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Brochure
Form ADV Part 2A
Item 1 - Cover Page
CRD# 144516
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
www.NHoffmanandCo.com
March 14, 2025
This Brochure provides information about the qualifications and business practices of Nicholas
Hoffman & Company, LLC. If you have any questions about the contents of this Brochure, please
contact us at (404) 815-5050 or nhoffman@nhoffmanandco.com. The information in this Brochure
has not been approved or verified by the United States Securities and Exchange Commission or by
any state authority.
Nicholas Hoffman & Company, LLC is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
www.AdviserInfo.sec.gov
information about Nicholas Hoffman & Company, LLC also is available on the SEC’s website at
.
Item 2 - Material Changes
Registered Investment Advisers are required to use the Brochure to inform clients of the nature of
advisory services provided, types of clients served, fees charged, potential conflicts of interest and
other information. The Brochure requirements include providing a Summary of Material Changes
(the “Summary”) reflecting any material changes to our policies, practices, or conflicts of interest
made since our last required “annual update” filing. In the event of any material changes, such
Summary is provided to all clients within 120 days of our fiscal year-end. Our last annual update
was filed on March 27, 2024. The complete Brochure is available to clients at any time upon
request.
Item 3 - Table of Contents
Page
Item 1 - Cover Page ............................................................................................................................................................ 1
Item 2 - Material Changes................................................................................................................................................ 1
Item 3 - Table of Contents ............................................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................................. 3
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 .............................................................................................................................. 11
Item 10 - Other Financial Industry Activities and Affiliations ....................................................................... 11
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 11
Item 12 - Brokerage Practices ..................................................................................................................................... 12
Item 13 - Review of Accounts ...................................................................................................................................... 15
Item 14 - Client Referrals and Other Compensation .......................................................................................... 16
Item 15 - Custody .............................................................................................................................................................. 16
Item 16 - Investment Discretion ................................................................................................................................. 16
Item 17 - Voting Client Securities .............................................................................................................................. 16
Item 18 - Financial Information .................................................................................................................................. 17
Brochure Supplements…………………..………………………...………….……………………………………… Exhibit A
Page 2
Item 4 - Advisory Business
General Information
Nicholas Hoffman & Company, LLC (“we,” “us” or “NHCO”) was formed in 2007 and provides
financial planning and portfolio management services to its clients.
Brochure Supplements
Exhibit A
Nicholas J. Hoffman is the sole principal owner of NHCO. Please see
,
, for more information on Mr. Hoffman and other individuals who formulate investment
advice and have direct contact with clients or have discretionary authority over client accounts.
As of December 31, 2024, we managed $5,826,920,988 on a discretionary basis, and
$1,334,250,873 of assets on a non-discretionary basis.
SERVICES OFFERED
At the outset of each client relationship, we spend time with the client, asking questions, discussing
the client’s investment experience and financial circumstances, and broadly identifying major goals
of the client.
Clients may elect to retain us to prepare a full financial plan. This detailed analysis is presented to
the client for consideration. In most cases, clients subsequently retain us to manage the investment
portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain us for portfolio management services, based on all the information
initially gathered, we generally develop with each client:
•
•
a financial outline for the client based on the client’s financial circumstances and goals, and
the client’s risk tolerance level (the “Financial Profile” or “Profile”);
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments we will make or
recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed
regularly with each client but are not necessarily written documents.
Financial Planning
One of the services offered by us is financial planning, described below. This service may be
provided as a stand-alone service or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of a client's financial
situation, such as estate planning, risk management, budgeting and cash flow controls, retirement
planning, education funding, philanthropic planning, and investment portfolio design. Depending
on a client’s particular situation, financial planning may include some or all of the following:
•
•
•
Gathering factual information concerning the client's personal and financial situation;
Assisting the client in establishing financial goals and objectives;
Analyzing the client's present situation and anticipated future activities in light of the
client's financial goals and objectives;
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•
•
•
•
•
Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
Making recommendations to help achieve retirement plan goals and objectives;
Designing an investment portfolio to help meet the goals and objectives of the client;
Providing estate planning, and
Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is given, the client may choose to have us implement the client’s
financial plan and manage the investment portfolio on an ongoing basis. However, the client is
under no obligation to act upon any of the recommendations made by us under a financial planning
engagement and/or engage the services of any recommended professional.
Portfolio Management
As described above, at the beginning of a client relationship, we meet with the client, gather
information, and perform research and analysis as necessary to develop the client’s Investment
Plan. The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by us based on updates to the client’s financial or other
circumstances.
To implement the client’s Investment Plan, we will manage the client’s investment portfolio on a
discretionary basis or a non-discretionary basis. As a discretionary investment adviser, we will
have the authority to supervise and direct the portfolio without prior consultation with the client.
Under a non-discretionary arrangement, clients must be contacted prior to the execution of any
trade in the account(s) under management. This may result in a delay in executing recommended
trades, which could adversely affect the performance of the portfolio. In a non-discretionary
arrangement, the client retains the responsibility for the final decision on all actions taken with
respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on us in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the
client’s investment portfolio. Each client should also note that his or her investment portfolio is
treated individually by giving consideration to each purchase or sale for the client’s account. For
these and other reasons, performance of client investment portfolios within the same investment
objectives, goals and/or risk tolerance may differ, and clients should not expect that the
composition or performance of their investment portfolios would necessarily be consistent with
similar clients of ours.
