of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including
as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection
plans, nursing homes, Medicaid, and elder law.
We gather required information through in-depth personal interviews. Information gathered
includes the client's current financial status, tax status, future goals, returns objectives and
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attitudes towards risk. We carefully review documents supplied by the client, including a
questionnaire completed by the client, and prepare a written report. Should the client choose
to implement the recommendations contained in the plan, we suggest the client work closely
with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of
financial plan recommendations is entirely at the client's discretion.
We also provide general non-securities advice on topics that may include tax and budgetary
planning, estate planning and business planning.
• Exchange-listed securities
• Securities traded over-the-counter
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
•
Interests in partnerships investing in real estate
•
Interests in partnerships investing in oil and gas interests
Typically, the financial plan is presented to the client within six months of the contract date,
provided that all information needed to prepare the financial plan has been promptly
provided.
Financial Planning recommendations are not limited to any specific product or service
offered by a broker-dealer or insurance company. All recommendations are of a generic
nature.
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CONSULTING SERVICES
Clients can also receive investment advice on a more focused basis. This may include
advice on only an isolated area(s) of concern such as estate planning, retirement planning,
or any other specific topic. We also provide specific consultation and administrative services
regarding investment and financial concerns of the client.
Consulting recommendations are not limited to any specific product or service offered by
a broker-dealer or insurance company. All recommendations are of a generic nature.
AMOUNT OF MANAGED ASSETS
As of February 28, 2025, we were actively managing $363,300,000 of clients' assets on a
discretionary basis plus $115,800,000 of clients' assets on a non-discretionary basis.
Item 5
Fees and Compensation
INVESTMENT SUPERVISORY SERVICES ("ISS")
INVESTMENT MANAGEMENT AND WEALTH MANAGEMENT FEES
Investment Management (Digital Platform)
Fees for Digital Investment Management are based on a percentage of assets under
management. They are billed quarterly in advance. Fees for the initial quarter will be
prorated based upon the number of calendar days in the calendar quarter that the advisory
agreement is in effect. Fees are based on the market value of the assets on the last
business day of the previous quarter. The annual fee is .85%.
The quarterly fee is calculated as follows: The market value of the assets under
management on the last business day of the previous quarter multiplied by ¼ of the annual
advisor fee. Betterment charges a separate fee to the client for access to their platform.
This fee starts at .20% and can be reduced based on the total amount of assets our firm
manages at Betterment. We do not share in Betterments fee, and this fee is disclosed by
Betterment.
Investment Management (Traditional)
Our annual fees for Investment Management are based on a percentage of assets under
management and generally range from 0.65% to 1.25% depending on the level of
complexity, amount of time required by staff, and amount of assets under management.
Hobbs Group Advisors LLC may group certain related client accounts for the purposes of
achieving the minimum account size and determining the annualized fee.
Our fees are billed quarterly, in advance, at the beginning of each calendar quarter based
upon the value (market value or fair market value in the absence of market value), of the
client's account at the end of the previous quarter. Fees will be debited from the account in
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accordance with the client authorization in the Client Services Agreement.
Fees for the initial quarter will be prorated based upon the number of calendar days in the
calendar quarter that the advisory agreement is in effect. Fees are based on the market
value of the assets on the last business day of the previous quarter.
Wealth Management
Our annual fees for Wealth Management are based on a percentage of assets under
management, based on the following schedule:
Up to $1,000,000
$1,000,001-$2,500,000
$2,500,001-$5,000,000
$5,000,001-$10,000,000
$10,000,000+
1.25%
1%
.85%
.75%
negotiable
There is a minimum annual fee of $6,250. This fee minimum may be negotiable under
certain circumstances. Hobbs Group Advisors LLC may group certain related client
accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
Our fees are billed quarterly, in advance, at the beginning of each calendar quarter based
upon the value (market value or fair market value in the absence of market value), of the
client's account at the end of the previous quarter. Fees will be debited from the account in
accordance with the client authorization in the Client Services Agreement.
