HOLISTIC FINANCIAL PARTNERS, LLC

Disclosure Brochure HOLISTIC FINANCIAL PARTNERS, LLC Registered Investment Adviser March 19, 2025 9959 Crosspoint Blvd Indianapolis, IN 46256 (317) 550-3400 www.holisticfinancialpartners.com This brochure provides information about the qualification and business practices of Holistic Financial Partners, LLC (hereinafter “HFP” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. 1 | P a g e  Disclosure Brochure Item 2. Material Changes In this Item, HFP is required to discuss any material changes that have been made to this brochure since the last annual amendment. Since the last annual amendment on March 20, 2024, HFP has had no material changes. 2 | P a g e  Disclosure Brochure Item 3. Table of Contents Item 2. Material Changes .............................................................................................................................. 2 Item 3. Table of Contents .............................................................................................................................. 3 Item 4. Advisory Business ............................................................................................................................ 4 Item 5. Fees and Compensation .................................................................................................................... 6 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................ 8 Item 7. Types of Clients ................................................................................................................................ 8 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 8 Item 9. Disciplinary Information ................................................................................................................ 13 Item 10. Other Financial Industry Activities and Affiliations .................................................................... 13 Item 11. Code of Ethics .............................................................................................................................. 14 Item 12. Brokerage Practices ...................................................................................................................... 14 Item 13. Review of Accounts ...................................................................................................................... 17 Item 14. Client Referrals and Other Compensation .................................................................................... 17 Item 15. Custody ......................................................................................................................................... 17 Item 16. Investment Discretion ................................................................................................................... 17 Item 17. Voting Client Securities ................................................................................................................ 18 Item 18. Financial Information ................................................................................................................... 18 3 | P a g e  Disclosure Brochure Item 4. Advisory Business HFP offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to HFP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with HFP setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement"). HFP has been owned by Jason Llewellyn since June 3, 2015. As of December 31, 2024, HFP had $377,971,272 in assets under management, all being managed on a discretionary basis. While this brochure generally describes the business of HFP, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on HFP's behalf and is subject to the Firm's supervision or control. While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, HFP is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. HFP may recommend clients engage the Firm for additional related services, its Supervised Persons in their individual capacities other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage HFP or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by HFP under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising HFP's recommendations and/or services. Wealth Management Services HFP provides clients with wealth management services which generally includes a broad range of comprehensive financial planning and consulting services as well as discretionary and/or non-discretionary management of investment portfolios. HFP primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"), individual debt and equity securities, and independent investment managers ("Independent Managers") in accordance with their stated investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage HFP to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, HFP directs or recommends the allocation of client assets among the various investment options available with the applicable product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider. Upon review of an investor's financial status, the company may propose that the investor include, as part of his or her financial portfolio, one or more types of products that are not part of the investment advisory services provided by the company, such as insurance products. If the investor chooses to include such a product in his or her financial portfolio, the company recommends that the investor work closely with his or her attorney, accountant, insurance 4 | P a g e  Disclosure Brochure agent and other related professionals. Incorporation of the non-advisory financial product into the investor's financial plan is entirely at the client's discretion. HFP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. HFP consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify HFP if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if HFP determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts. When Adviser provides investment advice to you regarding your retirement plan account or individual retirement account, Adviser 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 Adviser makes money creates some conflicts with your interests, so Adviser operates under a special rule that requires Adviser to act in your best interest and not put our interest ahead of yours. Retirement Plan Consulting Services HFP provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the following services:  Plan Design and Strategy  Plan Review and Evaluation  Plan Fee and Cost Analysis  Plan Committee Consultation • Executive Planning & Benefits • Investment Selection • Fiduciary and Compliance Assistance • Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by HFP as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended ("ERISA"). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of HFP's fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Sponsor and Manager of Wrap Program HFP provides substantially all investment management services as the sponsor and manager of the Holistic Financial Partners Program (the "Wrap Program"), a wrap fee program (i.e., an arrangement where brokerage commissions and transaction costs are absorbed by the Firm). Accounts managed through the Wrap Program are done so in substantially the same manner as those managed under a non -wrap arrangement. Participants in the Wrap Program may pay a higher aggregate fee than if investment management and brokerage ser vices are purchased separately. Additional information about the Wrap Program is available in HFP's Wrap Brochure, which appears as Part 2A Appendix 1 of the Firm's Form ADV. Use of Independent Managers As mentioned above, HFP may select certain Independent Managers to actively manage a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to t his brochure, 5 | P a g e  Disclosure Brochure clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. HFP evaluates a variety of information about Independent Managers, which may include the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance and risk results in relation to its clients' individual portfolio allocations and risk exposure. HFP also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. HFP continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. HFP seeks to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Item 5. Fees and Compensation HFP offers services on a fee basis, which may include fixed fees, as well as fees based upon assets under management or advisement. Financial Planning and Consulting Fees HFP may charge a fixed fee for providing financial planning and consulting services under a stand-alone engagement. These fees are negotiable, but generally range from $1,000 to $5,000, depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. If the client engages the Firm for additional investment advisory services, HFP may offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement and HFP generally requires one-half of the fee (estimated hourly or fixed) payable upon execution of the Advisory Agreement. The outstanding balance is generally due upon delivery of the financial plan or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services rendered. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have HFP implement those recommendations or utilize the services of any inve stment adviser or broker-dealer of their choice. HFP cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Wealth Management Fees HFP offers investment management services for an annual fee based on the amount of assets under the Firm's management. This management fee generally varies between 75 and 115 basis points (0.75% —1.15%) in accordance with the following blended fee schedule: 6 | P a g e  Disclosure Brochure PORTFOLIO VALUE BASE FEE First $500,000 Next $500,000 Next $2,000,000 Next $2,000,000 Above $5,000,000 1.15% 1.05% 0.95% 0.85% 0.75% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by HFP on the last day of the previous billing period. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as applicable. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held- away assets, accommodation accounts, alternative investments, etc.), HFP may negotiate a fee rate that differs from the range set forth above. For purposes of fee calculation, the asset value of client accounts include cash and cash equivalents. Fee Discretion HFP may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. Additional Fees and Expenses In addition to the advisory fees paid to HFP, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively "Financial Institutions"). These additional charges may include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual fund or ETF in a client's account, as disclosed in the fund's prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm's brokerage practices are described at length in Item 12 below. For insurance products, the company provides access to a platform of insurance products by DPL Financial Partners, LLC ("DPL"). The investor is under no obligation to use DPL's service, and may seek insurance advice from any licensed agent. The insurance products and fee structures available from DPL may differ from those available from other third-party insurance agents. The company recommends that the investor fully evaluate products and fee structures to determine which arrangements are most favorable to the investor prior to making an investment decision. The company does not receive compensation for insurance products selected by the investor, whether secured through DPL or any other agent. Direct Fee Debit 7 | P a g e  Disclosure Brochure Clients generally provide HFP and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to HFP. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to HFP's right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client's account. Clients may withdraw account assets on notice to HFP, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client's investment objectives. HFP may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidat ed, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Item 6. Performance-Based Fees and Side-by-Side Management HFP does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client's assets). Item 7. Types of Clients HFP offers services to individuals, pension and profit sharing plans, trusts, estates, corporations and business entities. Minimum Account Requirements HFP does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. Certain Independent Managers may impose more restrictive account requirements and billing practices from HFP. In these instances, HFP may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis HFP utilizes a combination of behavioral finance methods of analysis and an asset allocation strategy based on a derivative of Modern Portfolio Theory ("MPT"). Behavioral finance analysis involves an examination of conventional economics as well as behavioral and cognitive psychological factors. Behavioral finance methodology seeks to combine a qualitative and quantitative approach to provide explanations for why individuals may, at times, make irrational financial decisions. Where conventional financial theories have failed to explain certain patterns, the behavioral finance methodology investigates the underlying reasons and biases that cause some people to behave against