HT PARTNERS LLC

Part 2A of Form ADV: Firm Brochure HT PARTNERS LLC 6 Main Street Suite 312 Centerbrook, CT 06409 Telephone: (860) 662-4197 Facsimile: (860) 767-7102 Email: peter.decker@htptrs.com Web Address: www.htpartnersfamilywealth.com 03/20/2025 This Brochure provides information about the business practices of HT Partners LLC (hereinafter HT Partners, or Firm, or we). If you have any questions about the contents of this Brochure, contact us at (860) 662-4197 or peter.decker@htptrs.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Additional information about HT Partners is available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, a CRD number. The CRD number for HT Partners is 147400. 1  Item 2. Summary of Material Changes Since the last annual filing of this Brochure, we have updated our service offerings and fees. Please refer to Item 4 and Item 5 of this Brochure for detailed information. Additionally, we have the following material changes to report: • Devin Bourque has acquired a minority ownership interest in HT Partners and is now a member of the Firm. • We no longer provide HTIQ advisory services through Institutional Intelligent PortfoliosTM. • The website HTPartnersIQ.com has been decommissioned. • Our minimum stand-alone portfolio management fee has been increased to $20,000.00. • Our minimum AUM has increased to $2,000,000.00. • HT Partners has added a new values based planning service called Strategic Wealth Alignment Planning to replace our stand-alone fixed financial planning service. Our annual Strategic Wealth Alignment Planning fee will range between $25,000 to $50,000. • HT Partners has clarified our Proxy Voting Guidelines. 2  Item 3. Table of Contents Summary of Material Changes .............................................................................................. 2 Item 2. Table of Contents .................................................................................................................. 3 Item 3. Advisory Business .................................................................................................................. 4 Item 4. Fees and Compensation ........................................................................................................ 7 Item 5. Performance-Based Fees and Side-By-Side Management .................................................. 10 Item 6. Types of Clients ................................................................................................................... 10 Item 7. Methods of Analysis, Investment Strategies, and Risk of Loss ............................................ 10 Item 8. Disciplinary Information ..................................................................................................... 12 Item 9. Item 10. Other Financial Industry Activities and Affiliations ........................................................... 12 Item 11. Code of Ethics, Participation in Client Transactions, & Personal Trading ....................... 14 Item 12. Brokerage Practices ............................................................................................................ 17 Item 13. Review of Accounts ............................................................................................................. 19 Item 14. Client Referrals and Other Compensation .......................................................................... 21 Custody ................................................................................................................................ 21 Item 15 Item 16. Investment Discretion .......................................................................................................... 22 Item 17. Voting Client Securities ....................................................................................................... 23 Item 18. Financial Information ......................................................................................................... 24 3  Item 4. Advisory Business HT Partners is a fee-based investment adviser with its principal place of business in Centerbrook, Connecticut. The Firm has been in business since 2008, with Peter J. Decker and Christopher J. Koehm as direct owners and Managing Members and Devin Bourque as a Member of the Firm. Discretionary assets under the Firm's management were approximately $500,164,587, and non-discretionary assets under the Firm's management were approximately $3,241,997 as of December 31, 2024. Wealth Management, Financial Planning Services HT Partners LLC ("HT Partners") provides wealth management solutions to high-net-worth and ultra- high-net-worth clients. Our approach integrates investment and retirement planning, risk management, strategic tax and estate planning, family governance, trust and fiduciary services, business succession strategies, and family office advisory services. As part of our comprehensive process, we conduct an in-depth financial assessment, reviewing balance sheets, cash flow, income statements, risk management programs, and financial structures, including banking relationships. We also assist in assembling and coordinating a strategic advisory team, which may include legal, accounting, risk management, business advisory, and records management professionals. While we collaborate with these professionals at the Client's request, we do not provide legal or tax advice. HT Partners evaluates investment management arrangements and develops a tailored Letter of Understanding and asset allocation strategy designed to align with clients' long-term financial objectives. Our process prioritizes wealth transfer planning, offering estate planning solutions and business succession strategies to support multi-generational wealth preservation. HT Partners provides tax-efficient investment and financial planning strategies as part of its advisory services. While our team includes professionals with tax expertise, including a Certified Public Accountant (CPA) and an Enrolled Agent (EA), HT Partners does not provide tax advice, legal structuring, or tax filing services as part of its investment advisory engagement. However, clients may choose to engage our Enrolled Agent (EA) for tax preparation support services under a separate agreement and for a separate fee. These services are not provided as part of HT Partners' investment advisory services and do not create an advisory relationship beyond the terms of the separate tax service engagement. Clients are encouraged to consult with independent tax and legal professionals regarding their specific tax and legal needs. As part of our holistic approach, we may coordinate with external tax professionals at the Client's request. Still, all final tax decisions remain the responsibility of the Client and their chosen advisors. Client Responsibilities: Clients are responsible for providing complete and accurate financial disclosures. Failure to do so may limit HT Partners' ability to provide suitable recommendations and could materially impact financial outcomes. HT Partners is not responsible for any financial or investment