Cash Management
Hobbs Group Advisors offers Cash Management Services through the use of Cash and Cash
Equivalents (CDs, Treasury Bills, Money Market Mutual Funds). Typically, HGA will recommend
a Cash Management Account for a portion of Client assets outside of a Managed Account
Program. Cash management fees are paid quarterly, in advance of each calendar quarter,
pursuant to the terms of the agreement. Cash management fees are based on the market value
of assets under management at the end of the prior calendar quarter. Cash management
service fees range from 0.25% to 0.50% annually based on the level of assets to be managed,
and the overall relationship with the Advisor. All other assets under management of the firm can
be aggregated for the purpose of achieving the breakpoints for cash management. Fee
schedule is as follows:
$0- $250,000 .50%
$250,001-$1,000,000 .35%
$1,000,001+ .25%
FINANCIAL PLANNING FEES
Hobbs Group Advisors, LLC's Financial Planning fee is determined based on the nature of
the services being provided and the complexity of each client’s circumstances. All fees are
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agreed upon prior to entering into a contract with any client.
Although the length of time it will take to provide a Financial Plan will depend on each client's
personal situation, we will provide an estimate for the total hours at the start of the advisory
relationship.
The fee range for hourly financial planning services is $300 per hour. Financial planning
may also be charged as a fixed fee ranging between $1,000- $10,000. The client is billed in
arrears based on actual hours accrued. In some cases, a retainer fee in the amount of ½ the
projected cost of the engagement may be required. A minimum fee of $1,000 per
engagement is required.
Financial Planning Fee Offset: HGA gives a credit for financial planning fees paid
against investment management fees if a client engages our firm for Wealth
Management services. For example, if a client pays $1,000 towards a financial plan,
HGA will credit these fees towards quarterly Wealth Management fees until the credit is
fully offset.
CONSULTING SERVICES FEES
Hobbs Group Advisors, LLC's Consulting Services fee is determined based on the nature of
the services being provided and the complexity of each client’s circumstances. All fees are
agreed upon prior to entering into a contract with any client.
Our Consulting Services fees are calculated and charged on an hourly basis or as a fixed
fee. An estimate for the total hours is determined at the start of the advisory relationship.
The hourly fee range for consulting services is $175 - $300 per hour. Fixed Fees range from
$750-$10,000. In some cases, a retainer fee is required.
PENSION CONSULTING FEES
Our fees for Pension Consulting Services are based on a percentage of assets under
advisement, with a general range between .25% to 1.00% annually. Pension Consulting
Fees may also be charged on a fixed rate basis and can be billed monthly, quarterly, or
annually. This fee would be between $2,000 and $50,000 annually.
Plan sponsors and/or plan participants are invoiced in advance or in arrears at the beginning
of their negotiated billing period depending on the set-up with their respective recordkeeper.
Certain recordkeepers collect the quarterly fee in advance, while others require fees to be
billed in arrears.
GENERAL INFORMATION
Limited Negotiability of Advisory Fees: Although Hobbs Group Advisors, LLC has
established the aforementioned fees, we retain the discretion to negotiate alternative fees
on a client-by-client basis. Client facts, circumstances and needs are considered in
determining the fee schedule. These include the complexity of the client, assets to be placed
under management, anticipated future additional assets; related accounts; portfolio style,
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account composition, reports, among other factors. The specific annual fee is identified in
the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum
account size requirements and determining the annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family members
and friends of associated persons of our firm.
Termination of the Advisory Relationship: A client agreement may be canceled at any
time, by either party, for any reason upon receipt of 30 days written notice. [As disclosed
above, certain fees are paid in advance of services provided.] Upon termination of any
account, any prepaid, unearned fees will be promptly refunded. [In calculating a client’s
reimbursement of fees, we will pro rate the reimbursement according to the number
of days remaining in the billing period.]
Mutual Fund Fees: All fees paid to Hobbs Group Advisors, LLC for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds
and/or ETFs to their shareholders. These fees and expenses are described in each fund's
prospectus. These fees will generally include a management fee, other fund expenses, and
a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial
or deferred sales charge. A client could invest in a mutual fund directly, without our services.