their best interests. The risks relating to behavior finance analysis are that it relies on spotting trends in human behavior that may not predict future trends. Modern Portfolio Theory ("MPT") is a mathematical based investment discipline that seeks to quantify expected portfolio returns in relation to corresponding portfolio risk. The basic premise of MPT is that the risk of a 8 | P a g e  Disclosure Brochure particular holding is to be assessed by comparing its price variations against those of the market portfolio. However, MPT disregards certain investment considerations and is based on a series of assumptions that may not necessarily reflect actual market conditions. As such, the factors for which MPT does not account (e.g., tax implications, regulatory constraints and brokerage costs) may negate the upside or add to the actual risk of a particular allocation. Nevertheless, HFP's investment process is structured in such a way as to best attempt to integrate those assumptions and real life considerations for which MPT analytics do not account. Investment Strategies HFP employs a number of investment strategies with varying degrees of risk/return expectations. The Firm's belief is that the key to successful investing is global diversification and maintaining a long -term time horizon. The first step in the construction of the investment strategies is to build strategic allocations for each portfolio. The strategic allocations provide sensible long-term allocations that act as constant frames of reference against which to measure the impact of HFP's tactical decisions. The next step is determining tactical allocation targets based on the Firm's fundamental, technical, and cyclical analysis. The resulting data gathered from the Firm's analysis may persuade it (usually in the form of extreme under or overvaluation) to deviate from the strategic allocations in favor of more attractive classes. These may be asset classes that are included in HFP's strategic allocations, but it is also not uncommon for asset classes to be considered that are outside of the strategic allocation. The final step is using scenario analysis for risk assessment. Each of HFP's strategies has a one-year loss threshold to provide a frame of reference for informed decision making for clients. Different risk scenarios are identified and used to assess the potential impact on each holding as well as the portfolio as a whole. If risk is in excess of the threshold, the portfolio is adjusted. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. Holistic’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small -stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, o r by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage -backed and asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investmen t objective. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by Holistic include, among others: 9 | P a g e  Disclosure Brochure    Stock market risk, which is the chance that stock prices overall will decline. The ma rket value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services.  Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be.  Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated    stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize t hat the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standard s and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates.   Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held.  Management risk, which is the risk that the investment techniques and risk analyses applied by Holistic may not produce the desired results and that legislative, regulatory, or tax developments, affect the investment techniques available to Holistic. There is no guarantee that a client’s investment objectives will be achieved. 10 | P a g e  Disclosure Brochure  Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts  (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds.  Commodity risk, generally commodity prices fluctuate for many reasons, including changes in market and economic conditions or political circumstances (especially of key energy -producing and consuming countries), the impact of weather on demand, levels of domestic production and imported commodities, energy conservation, domestic and foreign governmental regulation (agricultural, trade, fiscal, monetary and exchange control), international politics, policies of OPEC, taxation and the availability of local, intrastate and interstate transporta tion systems and the emotions of the marketplace. The risk of loss in trading commodities can be substantial.  Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of Holistic and its service providers. The computer systems, networks and devices used by Holistic and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to tr ansact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. Alternative Investments / Private Funds risk, investing in alternative investments is spec ulative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include:   Loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; Lack of liquidity in that there may be no secondary market for the investment and none expected to develop;  Volatility of returns;  Restrictions on transferring interests in the investment;  Potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized;  Absence of information regarding valuations and pricing;  Delays in tax reporting;  Less regulation and higher fees than mutual funds; 11 | P a g e  Disclosure Brochure  Risks associated with the operations, personnel, and processes of the manager of the funds investing in alternative investments.  Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They may be diversified or non-diversified. Risks associated with closed-end fund investments include liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of leverage. Additionally, closed-end funds may trade below their net asset value. Structured Notes risk:  Complexity. Structured notes are complex financial instruments. Clients should understand the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates such reference asset(s) or index(es) in calculating the note’s performance. This payoff calculation may include leverage multiplied on the performance of the reference asset or index, protection from losses should the reference asset or index produce negative returns, and fees. Structured notes may have complicated payoff structures that can make it difficult for clients to accurately assess their value, risk and potential for growth through the term of the structured note. Determining the performance of each note can be complex and this calculation can vary significantly from note to note depending on the structure. Notes can be structured in a wide variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may result in larger returns or losses. Clients should carefully read the prospectus for a structured note to fully understand how the payoff on a note will be calculated and discuss these issues with Holistic.  