decisions based on incomplete or inaccurate client-provided information. HT Partners collects information through in-person meetings, teleconferences, or video interviews, focusing on client values, financial status, goals, and risk preferences. Our financial planning 4  recommendations are independent of any broker-dealer or insurance company products ensuring tailored advice based on each Client's unique circumstances. Clients with assets under our management receive periodic financial plan reviews customized to their evolving needs. Non-Advisory Services HT Partners provides a suite of supplemental, non-advisory services tailored to meet the unique needs of our clients. These services, which are separate from our investment advisory offerings, are available upon request and subject to separate agreements and fees, which will be disclosed in advance. Members of the Firm may serve as Trustees and or Executors. Important Distinction: While distinct from our wealth management solutions, financial planning, and investment advisory services, these non-advisory services are designed to support clients in achieving their financial objectives. However, they do not fall under HT Partners' fiduciary advisory services and may not be subject to the same regulatory protections. Clients should carefully evaluate whether such services align with their financial needs and seek independent legal or tax advice as necessary. Strategic Wealth Alignment Planning HT Partners offers Strategic Wealth Alignment Planning as a stand-alone service or as a complement to its traditional wealth management services, recognizing that not all clients seek this approach. This service is designed for business owners and clients, particularly those with illiquid assets who wish to align their financial decisions with their core values. This structured discovery process clarifies priorities, sets meaningful goals, and develops customized strategies to achieve financial success. HT Partners charges for these services by charging either a fixed fee, or assets under management (AUM) percentage, or a combination of both, depending on the complexity of client needs. Clients choosing this planning service and appointing HT Partners team members as Private Trustees may be required to utilize HT Partners' discretionary investment management services to ensure alignment with the Private Trustee's investment obligations and fiduciary responsibilities. All fees, requirements, and fiduciary obligations will be clearly disclosed and agreed upon in advance. Portfolio Management Services HT Partners provides ongoing investment advice tailored to each Client's unique needs. Through in- depth discussions, we establish goals and objectives based on individual circumstances and develop a customized Letter of Understanding or Investment Policy Statement (IPS). We then create and manage a portfolio aligned with this strategy. During the data-gathering process, we assess client objectives, time horizons, risk tolerance, and liquidity needs. Additionally, we may review and discuss prior investment history, family composition, and background to ensure a comprehensive approach. HT Partners manages advisory accounts on either a discretionary or non-discretionary basis, as agreed upon with each Client. Account management is guided by the Client's stated objectives and overall financial situation. Clients may impose reasonable restrictions on investing in specific securities, asset classes, or industry sectors. If a client elects to retain legacy positions in advisory accounts or imposes investment restrictions, if fees are not charged on these positions, then the Firm retains the right to 5  request an indemnification agreement, particularly in cases of concentrated positions, to mitigate potential risks to the Firm for agreeing to hold the position. HT Partners' investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. Our advice primarily includes exchange-traded funds (ETFs) and no-load or load-waived mutual funds. Client portfolios may also include exchange-listed and over- the-counter securities, options contracts, corporate debt securities, U.S. government securities, certificates of deposit, warrants, commercial paper, and municipal securities. Additionally, we may recommend illiquid direct investments, such as private placement offerings and limited investment partnerships, when suitable for the Client's objectives. These investments carry a higher degree of risk and reduced liquidity. Clients will receive offering documents detailing associated fees and risks before investing. All recommendations are made in alignment with the Client's investment objectives, risk tolerance, liquidity needs, and overall suitability. Risk Disclosure All investments carry inherent risks, including the potential loss of principal. Investment and financial planning strategies are based on available information at the time and may require adjustments due to changes in market conditions, tax laws, or personal circumstances. Past performance is not indicative of future results, and no investment strategy can guarantee success. Third-Party Estate Planning Services HT Partners collaborates with an unaffiliated third-party service provider to offer estate planning services under a separate consulting agreement. Our role in this process is to assist clients in gathering necessary information and interpreting estate plans. HT Partners does not assume responsibility for the accuracy or legal validity of estate planning documents produced by the third-party provider. Clients are strongly encouraged to seek independent legal counsel for complex estate planning needs. Fees and Termination Clients engaging with third-party estate planning platforms will have the option to maintain access under one of two models: • A direct monthly platform access fee is paid to the third-party provider, subject to changes in their terms of service. • An annual flat fee option is paid to HT Partners for continued platform access, as outlined in our consulting agreement. HT Partners may waive platform fees for clients with an ongoing relationship with the Firm. Either party may terminate this agreement at any time. Clients must understand that failure to remit fees will result in loss of platform access. 