In that case, the client would not receive the services provided by our firm which are
designed, among other things, to assist the client in determining which mutual fund or funds
are most appropriate to each client's financial condition and objectives. Accordingly, the
client should review both the fees charged by the funds and our fees to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory services
being provided.
Wrap Fee Programs and Separately Managed Account Fees: Clients participating in
separately managed account programs may be charged various program fees in addition to
the advisory fee charged by our firm. Such fees may include the investment advisory fees of
the independent advisers, which may be charged as part of a wrap fee arrangement. In a
wrap fee arrangement, clients pay a single fee for advisory, brokerage and custodial
services. Client’s portfolio transactions may be executed without commission charge in a
wrap fee arrangement. In evaluating such an arrangement, the client should also consider
that, depending upon the level of the wrap fee charged by the broker-dealer, the amount of
portfolio activity in the client’s account, and other factors, the wrap fee may or may not
exceed the aggregate cost of such services if they were to be provided separately. We will
review with clients any separate program fees that may be charged to clients.
Additional Fees and Expenses: In addition to our advisory fees, clients are also
responsible for the fees and expenses charged by custodians and imposed by broker
dealers, including, but not limited to, any transaction charges imposed by a broker dealer
with which an independent investment manager effects transaction for the client's
account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for
additional information.
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Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are
subject to Hobbs Group Advisors, LLC's minimum account requirements and advisory fees
in effect at the time the client entered into the advisory relationship. Therefore, our firm's
minimum account requirements will differ among clients.
ERISA Accounts: Hobbs Group Advisors, LLC is deemed to be a fiduciary to advisory
clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to
the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the
Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to
specific duties and obligations under ERISA and the Internal Revenue Code that include
among other things, restrictions concerning certain forms of compensation. To avoid
engaging in prohibited transactions, Hobbs Group Advisors, LLC may only charge fees for
investment advice about products for which our firm and/or our related persons do not
receive any commissions or 12b-1 fees, or conversely, investment advice about products
for which our firm and/or our related persons receive commissions or 12b-1 fees, however,
only when such fees are used to offset Hobbs Group Advisors, LLC's advisory fees.
Advisory Fees in General: Clients should note that similar advisory services may (or may
not) be available from other registered (or unregistered) investment advisers for similar or
lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of
fees in excess of $1200 more than six months in advance of services rendered.
Item 6
Performance-Based Fees and Side-By-Side Management
Hobbs Group Advisors LLC does not charge performance-based fees.
Item 7 Types of Clients
Hobbs Group Advisors LLC provides advisory services to the following types of clients:
•
Individuals (other than high net worth individuals)
• High net worth individuals
• Pension and profit sharing plans
• Charitable Organizations
• Corporations or other businesses not listed above
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or
managing client assets:
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Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking
at economic and financial factors (including the overall economy, industry conditions, and
the financial condition and management of the company itself) to determine if the company
is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be
time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to
identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s
investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a
particular security, industry, or market sector. Another risk is that the ratio of securities,
fixed income, and cash will change over time due to stock and market movements and, if
not corrected, will no longer be appropriate for the client’s goals.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions.
We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if
there is significant overlap in the underlying investments held in another fund(s) in the
client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are
continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may
not be able to replicate that success in the future. In addition, as we do not control the
underlying investments in a fund or ETF, managers of different funds held by the client may
purchase
the same security, increasing the risk to the client if that security were to fall in value. There
is also a risk that a manager may deviate from the stated investment mandate or strategy of
the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption
that the companies whose securities we purchase and sell, the rating agencies that review
these securities, and other publicly available sources of information about these securities,
are providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such
strategy(ies) are appropriate to the needs of the client and consistent with the client's
investment objectives, risk tolerance, and time horizons, among other considerations:
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Long-term purchases. We purchase securities with the idea of holding them in the client's
account for a year or longer. Typically, we employ this strategy when:
• we believe the securities to be currently undervalued, and/or
• we want exposure to a particular asset class over time, regardless of the current
projection for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time,
we may not take advantage of short-term gains that could be profitable to a client. Moreover,
if our predictions are incorrect, a security may decline sharply in value before we make the
decision to sell.