Market risk. Some structured notes provide for the repayment of principal at maturity, which is   often referred to as “principal protection.” This principal protection is subject to the credit risk of the issuing financial institution. Many structured notes do not offer this feature. For structured notes that do not offer principal protection, the performance of the linked asset or index may cause clients to lose some, or all, of their principal. Depending on the nature of the linked asset or index, the market risk of the structured note may include changes in equity or commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility. Issuance price and note value. The price of a structured note at issuance will likely be higher than the fair value of the structured note on the date of issuance. Issuers now generally disclose an estimated value of the structured note on the cover page of the offering prospectus, allowing investors to gauge the difference between the issuer’s estimated value of the note and the issuance price. The estimated value of the notes is likely lower than the issuance price of the note to investors because issuers include the costs for selling, structuring and/or hedging the exposure on the note in the initial price of their notes. After issuance, structured notes may not be re-sold on a daily basis and thus may be difficult to value given their complexity. Liquidity. The ability to trade or sell structured notes in a secondary market is often very limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed for trading on securities exchanges. As a result, the only potential buyer for a structured note may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the structured note. In addition, issuers often specifically disclaim their intention to repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to hold a structured note to its maturity date, or risk selling the note at a discount to its value at the time of sale.  Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the issuer is obligated to make payments on the notes as promised. These promises, including any principal protection, are only as good as the financial health of the structured note issuer. I f the structured note issuer defaults on these obligations, investors may lose some, or all, of the principal amount they invested in the structured notes as well as any other payments that may be due on the structured notes. 12 | P a g e  Disclosure Brochure There also are risks surrounding various insurance products that are recommended to Holistic clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. Holistic does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund's stated daily per share net asset value ("NAV"), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund's holdings. The trading prices of a mutual fund's shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund's shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers: As stated above, HFP may select certain Independent Managers to manage a portion of its clients' assets. In these situations, HFP continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers' ability to successfully implement their investment strategies. In addition, HFP generally may not have the ability to supervise the Independent Managers on a day-to-day basis. General Risk of Loss. Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Item 9. Disciplinary Information HFP has not been involved in any legal or disciplinary events that are material to a client's evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. 13 | P a g e  Disclosure Brochure Other Business Ventures The Firm's Supervised Persons may be involved in other business ventures and clients of the Firm may also be involved in such businesses. Where the Firm's Supervised Persons and clients are involved in a business, neither the Firm nor the Supervised Persons will recommend or advise on that investment and clients considering investing will receive specific disclosure of any conflict of interest. Item 11. Code of Ethics HFP has adopted a code of ethics in compliance with applicable securities laws (the "Code of Ethics") that sets forth the standards of conduct expected of its Supervised Persons. HFP's Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of HFP's personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm's Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm's policies and procedures. Thi s Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless:    the transaction has been completed; the transaction for the Supervised Person is completed as part of a batch trade with clients; or a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers' acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact HFP to request a copy of its Code of Ethics. Item 12. Brokerage Practices Recommendation of Broker/Dealers for Client Transactions HFP generally recommends that clients utilize the custody, brokerage and clearing services of Schwab Advisor ServicesTM ("Schwab") for investment management accounts. Factors which HFP considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab may enable the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. 14 | P a g e  Disclosure Brochure The commissions paid by HFP's clients to Schwab must comply with the Firm's duty to obtain "best execution." Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where HFP determines that the commissions are 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 Financial Institution's services, including among others, the value of research provided, execution capability, commission rates and responsiveness. HFP seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Transactions may be cleared through other broker-dealers with whom the Firm and its custodians have entered into agreements for prime brokerage clearing services. Should an account make use of prime brokerage, the Client may be required to sign an additional agreement, and additional fees are likely to be charged. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers in return for investment research products and/or services which assist HFP in its investment decision-making process. Such research generally will be used to service all of the Firm's clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client's portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because HFP does not have to produce or pay for the products or services. HFP periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Software and Support Provided by Financial Institutions HFP may receive without cost from Schwab computer software and related systems support, which allow HFP to better monitor client accounts maintained at Schwab. HFP may receive the software and related support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The software and support is not provided in connection with securities transactions of clients (i.e., not "soft dollars"). The software and related systems support may benefit HFP, but not its clients directly. In fulfilling its duties to its clients, HFP endeavors at all times to put the interests of its clients first. Clients should be aware, however, that HFP's receipt of economic benefits from a broker/dealer creates a conflict of interest since these benefits may influence the Firm's choice of broker/dealer over another that does not furnish similar software, systems support or services. Specifically, HFP may receive the following benefits from Schwab: • Credits to be used toward qualifying third-party service providers used in connection with the initial set up of the Firm's research, technology and software platforms; • Receipt of duplicate client confirmations and bundled duplicate statements; • Access to a trading desk that exclusively services its institutional traders; • Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and • Access to an electronic communication network for client order entry and account information. 15 | P a g e  Disclosure Brochure Brokerage for Client Referrals HFP does not consider, in selecting or recommending broker/dealers, whether the Firm receives client referrals from the Financial Institutions or another third party. Directed Brokerage The client may direct HFP in writing to use a particular Financial Institution to execute some or all transac tions for the client. In that case, the client will have the right to negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to "batch" client transactions for execution through other Financial Institutions with orders for other accounts managed by HFP (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may r eceive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, HFP may decline a client's request to direct brokerage if, in the Firm's sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client generally will be effected independently, unless HFP decides to purchase or sell the same securities for several clients at approximately the same time. HFP may (but is not obligated to) combine or "batch" such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm's clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Un der this procedure, transactions will generally be averaged as to price and allocated among HFP's clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which HFP's Supervised Persons may invest, the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. HFP does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account's assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation and the transaction may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. 16 | P a g e  Disclosure Brochure Item 13. Review of Accounts Account Reviews HFP monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by the Firm's investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with HFP and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and on an ongoing basis to discuss the impact resulting from any changes in the client's financial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from HFP and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from HFP or an outside service provider. Item 14. Client Referrals and Other Compensation The Firm does not currently provide/or receive compensation to/from any third-party solicitors for client referrals. Item 15. Custody The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize HFP and/or the Independent Managers to debit client accounts for payment of the Firm's fee s and to directly remit that those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to HFP. In addition, HFP may also send periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from HFP. Item 16. Investment Discretion HFP may be given the authority to exercise discretion on behalf of clients. HFP is considered to exercise investment discretion over a client's account if it can effect and/or direct transactions in client accounts without first seeking their consent. HFP is given this authority through a power-of-attorney included in the agreement between HFP and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). HFP takes discretion over the following activities:     The securities to be purchased or sold; The amount of securities to be purchased or sold; When transactions are made; and The Independent Managers to be hired or fired. 17 | P a g e  Disclosure Brochure Item 17. Voting Client Securities HFP generally does not accept the authority to vote a client's securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 18. Financial Information HFP is not required to disclose any financial information due to the following:    The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. 18 | P a g e 

Wrap Fee Program Brochure HOLISTIC FINANCIAL PARTNERS PROGRAM Sponsored by HOLISTIC FINANCIAL PARTNERS, LLC A Registered Investment Adviser March 19, 2025 9959 Crosspoint Blvd Indianapolis, IN 46256 (317) 550-3400 www.holisticfinancialpartners.com This brochure provides information about the qualification and business practices of Holistic Financial Partners, LLC (hereinafter “HFP” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. 1  Wrap Fee Program Brochure Item 2. Material Changes In this Item, HFP is required to discuss any material changes that have been made to this brochure since the last annual amendment. Since the last annual amendment on March 20, 2024, HFP has had no material changes. Page | 2  Wrap Fee Program Brochure Item 3. Table of Contents Item 2. Material Changes ............................................................................................................... 2 Item 3. Table of Contents ............................................................................................................... 3 Item 4. Advisory Business ............................................................................................................... 