6  Disclaimers HT Partners does not warrant the completeness or accuracy of documents generated through the third-party platform. The decision to utilize these non-advisory services is solely at the Client's discretion. Clients are not obligated to engage in these services and are encouraged to consider their unique circumstances and seek independent advisors as needed. Item 5. Fees and Compensation Wealth Management, Financial Planning, Portfolio Management Our minimum fee is $20,000.00 based on family relationships. The annual fee for our consolidated wealth management, financial planning, and portfolio services will be based on the amount of assets under management. It will typically range from 0.42% to 1.25%, depending on the level of service chosen and the existence of special assets in need of supervision. Special Asset Management High net worth Clients often want to own special assets directly through their trust accounts or other estate planning vehicles. These assets may include mortgages, notes, promissory notes, limited liability companies, partnerships, corporations, tangible real estate, or other business investments. HT Partners may supervise or support Clients in the management of these assets. In those situations where the Firm supervises special assets, HT Partners may charge an annual fee of up to 1.25% in addition to other portfolio management services that are negotiable depending on the scope of responsibilities. Fair market value for private/special assets such as unmarketable securities, closely held business interests, promissory notes, debt obligations, and tangible real estate will be appraised periodically whenever possible unless an independent pricing authority provides an intervening value. If a scheduled appraisal does not occur for any reason, the prior appraisal value will be used. While HT Partners will attempt to verify the accuracy of these independent pricing authorities, each Client is responsible for notifying HT Partners if they have concerns regarding the accuracy of any appraisals or valuations. The Client is responsible for all costs associated with the appraisal of assets. Unless expressly excluded, when the valuation of these assets is determined, they will be billed at the lesser of their fair market value and the asset's cost basis. The expenses of maintaining the business entity include but are not limited to, entity filing fees, operational expenses, and compliance costs, which will be approved and billed to Clients at cost. Strategic Wealth Alignment Planning Our annual Strategic Wealth Alignment Planning fee will range between $25,000 to $50,000, with the potential for higher negotiated fees based on Client complexity and sophistication. Closely held business owners may choose to have their businesses engage the Firm to provide these services on behalf of the company. 7  Non-Advisory Services Fees for non-advisory services are fully negotiated based on the scope, complexity, and breadth of services required. Clients with significant assets under management or engaging in comprehensive service agreements may be eligible for discounted or complimentary services at HT Partners' discretion. Fees in General Unless otherwise agreed, the Firm will directly debit Client accounts 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, pro-rated for additions and withdrawals. The fair market value for private/specially designated assets such as unmarketable securities, closely held business interests, promissory notes, debt obligations, and tangible real estate will be appraised every two years unless an independent pricing authority provides an intervening value. Clients are responsible for the cost of the appraisal. These assets will be billed at the lesser of their fair market value and the assets cost basis. In delivering our services, HT Partners may incur various expenses on behalf of our Client, which may encompass travel and third-party support expenses. When travel and support services are required, HT Partners will request and receive reimbursement for all travel and support services expenses directly associated with providing services. These travel and business expenses may be billed to the Client's accounts at cost, and the Client will be provided with an itemized receipt detailing the expenses incurred during travel and vendors. Fees, account minimums, and payment of travel expenses for all services are negotiable based upon specific criteria (i.e., anticipated future earning capacity, anticipated future additional assets, the dollar amount of assets to be managed, related accounts, account composition, negotiations with the Client, etc.). Discounts, not generally available to advisory Clients, may be offered to family members and friends. The Firm may group related Client accounts to determine the account size and annualized fee. Certain legacy Client agreements may be governed by fee schedules different from those listed above. Under no circumstances will the Firm require payment of fees above $1,200 more than six months in advance of services rendered. Account Termination Clients may terminate the agreement by providing the Firm with a 30-day written notice delivered to the HT Partners' principal place of business. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. HT Partners reserves the right to terminate any agreement. Mutual Fund and ETF Fees and Expenses All fees paid to HT Partners for investment advisory services are separate and distinct from the internal fees and expenses charged by mutual funds and exchange-traded funds (ETFs) to their shareholders. These fees and expenses, which are detailed in each fund's prospectus, may include management fees, fund operating expenses, and, in some cases, distribution fees. 8  Clients may invest in mutual funds or ETFs directly, without engaging HT Partners, and would therefore not incur the Firm's investment advisory fees. However, they would also not receive the Firm's advisory services, which include personalized financial planning, portfolio allocation guidance, and ongoing investment oversight. Clients should carefully review and consider all fees and expenses, both those charged by HT Partners and those associated with mutual funds and ETFs, to fully understand the total cost of their investment and the value of the advisory services provided. Brokerage and Custodial Fees In addition to advisory fees paid to HT Partners, clients are responsible for any transaction fees, brokerage commissions, custodial fees, administrative costs, and trustee fees charged by third-party service providers in connection with the management of their accounts. These fees are separate from and in addition to HT Partners' advisory fees. The amount and structure of these fees will vary depending on the custodian, brokerage firm, or other service providers selected by the Client. For more details on brokerage and transaction-related fees, please refer to Item 12 of this Brochure, which provides important disclosures regarding our brokerage practices and potential conflicts of interest. Cash and Margin Holdings HT Partners' advisory fees apply to all managed assets, including cash holdings, as part of our Portfolio and Wealth Management Financial Planning Services. Cash Fee Guidelines: • Inclusive Fees: Advisory fees cover all managed assets, including cash, to align with our overall asset allocation approach. • Potential Exclusions: In certain cases, we may exclude specific cash balances from fees, such as cash designated for immediate liquidity needs or linked to operational checking accounts, based on the Client's overall relationship and cash's intended use. • Fee vs. Yield Consideration: Clients should be aware that advisory fees may exceed the yield earned on cash holdings, particularly in low-interest-rate environments. Advisory fees reflect the value of portfolio management and investment guidance rather than just cash performance. Margin Holdings & Conflict Disclosure Unless otherwise agreed, accounts utilizing margin are billed on the higher margin balance (the net market value of securities plus the margin loan balance). This creates a potential conflict of interest, as HT Partners earns higher advisory fees when margin balances are maintained. To mitigate this conflict, we maintain a fiduciary duty to act in the best interests of our clients and do not incentivize margin use for fee purposes. Clients should carefully evaluate the costs and risks of margin borrowing, including interest charges and market volatility, before utilizing margin. 