Short-Term Purchases. We purchase securities with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of
the securities’ short-term price fluctuations.
Short-term purchase Risk. The prices of securities fluctuate, sometimes dramatically.
The price of a security may move up or down and may become valueless. It is as likely
that losses will be incurred rather than profit made as a result of buying and selling
securities. There is inherent risk in short-term investments since material declines in value
may not have time to recover.
Risk of Loss. Securities investments are not guaranteed, and you may lose money on
your investments. We ask that you work with us to help us understand your tolerance for
risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Management personnel of our firm are also partners in the accounting firm of The Hobbs
Group, PA, where they are individually licensed and practicing Certified Public Accountants
providing accounting services for separate and typical compensation, and Wealth Alliance,
Incorporated, where they are insurance licensed.
The Hobbs Group, PA typically recommends Hobbs Group Advisors LLC to accounting
clients in need of advisory services. Conversely, Hobbs Group Advisors LLC typically
recommends The Hobbs Group, PA to advisory clients in need of accounting services.
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Accounting services provided by The Hobbs Group, PA are separate and distinct from our
advisory services, and are provided for separate and typical compensation. There may be
referral fee arrangements between our firms for these recommendations, but this will not
result in the client paying a higher fee. No Hobbs Group Advisors LLC client is obligated to
use The Hobbs Group, PA for any accounting services and conversely, no accounting client
is obligated to use the advisory services provided by us. The Hobbs Group, PA's accounting
services do not include the authority to sign checks or otherwise disburse funds on any of
our advisory client's behalf.
These individuals will spend the majority of their time on their accounting practice.
Management personnel of our firm, in their individual capacities, are agents for various
insurance companies. As such, these individuals are able to receive separate, yet
customary commission compensation resulting from implementing product transactions on
behalf of advisory clients as employees of Wealth Alliance, Incorporated or
independently. Clients, however, are not under any obligation to engage these individuals
when considering implementation of advisory recommendations. The implementation of
any or all recommendations is solely at the discretion of the client.
Clients should be aware that the receipt of additional compensation by Hobbs Group
Advisors LLC and its management persons or employees creates a conflict of interest that
may impair the objectivity of our firm and these individuals when making advisory
recommendations. Hobbs Group Advisors LLC endeavors at all times to put the interest of
its clients first as part of our fiduciary duty as a registered investment adviser; we take the
following steps to address this conflict:
• we disclose to clients the existence of all material conflicts of interest, including the
potential for our firm and our employees to earn compensation from advisory clients
in addition to our firm's advisory fees;
• we disclose to clients that they are not obligated to purchase recommended
investment products from our employees or affiliated companies;
• we collect, maintain and document accurate, complete and relevant client
background information, including the client’s financial goals, objectives, and risk
tolerance;
• our firm's management conducts regular reviews of each client account to verify that all
recommendations made to a client are suitable to the client’s needs and
circumstances;
• we require that our employees seek prior approval of any outside employment activity
so that we may ensure that any conflicts of interests in such activities are properly
addressed;
• we periodically monitor these outside employment activities to verify that any conflicts
of interest continue to be properly addressed by our firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including the
need for having a reasonable and independent basis for the investment advice provided
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to clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business
conduct that we require of our employees, including compliance with applicable federal
securities laws.
Hobbs Group Advisors LLC and our personnel have a duty of loyalty, fairness and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the
Code of Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as initial and annual securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics also requires
the prior approval of any acquisition of securities in a limited offering (e.g., private placement)
or an initial public offering. Our code also provides for oversight, enforcement, and
recordkeeping provisions.
Hobbs Group Advisors LLC's Code of Ethics further includes the firm's policy prohibiting the
use of material non-public information. While we do not believe that we have any particular
access to non-public information, all employees are reminded that such information may
not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients.
You may request a copy by email sent to info@hobbsgroupadvisors.com, or by calling us
at 803-540-3034.