4 Item 5. Account Requirements and Types of Clients ..................................................................... 7 Item 6. Portfolio Manager Selection and evaluation ..................................................................... 7 Item 7. Client Information Provided to Portfolio Managers……………………………...........................13 Item 8. Client Contact with Portfolio Managers……………………………………………………………………….13 Item 9. Additional Information………………………………………………………………………………………………..14 Page | 3  Wrap Fee Program Brochure Item 4. Advisory Business include financial planning, consulting, and The Holistic Financial Partners Program (the “Program”) is an investment advisory program sponsored by HFP. In addition to the Program, the Firm may offer a variety of advisory services, which investment management services under different arrangements than those described herein. Prior to HFP rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with HFP setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). HFP has been owned by Jason Llewellyn since June 3, 2015. As of December 31, 2024, HFP had $377,971,272 of assets under management, all being managed on a discretionary basis. While this brochure generally describes the business of HFP, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other personal occupying a similar status or performing similar functions), employees or any other person who provides investment advice on HFP’s behalf and is subject to the Firm’s supervision or control. Description of the Program The Program is offered as a wrap fee program, which provides clients with the ability to trade in certain investment products without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered any arrangement under which clients receive investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open a new securities brokerage account and complete a new account agreement with Schwab Advisor Services™ (“Schwab”), or another broker-dealer that HFP approves under the Program (collectively “Financial Institutions”). At the onset of the Program, clients complete an investor profile describing their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, HFP assists its clients in developing an appropriate strategy for managing their assets. Clients’ investment portfolios are generally managed on a discretionary or non-discretionary basis by HFP’s investment adviser representatives and/or one or more independent investment managers (collectively, the “Independent Managers”), as recommended or selected by HFP. HFP and/or the Independent Managers generally allocate client assets among the various investment products available under the Program, as described further in Item 6 (below). Page | 4  Wrap Fee Program Brochure Fees for Participation in the Program The Program is offered on a fee basis, meaning participants pay a single annualized fee based upon assets under management (the “Program Fee”). The Program Fee generally varies between 75 and 115 basis points (0.75% - 1.15%) in accordance with the following blended fee schedule. PORTFOLIO VALUE BASE FEE First $500,000 Next $500,000 Next $2,000,000 Next $2,000,000 Above $5,000,000 1.15% 1.05% 0.95% 0.85% 0.75% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by HFP on the last day of the previous billing period. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. For purposes of fee calculation, the asset value of client accounts include cash and cash equivalents. Fee Comparison As referenced above, a portion of the fees paid to HFP are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios. The fees do not, however, include all fees (including those charged by the Independent Managers). Additional fees are discussed below. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in clients’ accounts, as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. Because HFP absorbs certain transaction costs in client accounts, HFP may have a financial incentive not to place transaction orders in those accounts since doing so increases HFP’s transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Page | 5  Wrap Fee Program Brochure Fee Discretion HFP, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre- existing/legacy client relationship, account retention and pro bono activities. Other Charges In addition to the advisory fees paid to HFP, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions. These additional charges may include fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund Program Fees and other fund expenses), fees and commission for assets not held with Schwab (such as 401(k) or 529 plan assets), transfer taxes, wire transfer and electronic fund fees. Direct Fee Debit Clients generally provide HFP and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to HFP. Account Additions and Withdrawals Clients may make additions to and withdrawals from their account at any time, subject to HFP’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets on notice to HFP, subject to the usual and customary securities settlement procedures. However, HFP designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. HFP may consult with its clients about the option and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charge) and/or tax ramifications. Page | 6  Wrap Fee Program Brochure Compensation for Recommending the Program HFP has no internal arrangements in place whereby persons recommending the Program are entitled to receive additional compensation as a result of clients’ participation. A person recommending the Program will not earn more compensation that he or she would otherwise receive if a client elected another investment management program. Item 5. Account Requirements and Types of Clients HFP offers services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and business entities. Minimum Account Requirements HFP does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. Certain Independent Managers may, however, impose more restrictive account requirements and billing practices from the Firm. In these instances, HFP may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 6. Portfolio Manager Selection and Evaluation Clients’ investment portfolios are typically managed by HFP, but the Firm may also utilize certain Independent Managers, as referenced above. Financial Planning and Consulting Services HFP offers clients a broad range of financial planning and consulting services, which may include any or all of the following functions:  Divorce Planning  Business Planning  Cash Flow Forecasting  Trust and Estate Planning  Budgeting  Insurance Planning  