9  Item 6. Performance-Based Fees and Side-By-Side Management HT Partners does not charge fees based on a share of capital gains or capital appreciation of a Client's assets. Item 7. Types of Clients HT Partners generally provides advisory services to individuals, high-net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, business entities, and family office entities. HT Partners typically requires a minimum of $2,000,000 in assets under management (AUM) for its advisory services. However, this minimum may be waived or adjusted at HT Partners' discretion for: • Clients who are part of a larger family relationship (e.g., multigenerational planning or family office structures). • Clients who represent strategic or long-term relationship opportunities at the Firm's discretion. Item 8. Methods of Analysis, Investment Strategies, and Risk of Loss HT Partners employs multiple methods of analysis to develop investment strategies tailored to Clients' financial objectives and risk tolerance. All investment strategies involve risk, including the risk of loss of principal. Asset Allocation HT Partners emphasizes asset allocation, focusing on constructing diversified portfolios across alternatives, equities, fixed income, and cash to align with Clients' goals and risk tolerance. Risks: • Asset allocation does not guarantee profit or protection against loss in declining markets. • Clients may not fully participate in gains from specific securities, industries, or market sectors that perform strongly. • Portfolio allocations may shift over time due to market fluctuations, requiring rebalancing. Technical Analysis HT Partners employs technical analysis to identify price trends and market patterns, using factors such as price movements, trading volume, moving averages, and market sentiment. Risks: • Technical indicators may provide false signals, leading to incorrect investment decisions. • Unexpected market conditions, such as sudden volatility, may render technical patterns ineffective. 10  Cyclical Analysis HT Partners evaluates economic and market cycles to assess how different assets perform in various phases of expansion and contraction. Risks: • Market cycles are difficult to predict, and incorrect timing can negatively impact portfolio performance. • Cyclical investing strategies may underperform if trends persist longer or shorter than expected. Mutual Fund and ETF Analysis HT Partners selects mutual funds and ETFs based on factors such as historical performance, management expertise, and underlying asset composition. The Firm seeks to avoid unnecessary concentration in holdings across different funds. Risks: • The past performance of a fund or ETF is not indicative of future results. • Clients may hold overlapping securities in multiple funds, leading to unintended concentration risk. • Fund managers may deviate from their stated investment strategy, altering the risk return profile of the fund. Short-Term Purchases & Trading HT Partners may occasionally purchase securities for short-term investment (holding for one year or less) or engage in active trading (holding for 30 days or less) to capitalize on market inefficiencies. Risks: • Short-term trades may result in higher transaction costs and brokerage fees, reducing net returns. • Frequent trading may generate short-term capital gains taxes, which are generally taxed at • higher rates. If expected price movements do not materialize, Clients may incur losses or be forced to hold investments longer than intended. Option Strategies & Derivatives HT Partners may use options and other derivatives as part of its investment approach. These strategies may include: • Protective Hedging – Using options to reduce downside risk. • Income Generation – Writing covered calls or selling options to generate additional portfolio income. • Strategic Positioning – Taking derivative positions to express market views. 11  Risks • Leverage Risk – Options and derivatives can amplify losses beyond the initial investment. • Market & Liquidity Risks – Certain options may be illiquid, leading to unfavorable pricing or Execution. • Complexity & Suitability – Options involve sophisticated risk management and may not be suitable for all Clients. Clients should carefully consider the risks of derivatives before engaging in such strategies and should consult with HT Partners to determine suitability based on their financial objectives and risk tolerance. CLIENTS SHOULD UNDERSTAND THAT INVESTING IN ANY SECURITIES, INCLUDING MUTUAL FUNDS, INVOLVES A RISK OF LOSS OF BOTH INCOME AND PRINCIPAL. Item 9. Disciplinary Information In December 2014, F-Squared Investments (F-Squared), an unaffiliated former signal provider to HT Partners, admitted to violating federal securities laws by providing inaccurate performance information for the period between April 2001 and September 2008. Between June 2012 and January 2015, F-Squared provided investment signals to HT Partners through the AlphaSector Strategy. HT Partners included F-Squared's track record in materials provided to certain Clients without knowledge that the performance data was inaccurate. On May 27, 2016, HT Partners reached a settlement with the SEC regarding this matter. Without admitting or denying the SEC's findings, HT Partners agreed to a cease-and-desist order on August 25, 2016, related to violations of Rule 204-2(a)(16) (a recordkeeping rule) and Rule 206(4)-1(a)(5) (an advertising rule). As part of the settlement, HT Partners paid a civil monetary penalty of $100,000. Item 10. Other Financial Industry Activities and Affiliations In addition to the advisory services described in Item 4 of this Brochure, HT Partners provides multifamily office services to select Clients, typically with assets exceeding $25 million. Multifamily Office Services HT Partners' multifamily office services may include: • Management of non-securitized real estate holdings • Oversight of business entities, including closely held businesses • Coordination with third-party service providers, such as: o Bookkeepers and bookkeeping services 12  o Attorneys o Private bankers o Accountants Insurance advisors o o Private security services o Family education advisors o Real estate management firms o Other family office-related professionals HT Partners also assists eligible Clients in creating, structuring, and managing family office entities. Fee Structure: Clients engaging HT Partners for non-advisory multifamily office services