Hobbs Group Advisors LLC and individuals associated with our firm are prohibited from
engaging in principal transactions.
Hobbs Group Advisors LLC may, at times, effect an agency cross transaction for an advisory
client, provided that the transaction is consistent with our firm's fiduciary duty to the client and
that all requirements outlined in Sec. 206(3)-2 of the Investment Advisers Act of 1940 are met.
An agency cross transaction is a transaction where our firm acts as an investment adviser in
relation to a transaction in which Hobbs Group Advisors, LLC, acts as broker for two
advisory clients.
Our Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of our employees will not interfere with (i) making decisions in the best interest
of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal
accounts securities identical to or different from those recommended to our clients. In
addition, any related person(s) may have an interest or position in a certain security(ies)
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which may also be recommended to a client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any
security prior to a transaction(s) being implemented for an advisory account, thereby
preventing such employee(s) from benefiting from transactions placed on behalf of advisory
accounts.
As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm
are separately licensed as an insurance agent/broker of Wealth Alliance, Incorporated.
Please refer to Item 10 for a detailed explanation of these relationships and important
conflict of interest disclosures.
Item 12 Brokerage Practices
For discretionary clients, Hobbs Group Advisors LLC requires these clients to provide us with
written authority to determine the broker dealer to use and the commission costs that will be
charged to these clients for these transactions.
These clients must include any limitations on this discretionary authority in this written
authority statement. Clients may change/amend these limitations as required. Such
amendments must be provided to us in writing.
Hobbs Group Advisors, LLC will block trades where possible and when advantageous to
clients. This blocking of trades permits the trading of aggregate blocks of securities
composed of assets from multiple client accounts, so long as transaction costs are shared
equally and on a pro-rated basis between all accounts included in any such block.
Block trading may allow us to execute equity trades in a timelier, more equitable manner, at
an average share price. Hobbs Group Advisors, LLC will typically aggregate trades among
clients whose accounts can be traded at a given broker, and generally will rotate or vary the
order of brokers through which it places trades for clients on any particular day. Hobbs Group
Advisors, LLC's block trading policy and procedures are as follows:
Transactions for any client account may not be aggregated for execution if the practice is
prohibited by or inconsistent with the client's advisory agreement with Hobbs Group Advisors,
LLC, or our firm's order allocation policy.
1) The trading desk in concert with the portfolio manager must determine that the purchase
or sale of the particular security involved is appropriate for the client and consistent with the
client's investment objectives and with any investment guidelines or restrictions applicable to
the client's account.
2) The portfolio manager must reasonably believe that the order aggregation will benefit,
and will enable Hobbs Group Advisors, LLC to seek best execution for each client
participating in the aggregated order. This requires a good faith judgment at the time the
order is placed for the execution. It does not mean that the determination made in advance
of the transaction must always prove to have been correct in the light of a "20-20 hindsight"
perspective. Best execution includes the duty to seek the best quality of execution, as well
as the best net price.
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3) Prior to entry of an aggregated order, a written order ticket must be completed which
identifies each client account participating in the order and the proposed allocation of
the order, upon completion, to those clients.
4) If the order cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated pro rata among the
participating client accounts in accordance with the initial order ticket or other written
statement of allocation. However, adjustments to this pro rata allocation may be made to
participating client accounts in accordance with the initial order ticket or other written
statement of allocation. Furthermore, adjustments to this pro rata allocation may be made
to avoid having odd amounts of shares held in any client account, or to avoid excessive
ticket charges in smaller accounts.
5) Generally, each client that participates in the aggregated order must do so at the average
price for all separate transactions made to fill the order and must share in the commissions
on a pro rata basis in proportion to the client's participation. Under the client’s agreement
with the custodian/broker, transaction costs may be based on the number of shares traded
for each client.
6) If the order will be allocated in a manner other than that stated in the initial statement of
allocation, a written explanation of the change must be provided to and approved by the
Chief Compliance Officer no later than the morning following the execution of the aggregate
trade.