Retirement Planning  Education Planning  Tax Planning  Manager Due Diligence Page | 7  Wrap Fee Program Brochure While each of these services is available on a stand-alone basis outside of the Program, many of them are also rendered in conjunction with investment portfolio management in the Program as part of a comprehensive wealth management engagement. The specific services are discussed in the applicable Advisory Agreement. In performing these services, HFP is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on such information. HFP may recommend that clients engage the Firm for additional related services, its Supervised Persons in their individual capacities, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage HFP or its affiliates to provide additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by HFP under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising HFP’s recommendations and/or services. Portfolio Management Services HFP primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and Independent Managers in accordance with their stated investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may engage HFP to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, HFP directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. HFP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. HFP consults with clients on an initial and ongoing basis Page | 8  Wrap Fee Program Brochure to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify HFP if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if HFP determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Side-By-Side Management HFP does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Methods of Analysis HFP utilizes a combination of behavioral finance methods of analysis and an asset allocation strategy based on a derivative of Modern Portfolio Theory (“MPT”). Behavioral finance analysis involves an examination of conventional economics as well as behavioral and cognitive psychological facts. Behavioral finance methodology seeks to combine a qualitative and quantitative approach to provide explanations for why individuals may, at times, make irrational financial decisions. Where conventional financial theories have failed to explain certain patterns, the behavioral finance methodology investigates the underlying reasons and biases that cause some people to behave against their best interests. The risks relating to behavioral finance analysis are that it relies on spotting trends in human behavior that may not predict future trends. Modern Portfolio Theory (“MPT”) is a mathematical based investment discipline that seeks to quantify expected portfolio returns in relation to corresponding portfolio risk. The basic premise of MPT is that the risk of a particular holding is to be assessed by comparing its price variations against those of the market portfolio. However, MPT disregards certain investment considerations and is based on a series of assumptions that may not necessarily reflect actual market conditions. As such, the factors for which MPT does not account (e.g., tax implications, regulatory constraints and brokerage costs) may negate the upside or add to the actual risk of a particular allocation. Nevertheless, HFP’s investment process is structured in such a way to best attempt to integrate those assumptions and real life considerations for which MPT analytics do not account. Page | 9  Wrap Fee Program Brochure Investment Strategies HFP employs a number of investment strategies with varying degrees of risk/return expectations. The Firm’s belief is that the key to successful investing is global diversification and maintaining a long-term time horizon. The first step in the construction of the investment strategies is to build strategic allocations for each portfolio. The strategic allocations provide sensible long-term allocations that act as constant frames of reference against which to measure the impact HFP’s tactical decisions. The next step is determining tactical allocation targets based on the Firm’s fundamental, technical, and cyclical analysis. The resulting data gathered from the Firm’s analysis may persuade it (usually in the form of extreme under or overvaluation) to deviate from the strategic allocations in favor of more attractive classes. These may be asset classes that are included in HFP’s strategic allocations, but it is also not uncommon for asset classes to be considered that are outside of the strategic allocation. The final step is using scenario analysis for risk assessment. Each of HFP’s strategies has a one-year loss threshold to provide a frame of reference for informed decision making for clients. Different risk scenarios are identified and used to assess the potential impact on each holding as well as the portfolio as a whole. If risk is in excess of the threshold, the portfolio is adjusted. Risk of Loss Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of HFP’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that HFP will be able to predict those price movements accurately or capitalize on any such assumptions. Page | 10  Wrap Fee Program Brochure Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, HFP may select certain Independent Managers to manage a portion of its clients’ assets. In these situations, HFP continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, HFP generally may not have the ability to supervise the Independent Managers on a day-to- day basis. Page | 11  Wrap Fee Program Brochure Cybersecurity Risk There are a number of operational and systems risks involved in investing, including but not limited to “cybersecurity” risk. As the use of technology has increased, your account(s) have become potentially more susceptible to operational risks through breaches in cybersecurity. A breach in cybersecurity refers to both intentional and unintentional events that may cause Holistic to lose proprietary information, suffer data corruption, or lose operational capacity. This in turn could cause Holistic and/or your account(s) to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. If a cybersecurity breach were to occur it could result in a third party obtaining unauthorized access to your information, including Social Security numbers, home addresses, account numbers, involve account balances, and account holdings. Cybersecurity breaches may unauthorized access to digital information systems (e.g., through “hacking” or malicious software coding), and may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, cybersecurity breaches of third-party service providers (e.g., an account’s custodian) or issuers of