pay separate and distinct fees in addition to the advisory fees described in Item 5 of this Brochure. At the Firm's sole discretion, Clients with assets exceeding $50 million may be eligible for partial or full fee waivers on certain non-advisory services. Affiliated Business Interests & Potential Conflicts of Interest Accounting & Tax Services Christopher J. Koehm, CPA, Managing Director of HT Partners, separately owns and operates an accounting firm affiliated with HT Partners through common ownership and control. Clients of HT Partners may be referred to this affiliated entity and vice versa. However, no referral fees are paid between the two entities. Insurance Services HT Partners' principals, Peter J. Decker, Christopher J. Koehm, and Devin C. Bourque, are principals and/or owners of Essex Insurance Group, Inc. (EIG), an independent insurance agency offering life, health, accident, disability, and long-term care insurance products. Additionally, Mr. Bourque is a licensed insurance agent affiliated with various unaffiliated insurance companies. Clients are not obligated to use the services of EIG or any affiliated insurance providers. All insurance related fees are separate from and in addition to HT Partners' advisory fees. Trustee & Fiduciary Roles Peter J. Decker and Christopher J. Koehm serve as Executors, Private Trustees, or Co-Executors for certain Clients and non-clients under separate, non-advisory agreements. Clients are not required to appoint firm members as Trustees or Executors. If appointed, Clients may choose to engage HT Partners for Wealth Management Services, but this is entirely separate from fiduciary appointments and governed by an independent agreement. Fees for Executor, Trustee, or Co-Executor services are negotiated on a case-by-case basis and billed separately. Real Estate Holdings & Business Interests Peter J. Decker serves as Vice President of Macbeth Ventures LLC, a real estate holding company managing the historic former Witch Hazel Works in Centerbrook, Connecticut. 13  • Mr. Decker is responsible for managing the property. • Both Mr. Decker and Mr. Koehm serve as Co-Executors of the Estate that holds this Limited Liability Company. Conflict of Interest Considerations & Mitigation Some of these non-advisory activities present potential conflicts of interest, including: • Additional Compensation Risks – HT Partners' principals and owners may receive compensation from family office, accounting, and insurance services offered to Clients. • Time Commitment Concerns – Mr. Decker and Mr. Koehm's involvement in outside business activities could limit the time they dedicate to managing advisory Client accounts. • Access to Client Funds – Certain business relationships may result in HT Partners, Mr. Decker, and/or Mr. Koehm having direct or indirect access to Client funds (e.g., through Trustee or Business Manager roles). Fiduciary Duty & Client Protections HT Partners maintains a fiduciary duty to act in Clients' best interests. To mitigate potential conflicts: • All advisory Clients are informed that non-advisory services are optional and billed separately. • HT Partners does not require Clients to use affiliated businesses or third-party providers. • Advisory and non-advisory services are governed by separate agreements to ensure transparency. • All roles involving access to Client funds (e.g., Trusteeship or Business Management) are subject to appropriate oversight and controls to prevent conflicts of interest. HT Partners endeavors at all times to put the interests of the Client first. Item 11. Code of Ethics, Participation in Client Transactions, & Personal Trading Code of Ethics Disclosure HT Partners has adopted a Code of Ethics designed to uphold high standards of professional and ethical conduct. This Code ensures that all firm personnel comply with federal securities laws and act in the best interests of Clients. The Code includes: • Personal Trading Policies: Employees must report personal trades and holdings on a quarterly and annual basis. • Restrictions on Trading: Employees may not trade securities based on non-public information obtained through their employment. • Pre-clearance Requirements: Employees must obtain prior approval before purchasing securities in limited offerings (e.g., private placements) or initial public offerings (IPOs). • Supervision & Enforcement: The Firm maintains oversight, recordkeeping, and enforcement provisions to monitor compliance. 14  A copy of the Code of Ethics is available to Clients and prospective Clients upon request by contacting Peter J. Decker, Managing Member & Chief Compliance Officer, at the Firm's principal office address. Personal Trading & Potential Conflicts of Interest HT Partners, its employees, and its principals may buy or sell securities identical to those recommended to Clients. Employees and related persons may also hold an interest in securities recommended to Clients, creating a potential conflict of interest. To mitigate these conflicts, the Firm has established the following restrictions: • Prohibited Use of Insider Information: Employees cannot trade securities based on non-public information acquired through their employment. • No Preferential Trading: Employees may not execute personal trades ahead of Client transactions. • Restricted Securities List: The Firm maintains a list of all employee and firm securities holdings, regularly reviewed by Peter J. Decker, Christopher J. Koehm, Devin C. Bourque, and the Investment Policy Committee. • Trade Allocation Policy: In the event of a partial fill of a batch order, Client accounts receive priority over employee accounts. • Client Right to Decline Advice: Clients retain full discretion to implement or reject any investment recommendations, except where HT Partners has discretionary authority. • Regulatory Compliance: All firm personnel must comply with applicable SEC, ERISA, IRS, and state regulations governing investment advisers. • Disciplinary Actions: Employees who violate these policies may be subject to disciplinary action, including termination. HT Partners may aggregate employee trades with Client trades only when such aggregation is expected to result in equal or more favorable pricing for Clients. When employee trades are aggregated with Client trades, all accounts in the trade will receive the same average price per share. Fiduciary Status Under ERISA & IRS Code When HT Partners provides investment advice regarding your retirement plan account or individual retirement account (IRA), it is acting as a fiduciary under: • Section 3(21) of the Employee Retirement Income Security Act of 1974 (ERISA) • Section 4975 of the Internal Revenue Code of 1986 As a fiduciary, HT Partners must act in the Clients' best interests and not place its interests ahead of the Clients' interests. How HT Partners Manages Potential Conflicts of Interest HT Partners is compensated through advisory fees, and in some cases, employees or affiliated entities may receive compensation for non-advisory services (e.g., insurance or accounting services, as disclosed in Item 10). 