7) Hobbs Group Advisors, LLC's client account records separately reflect, for each account
in which the aggregated transaction occurred, the securities which are held by, and bought
and sold for, that account.
8) Funds and securities for aggregated orders are clearly identified on Hobbs Group
Advisors, LLC's records and to the broker-dealers or other intermediaries handling
the transactions, by the appropriate account numbers for each participating client.
9) No client or account will be favored over another.
Hobbs Group Advisors LLC has an arrangement with National Financial Services LLC and
Fidelity Brokerage Services LLC (collectively, and together with all affiliates, "Fidelity")
through which Fidelity provides our firm with "institutional platform services." The
institutional platform services include, among others, brokerage, custody, and other related
services.
Fidelity's institutional platform services that assist us in managing and administering clients'
accounts include software and other technology that (i) provide access to client account
data (such as trade confirmations and account statements); (ii) facilitate trade execution
and allocate aggregated trade orders for multiple client accounts; (iii) provide research,
pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and
(v) assist with back-office functions, recordkeeping and client reporting.
Fidelity also offers other services intended to help our firm manage and further develop its
advisory practice. Such services include, but are not limited to, performance reporting,
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financial planning, contact management systems, third party research, publications, access
to educational conferences, roundtables and webinars, practice management resources,
access to consultants and other third party service providers who provide a wide array of
business related services and technology with whom Hobbs Group Advisors LLC may
contract directly.
Hobbs Group Advisors LLC is independently operated and owned and is not affiliated with
Fidelity.
Fidelity generally does not charge its advisor clients separately for custody services but
is compensated by account holders through commissions and other transaction-related
or asset-based fees for securities trades that are executed through Fidelity or that settle
into Fidelity accounts (i.e., transactions fees are charged for certain no-load mutual
funds, commissions are charged for individual equity and debt securities transactions).
Fidelity
provides access to many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges.
As a result of receiving such services for no additional cost, we may have an incentive to
continue to use or expand the use of Fidelity's services. We examined this potential conflict
of interest when we chose to enter into the relationship with Fidelity and have determined
that the relationship is in the best interests of Hobbs Group Advisors LLC's clients and
satisfies our client obligations, including our duty to seek best execution. A client may pay a
commission that is higher than another qualified broker-dealer might charge to effect the
same transaction where we determine in good faith that the commission is reasonable in
relation to the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range
of a broker-dealer’s services, including the value of research provided, execution capability,
commission rates, and responsiveness. Accordingly, while Hobbs Group Advisors LLC will
seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest
possible commission rates for specific client account transactions. Although the investment
research products and services that may be obtained by us will generally be used to service
all of our clients, a brokerage commission paid by a specific client may be used to pay for
research that is not used in managing that specific client’s account.
Item 13 Review of Accounts
INVESTMENT SUPERVISORY SERVICES ("ISS")
INDIVIDUAL PORTFOLIOMANAGEMENT
REVIEWS: While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed at least quarterly.
Accounts are reviewed in the context of each client's stated investment objectives and
guidelines. More frequent reviews may be triggered by material changes in variables such as
the client's individual circumstances, or the market, political or economic environment.
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These accounts are reviewed by: Peter A. Pigeon, CFP
D. Garet Strange, CFP
Thomas Manly, CFP
Marc Murray
REPORTS: In addition to the monthly statements and confirmations of transactions that
clients receive from their broker-dealer, we provide quarterly reports summarizing
account performance, balances, and holdings.
PENSION CONSULTING SERVICES
REVIEWS: Hobbs Group Advisors LLC will review the client's needs and suitability
whenever the client advises us of a change in circumstances regarding the needs of the
plan. Hobbs Group Advisors LLC will also review the investment options of the plan
according to the agreed upon time intervals established by the client. Such reviews will
generally occur annually.
These accounts are reviewed by: Peter A Pigeon, CFP
D. Garet Strange, CFP
Thomas Manly, CFP
REPORTS: These client accounts will receive reports as contracted for at the inception of
the advisory relationship.
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms
of the specific engagement, typically no formal reviews will be conducted for Financial
Planning clients unless otherwise contracted for.