securities in which an account invests can subject your account(s) to many of the same risks associated with direct cybersecurity breaches. Although Holistic has put in place systems designed to reduce the risks associated with cybersecurity threats, there is no guarantee that such efforts will succeed. Voting of Client Securities HFP generally does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the financial institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 7. Client Information Provided to Portfolio Managers In this Item, HFP is required to describe the type and frequency of the information it communicates to the Independent Managers, if any, managing its clients’ investment portfolios. Clients participating in the Program generally grant HFP the authority to discuss certain non-public information with the Independent Mangers engaged to manage their accounts. Depending upon the specific arrangement, the Firm may be authorized to disclose various personal information including, without limitation: names, phone numbers, addresses, social security numbers, tax identification numbers and Page | 12  Wrap Fee Program Brochure account numbers. HFP may also share certain information related to its clients’ financial positions and investment objectives in an effort to ensure that the Independent Managers’ investment decisions remain aligned with its clients’ best interests. This information is communicated on an initial and ongoing basis, or as otherwise necessary for the management of its clients’ portfolios. Item 8. Client Contact with Portfolio Managers In this Item, HFP is required to describe any restrictions on clients’ ability to contact and consult with the portfolio managers managing their investment portfolios. There are no restrictions on clients’ ability to correspond with HFP. Clients can generally contact the Independent Managers managing their portfolios through HFP by providing the Firm with written request and identification of the questions or issues to be discussed with the Independent Managers. After receiving the client’s written request, HFP, at its sole discretion, may contact the Independent Managers for the client or arrange for the Independent Managers and the client to communicate directly. Item 9. Additional Information Disciplinary Information HFP has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Other Financial Industry Activities and Affiliations This Item requires investment advisers to disclose certain financial industry activities and affiliations. Other Business Ventures The Firm’s Supervised persons may be involved in other business ventures and clients of the Firm may also be involved in such businesses. Where the Firm’s Supervised Persons and clients are involved in a business, neither the Firm nor the Supervised Persons will recommend or advise on that investment and clients considering investing will receive specific disclosure of the conflict of interest. Page | 13  Wrap Fee Program Brochure Code of Ethics HFP had adopted a code of ethics in compliance with applicable securities laws (the “Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. HFP’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of HFP’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Personal are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless:   the transaction has been completed; the transaction for the Supervised Person is completed as part of a batch trade with clients; or  a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issues by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact HFP to request a copy of its Code of Ethics. Page | 14  Wrap Fee Program Brochure Account Reviews Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from HFP and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from HFP or an outside service provider. Client Referrals The Firm does not currently provide compensation to any third-party solicitors for client referrals. Receipt of Economic Benefit and Brokerage Practices HFP generally recommends that clients utilize the custody, brokerage and clearing services of Schwab for investment management accounts. Factors which HFP considers in recommending Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. The execution clients receive from Schwab will comply with the Firm’s duty to obtain “best execution.” 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 Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers in return for investment research products and/or services which assist HFP in its investment decision-making process. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because HFP does not have to produce or pay for the products of services. Page | 15  Wrap Fee Program Brochure HFP periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. HFP may receive computer software and related systems support from Schwab without cost, which allow HFP to better monitor client accounts maintained at Schwab. HFP may receive the software and related support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The software and support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The software and related systems support may benefit HFP, but not its clients directly. In fulfilling its duties to its clients, HFP endeavors at all times to put the interests of its clients first. Clients should be aware, however, that HFP’s receipt of economic benefits from a broker/dealer creates a conflict of interest since these benefits may influence the Firm’s choice of one broker/dealer over another that does not furnish similar software, systems support or services. Specifically, HFP may receive the following benefits from Schwab:  Credits to be used toward qualifying third-party service providers used in connection with the initial set up of the Firm’s research, technology and software platforms;  Receipt of duplicate client confirmations and bundled duplicate statements;  Access to a trading desk that exclusively services its institutional traders;  Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and  Access to an electronic communication network for client order entry and account information. HFP does not consider, in selecting or recommending broker/dealers, whether the Firm receives client referrals from the Financial Institutions or another third party. Financial Information HFP is not required to disclose any financial information due to the following:  The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered;  The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and Page | 16  Wrap Fee Program Brochure  The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 17