15  To mitigate conflicts, the Firm: • Operates under a fiduciary duty to act in Clients' best interests. • Ensures transparency in all compensation arrangements, including separate billing for non- advisory services. • Provides full disclosure of potential conflicts in its Form ADV and Client agreements. Clients should review all fees, expenses, and compensation arrangements to understand how HT Partners is compensated for its services fully. Asset Rollover Disclosure HT Partners is required to disclose conflicts of interest associated with its recommendations to roll over retirement assets. A rollover recommendation creates a conflict of interest if HT Partners earns new or increased advisory fees on the rolled-over assets. Clients should carefully consider this potential conflict when evaluating a rollover decision. HT Partners acts as a fiduciary under SEC and DOL regulations when providing rollover recommendations and is required to act in the Client's best interest. Clients should evaluate whether a rollover is appropriate based on their financial situation, investment needs, and the costs associated with maintaining their current retirement plan versus rolling it into an IRA. For additional details regarding HT Partners' services, fees, and conflicts of interest, please refer to Item 5 of Form ADV Part 2A. Factors to Consider Before Rolling Over Your Retirement Assets Clients and prospective Clients evaluating a rollover from a qualified employer-sponsored workplace retirement plan (Employer Retirement Plan) to an Individual Retirement Account (IRA) or from one IRA to another IRA should consider the advantages and disadvantages of a rollover, including, but not limited to: • Fees & Expenses: Compare management fees, transaction costs, custodial fees, and overall expenses between your existing plan and the IRA. • Investment Options: Employer plans may offer lower cost institutional funds not available in an IRA, while an IRA may provide broader investment choices. • Services & Advice: Employer plans may offer low cost fiduciary advice, managed accounts, or financial planning services, whereas an IRA allows for personalized advisory services (which may come at an additional cost). • Withdrawal Rules & Penalties: Employer plans may allow penalty free withdrawals at age 55, while IRAs generally impose penalties for withdrawals before age 59½. • Creditor & Asset Protection: Employer plans may have stronger creditor protection under ERISA rules, while IRAs follow state specific protections. • Employer Matching Contributions: If rolling over to a new employer plan, consider whether the new plan offers employer matching contributions. 16  Potential Alternatives to a Rollover Clients have several options when deciding what to do with their Employer Retirement Plan assets: • Remain in Your Current Employer's Retirement Plan (if allowed): If the plan offers low- cost investment options and strong benefits, this may be preferable. • Roll Over to a New Employer's Retirement Plan (if available): If the new plan has lower costs and better investment options, this could be a beneficial option. • Roll Over to an IRA: This may provide greater investment flexibility but could come with higher fees. • Cash Out & Withdraw Funds: This may trigger tax consequences and early withdrawal penalties. Before making a decision, Clients should consult with HT Partners and/or their tax professional to evaluate their options based on their specific financial goals. Item 12. Brokerage Practices Soft-Dollar Arrangements & Directed Brokerage HT Partners does not have any formal or informal soft-dollar arrangements and does not receive soft- dollar benefits tied to Client transactions. However, the Firm may receive certain indirect benefits from custodians, as outlined below. HT Partners does not have discretionary authority to determine the broker-dealer or custodian for Client accounts. Clients must direct HT Partners to use a specific broker-dealer or custodian for all securities transactions. Best Execution Review & Limitations Although Clients direct brokerage, HT Partners conducts periodic Best Execution reviews to evaluate whether Client transactions are executed at competitive prices and under favorable conditions. • Scope of Review: The review examines factors such as execution speed, commission rates, trade accuracy, and overall execution quality. • Limitations: Since Clients direct brokerage, HT Partners cannot compare execution quality across multiple broker-dealers or seek alternative trading venues. • Potential Impact on Client Costs: In a directed brokerage arrangement, Clients may experience higher trading costs, wider bid-ask spreads, or execution delays compared to an RIA that selects broker-dealers for Best Execution. Clients should be aware that not all RIAs require Clients to direct brokerage, and selecting a brokerage firm may impact trade execution quality and costs. Custodial Relationship & Associated Benefits HT Partners recommends Charles Schwab & Company, Inc. (Schwab), an unaffiliated FINRA- registered broker-dealer, to Clients who require brokerage and custodial services. As part of Schwab's 17  Schwab Institutional (SI) platform, HT Partners receives certain benefits that it would not receive if it did not maintain Client accounts with Schwab. These benefits include: • Access to Schwab's institutional trading desk for RIA accounts. • Consolidated reporting services for Client accounts. • Access to institutional mutual funds and share classes is not available to retail investors. • Business development and compliance resources, including educational events, technology support, and practice management consulting. Potential Conflicts of Interest & Mitigation HT Partners does not receive direct compensation from Schwab. However, the Firm benefits from its participation in Schwab's RIA platform, creating a potential conflict of interest because these benefits could incentivize the Firm to recommend Schwab over other custodians. To mitigate this conflict, HT Partners conducts Best Execution reviews to ensure that Schwab's execution quality remains competitive. Clients are not required to use Schwab and may select another custodian. HT Partners does not receive transaction-based compensation or referral fees from Schwab. HT Partners fully discloses its relationship with Schwab in this Brochure and Client agreements. Trade Aggregation & Allocation HT Partners may aggregate Client trades when the Firm determines that doing so may result in more efficient Execution and potential cost savings for Clients. Some benefits of trade aggregation are: • Reduced Transaction Costs: Aggregating trades may lower commission costs and transaction fees. • Minimized Market Impact: Larger block orders may reduce price movements caused by multiple smaller trades. • More Uniform Execution Pricing: Clients participating in aggregated trades may receive the same execution price, reducing pricing discrepancies between accounts. Trade Allocation & Fairness Policy If HT Partners aggregates Client orders, trades will be allocated fairly and equitably across participating accounts in proportion to the size of each Client's order. All Clients participating in an aggregated trade will receive the same average execution price. Transaction costs will be shared proportionally among participating Clients unless the custodian's fee structure dictates otherwise. Handling of Partial Fills If an aggregated order is only partially filled. Allocations will be made on a pro-rata basis to ensure fair distribution. In cases where a pro-rata allocation is impractical or disadvantageous, HT Partners may allocate based on other objective criteria, such as account type, strategy, or Client-specific needs. HT Partners does not aggregate trades solely for the benefit of the Firm or its employees. Personal accounts of HT Partners personnel will not receive preferential treatment in the allocation process. 