REPORTS: Financial Planning clients will receive financial planning deliverable(s). Additional
reports will not typically be provided unless otherwise contracted for.
CONSULTING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms
of the specific engagement, typically no formal reviews will be conducted for Consulting
Services clients unless otherwise contracted for. Such reviews will be conducted by the
client's account representative.
REPORTS: These client accounts will receive reports as contracted for at the inception of
the advisory engagement.
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Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
Our firm may refer clients to other independent firms depending on the circumstances. In
this event, Hobbs Group Advisors, LLC would be acting as a Promoter to the other firm.
Hobbs Group Advisors, LLC has a Promoter’s Agreement with the other independent firm(s)
and the client is required to receive a Promoter’s Disclosure Document disclosing the referral
fee that is paid to Hobbs Group Advisors, LLC.
Our firm may engage in promoter arrangements for client referrals. These individual promoters
offer our services to the public. The Firm pays a referral fee to the promoter based on a portion
of the management fees charged by the Firm and memorialized in a written agreement (“Promoter
Agreement”). In all cases, the Firm will comply with the cash solicitation rules established by the
SEC, state regulators and the client disclosure requirements. If a referred prospective client enters
into an investment advisory agreement with the Firm, a referral fee is paid to the referring party.
The referral relationship will not result in clients being charged any fees over and above the normal
advisory fees charged for the advisory services provided. The Firm will pay the promoter their
share of the total fee. The Promoter Agreement requires that the promoter be appropriately
registered under federal and state securities laws where applicable. Clients receive all related
agreements and disclosures prior to or at the time of entering into an Investment Advisory
Agreement with the Firm.
Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure
that our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required to
send to the client a statement showing all transactions within the account during the
reporting period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy of
the calculation, among other things. Clients should contact us directly if they believe that
there may be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, we
also send account statements directly to our clients on a quarterly basis. We urge our
clients to carefully compare the information provided on these statements to ensure that all
account transactions, holdings, and values are correct and current.
Standing Letters of Authorization
Some clients may execute limited powers of attorney or other standing letters of
authorization that permit the firm to transfer money from their account with the client’s
independent qualified Custodian to third-parties. This authorization to direct the Custodian
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may be deemed to cause our firm to exercise limited custody over your funds or securities
and for regulatory reporting purposes, we are required to keep track of the number of clients
and accounts for which we may have this ability. We do not have physical custody of any of
your funds and/or securities. Your funds and securities will be held with a bank, broker-
dealer, or other independent, qualified custodian. You will receive account statements from
the independent, qualified custodian(s) holding your funds and securities at least quarterly.
The account statements from your custodian(s) will indicate any transfers that may have
taken place within your account(s) each billing period. You should carefully review account
statements for accuracy.
Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we
place trades in a client's account without contacting the client prior to each trade to obtain
the client's permission.
Our discretionary authority includes the ability to do the following without contacting the
client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with our firm
and may limit this authority by giving us written instructions. Clients may also change/amend
such limitations by once again providing us with written instructions.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although
our firm may provide investment advisory services relative to client investment assets, clients
maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by
issuers of securities beneficially owned by the client shall be voted, and (2) making all
elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or
other type events pertaining to the client’s investment assets. Clients are responsible for
instructing each custodian of the assets, to forward to the client copies of all proxies and
shareholder communications relating to the client’s investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact us
with questions at our principal place of business.
Item 18 Financial Information
As an advisory firm that maintains discretionary authority for client accounts, we are
also required to disclose any financial condition that is reasonable likely to impair our ability
to meet our contractual obligations. Hobbs Group Advisors LLC has no such financial
circumstances to report.
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Under no circumstances do we require or solicit payment of fees in excess of $1,200 per
client more than six months in advance of services rendered. Therefore, we are not required
to include a financial statement.
Hobbs Group Advisors LLC has not been the subject of a bankruptcy petition at any time
during the past ten years.
Item 19 Requirements for State-Registered Advisers
This section is not applicable, as the firm is registered with the SEC.
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