18  Vanguard Strategic Model Portfolios HT Partners receives complimentary access to Strategic Model Portfolios from Vanguard Investments at no cost. While this may create a potential conflict of interest, as it could create an incentive to invest in Vanguard-sponsored funds, HT Partners is not required to use these models and retains full discretion in constructing Client portfolios. HT Partners does not receive compensation, revenue sharing, or any direct financial incentives for investing in Vanguard-sponsored funds. HT Partners may use Vanguard's models in whole or in part as a reference for portfolio construction but is not obligated to follow them. The Firm selects investment options based on its independent research and Clients' best interests, which may or may not include Vanguard funds. HT Partners regularly reviews its investment selection process to ensure that any use of Vanguard funds aligns with Clients' investment objectives, cost efficiency, and overall portfolio strategy. Item 13. Review of Accounts Portfolio Management Services HT Partners provides ongoing portfolio management services for Clients, continuously monitoring account holdings for consistency with Client investment objectives, asset allocation targets, and risk tolerance. Portfolio Review & Monitoring Process HT Partners' portfolio management team, led by: • Peter J. Decker, Managing Member & Chief Compliance Officer • Christopher J. Koehm, CPA, Managing Member • Devin C. Bourque, CFP®, Member & Director of Planning & Portfolio Services • Austin M. Van Winkle, CFP®, Enrolled Agent • Jack W. Wheeler, CFP®, Investment Adviser Representative HT Partners conducts ongoing reviews of Client portfolios. These reviews assess: • Portfolio alignment with Client investment strategy & objectives • Asset allocation & diversification • Risk tolerance & market exposure • Performance relative to appropriate benchmarks Review Triggers Portfolio reviews may be conducted more frequently if triggered by Client-Specific Events – Changes in personal, financial, or tax circumstances, market conditions, economic shifts, macroeconomic events, or significant market movements. 19  Client Reporting & Custodial Statements Clients receive monthly brokerage statements and transaction confirmations directly from their custodian or broker-dealer. Additionally, HT Partners may provide or make available by USPS mail or online a Consolidated Relationship Report. Clients are encouraged to review their official brokerage or trust account statements regularly and compare them to any additional reports provided by HT Partners. Clients should also utilize their custodian, trust company, or bank's online portals to monitor their accounts. Financial Consulting Services HT Partners provides financial consulting services tailored to Client needs. As agreed upon at the inception of the advisory relationship, the Firm will review Client accounts periodically based on the terms outlined in the Client's advisory agreement. The scope and frequency of these reviews are determined at the outset of the engagement and may vary based on the Client's needs and contractual agreement. HT Partners does not typically provide additional reports unless explicitly agreed upon in the initial advisory agreement or through a separate engagement. Clients should refer to their advisory agreement for details regarding the specific services, review frequency, and reporting expectations associated with their financial consulting engagement. Notice & Communication Policy HT Partners may deliver notices, reports, and other required communications electronically to the Client's email address of record or through a secure Client portal at no additional charge. Alternative Delivery Methods & Associated Fees Clients may request physical delivery of communications using the following methods: In-person delivery • • Facsimile (with a hard copy sent by U.S. mail) • Overnight courier (postage prepaid) • Registered mail (first-class postage prepaid) Clients choosing an alternative delivery method will be responsible for any additional fees associated with the requested service. The Firm will only charge the actual cost of the service and will provide an estimated cost before processing the request. Clients may opt out of electronic communications by submitting a written request to HT Partners' Manager, specifying the preferred alternative delivery method. 20  Item 14. Client Referrals and Other Compensation Third-Party Compensation Disclosure Other than as described in this Brochure, HT Partners does not receive direct or indirect compensation from third parties for providing investment advice to Clients. However, HT Partners or its affiliates may receive compensation for non-advisory services, such as trustee, executor, insurance, estate planning consulting, or accounting services (as disclosed in Item 10). HT Partners does not pay third parties for Client referrals and does not participate in third-party solicitor arrangements. Employee Referral Program & Compensation Disclosure HT Partners may compensate employees for referring prospective Clients who become advisory Clients of the Firm. Compensation under this program is based on factors such as the duration of the Client's relationship with HT Partners and the amount of assets invested by the referred Client. As this arrangement creates a potential conflict of interest, since employees may have a financial incentive to refer Clients, HT Partners has implemented the following safeguards: • Regulatory Compliance: All referral compensation is paid in accordance with the Investment Advisers Act of 1940, SEC rules, and applicable state securities laws. • Client Suitability Review: Referred Clients undergo a thorough suitability assessment to ensure that HT Partners' fees, services, and investment strategies align with their financial needs. • No Higher Fees for Referred Clients: Clients referred by employees are not charged higher fees than Clients who engage HT Partners through other means. • Fiduciary Standard Maintained: Referral arrangements do not influence investment recommendations or portfolio management decisions. HT Partners remains committed to acting in Clients' best interests, and all referral arrangements are subject to ongoing compliance oversight to ensure fairness and transparency. Item 15 Custody Under SEC Rule 206(4)-2 (Custody Rule), HT Partners is deemed to have custody of certain Client assets even though the Firm does not physically hold any Client funds or securities. Why HT Partners Are Deemed to Have Custody? HT Partners is deemed to have constructive custody of Client assets under SEC rules due to the following factors: the ability to deduct advisory fees directly from Client accounts, including. Standing Letters of Authorization (SLOAs) that allow the Firm to transfer Client funds to designated third 21  parties. HT Partners' principals serve as Trustees, Executors, or holding similar fiduciary roles for certain Clients. Custodian Relationship & Client Responsibilities All Client funds and securities are maintained by qualified custodians, who provide Clients with direct account statements. Clients are encouraged to review their custodial statements carefully for accuracy. Compare custodial statements to any reports provided by HT Partners (which may differ due to reporting methods, trade settlements, or timing differences). Report any discrepancies directly to the custodian first, and then notify HT Partners (Peter J. Decker, Christopher J. Koehm, or another firm representative). Custody Compliance & Regulatory Safeguards To comply with SEC custody regulations, HT Partners undergoes independent audits when required. For accounts where the Firm has direct access to Client funds beyond advisory fee deductions, the Firm follows SEC-mandated custody safeguards. HT Partners does not act as a qualified custodian and does not commingle Client assets. For discrepancies, the Client should notify Peter J. Decker, Christopher J. Koehm, and/or the custodian as soon as possible. Item 16. Investment Discretion HT Partners provides investment advisory services on a discretionary basis, meaning the Firm has the authority to determine which securities and the amounts to be bought or sold in Client accounts without prior Client approval for each transaction. Granting Discretionary Authority Clients grant discretionary trading authority to HT Partners in writing, typically by executing an Investment Management Agreement with HT Partners or a custodial trading authorization (as required by the custodian). Client-Imposed Restrictions on Discretionary Authority Clients may impose reasonable limitations on HT Partners' discretionary authority, such as restrictions on specific securities or industries. Limits on trading frequency or asset allocation parameters. These restrictions must be documented in writing in the Client's Letter of Understanding or an addendum to their investment management agreement. If a Trust Agreement or other governing document requires HT Partners to adhere to specific investment guidelines, the Firm will follow those instructions as mandated by the trust or legal agreement. 22  Modifications to Investment Restrictions Clients may change or amend their investment restrictions at any time by providing written notice to HT Partners. The Firm will update trading parameters accordingly once the written request is received and acknowledged. Item 17. Voting Client Securities Proxy Voting Authority & HT Partners' Role Unless otherwise agreed in writing, HT Partners retains proxy voting authority for Client securities and utilizes EC Proxy Voting Service, Inc. (EC Proxy), an unaffiliated third-party proxy voting service, to execute votes. HT Partners establishes and provides the voting guidelines that EC Proxy follows when voting proxies on behalf of Clients. EC Proxy does not exercise independent discretion over voting decisions but implements votes based on HT Partners' pre-determined policies. Voting Guidelines & Review Process HT Partners' Investment Policy Committee reviews and updates proxy voting guidelines at least annually, considering regulatory and market developments affecting corporate governance and shareholder rights. Client input on key voting issues, where applicable. Best practices in corporate governance and shareholder engagement. Clients may request a copy of HT Partners' current proxy voting guidelines at any time. However, proxy votes are cast uniformly across accounts following these guidelines. Clients who wish to vote proxies differently from HT Partners' standard voting policies must opt out of this service and assume full proxy voting responsibility. Client Options, Cost Responsibility & Voting Preferences Clients who opt to vote their proxies may be responsible for any associated costs incurred by HT Partners related to processing shareholder materials or proxy voting requests. These costs will be passed through to the Client at cost with no markup and may include Custodian-imposed fees for processing proxy materials. Administrative costs associated with shareholder communications. Direct third-party expenses incurred to facilitate the Client's voting request. If a Client wants to vote on a specific proxy issue but delegates others, HT Partners will evaluate feasibility on a case-by-case basis, and the Client will bear any associated costs. Conflicts of Interest & Mitigation Since HT Partners establishes the voting guidelines followed by EC Proxy, this creates a potential conflict of interest if proxy votes affect issuers with business relationships or investments involving HT Partners, its affiliates, or employees. 23  To mitigate this, HT Partners' voting guidelines are developed independently and are designed to align with Clients' best interests. HT Partners' Investment Policy Committee oversees the annual review process to prevent bias or undue influence. Any material conflicts of interest that arise in proxy voting decisions will be disclosed to Clients upon request. Access to Proxy Voting Records & Cost Transparency Clients may request a report detailing how proxies were voted for their account(s) at no additional cost if HT Partners votes proxies on their behalf. If a Client has opted to vote their proxies and requires HT Partners to facilitate reporting or shareholder material processing, associated costs will be passed through at cost. Any requests for proxy voting records or reports should be directed to Peter J. Decker. HT Partners remains committed to acting in Clients' best interests when voting proxies and ensures that all voting activities are conducted in accordance with the Firm's established policies and procedures. HT Partners will neither advise nor act on behalf of the Client in legal proceedings involving companies whose securities are held in the Client's account(s), including, but not limited to, the filing of Proofs of Claim in class action settlements. If desired, the Client may direct the Firm to transmit copies of class action notices to the Client or a third party. Upon such direction, the Firm will make commercially reasonable efforts to forward such notices promptly. Item 18. Financial Information Under no circumstances will HT Partners require payment of fees above $1,200 more than six months in advance of services rendered. 24