Private Funds
We will from time to time, based on the client’s risk tolerance, sophistication and financial
qualifications, recommend that a portion of the client’s assets be invested in certain private
investments. These include private equity, private debt and real estate funds, hedge funds, and
other types of private investment vehicles (collectively “Private Funds”). We will assist clients in
implementation of such recommendations to invest in Private Funds; however, we do not exercise
discretion with respect to these types of investments. We will continue to render the advisory
services to the client, relative to the ongoing monitoring and review of asset performance and due
diligence of the Private Fund. Clients are provided with private placement memorandums and other
offering and subscription documentation that detail the nature, risks and associated fees of each
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Private Fund. It is important that the client read and review these documents with their legal and
tax advisors, before investing, to fully understand the types of investments, risks and conflicts
pertaining to the Private Funds.
Separate Account Managers
When appropriate and in accordance with the Investment Plan for a client, we may recommend the
use of one or more separate account managers, each a “Manager”. Having access to various
Managers offers a wide variety of manager styles and offers clients the opportunity to utilize more
than one Manager if necessary to meet the needs and investment objectives of the client. We will
select the Manager(s) we deem most appropriate for the client. Factors that we consider in
recommending/selecting Managers generally includes the client’s stated investment objective(s),
management style, performance, risk level, reputation, financial strength, reporting, pricing, and
research.
The Manager(s) will be granted discretionary trading authority to provide investment supervisory
services for the portfolio, but we normally retain the authority to terminate the Manager’s
relationship or to add new Managers without specific client consent. With respect to assets
managed by a Manager, our role will be to monitor the overall financial situation of the client, to
monitor the investment approach and performance of the Manager(s), conduct on-going due
diligence, and to assist the client in understanding the investments of the portfolio.
In instances where the services of one or more Managers are utilized, the fee assessed by the
Manager(s) will be separate and in addition to our fee and will be detailed in a Management
Agreement signed by the client.
may impose more restrictive account requirements than NHCO, and
Additionally, certain Managers
billing practices may vary. In such instances, we may be required to alter our corresponding
account requirements and/or billing practices to accommodate those of the Manager(s).
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. We will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The
particular services provided will be detailed in the consulting agreement. The appropriate Plan
Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i)
make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and
(iii) make the ultimate decision as to accepting any of the recommendations that we may provide.
The Plan Fiduciaries are free to seek independent advice about the appropriateness of any
recommended services for the Plan. Retirement Plan consulting services may be offered
individually or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, we will be considered a fiduciary under ERISA.
With respect to any account for which we meet the definition of a fiduciary under Department of
Labor rules, we acknowledge that both NHCO and its Related Persons are acting as fiduciaries.
Additional disclosure may be found elsewhere in this Brochure or in the written agreement
between us and Client.
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Consulting
Fiduciary
Services
Investment Selection Services
•
We will provide Plan Fiduciaries with recommendations of investment options consistent
with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination
of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment
advice regarding asset classes and investments.
Investment Monitoring
•
investment performance, consistency of
We will assist in monitoring the plan’s investment options by preparing periodic
fund
investment reports that document
management and conformation to the guidelines set forth in the investment policy
statement and we will make recommendations to maintain or remove and replace
investment options. The details of this aspect of service will be enumerated in the
engagement agreement between the parties.
Non-Fiduciary Services
• Participant Education
We will provide education services to Plan Participants about general investment principles
and the investment alternatives available under the Plan. Education presentations will not
take into account the individual circumstances of each Plan Participant and individual
recommendations will not be provided unless a Plan Participant separately engages us for
such services. Plan Participants are responsible for implementing transactions in their own
accounts.
• Participant Enrollment
We will assist with group enrollment meetings designed to increase retirement Plan
participation among employees and investment and financial understanding by the
employees.
Retirement Plan Rollovers
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also
fiduciaries 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. We must
act in your best interest and not put our interest ahead of yours. If we recommend that you roll over
or transfer your retirement assets into an account to be managed by us, such a recommendation
creates a conflict of interest if we will earn a new (or increase our current) advisory fee because of
the rollover/transfer. You are under no obligation to roll over retirement assets to an IRA managed
Item 5 - Fees and Compensation
by us or to engage us to monitor and/or manage the account while maintained at your employer.
Item 12 - Brokerage Practices
General Fee Information
Fees paid to us are exclusive of all custodial and transaction costs paid to the client’s custodian,
for additional
brokers or other third-party consultants. Please see
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information. Fees paid to us are also separate and distinct from the fees and expenses charged by
mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s prospectus
or offering materials). The client should review all fees charged by funds, brokers, us and others to
fully understand the total amount of fees paid by the client for investment and financial-related
services.
Financial Planning Fees
When we provide financial planning services to clients, these services are generally part of our
portfolio management services. If a separate fee is to be charged for financial planning, it will be
negotiated at the time of the engagement for such services and will normally be in the form of a
fixed fee.
Portfolio Management Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
First $1,000,000
Next $2,000,000
Next $2,000,000
Next $5,000,000
Next $10,000,000
Amounts over $20,000,000
1.25%
1.00%
0.75%
0.50%
0.40%
0.30%
Although we have established the standard fee structure set forth above, we retain the discretion to
negotiate or waive fees on a client-by-client basis. We may also negotiate a fixed fee or negotiate a
minimum portfolio value and/or a minimum fee. In proposing the fee structure for your account(s),
we consider the nature of our proposed advisory relationship, which is determined by the assets to
be placed under our management, anticipated future additional assets, the complexity of financial
planning services to be provided, other accounts you may have with us, account type, portfolio
style, account composition, and reporting, among other factors. Your specific annual fee structure is
described in your Advisory Agreement (“Agreement”) with us. Also, pre-existing advisory clients
are subject to any minimum fee requirements and advisory fees in effect at the time the client
entered into the advisory relationship with us. Therefore, the applicable minimum fee
requirements as well as advisory fees paid will differ among clients, and other clients may pay less
than you or have lower minimums.
Asset-based portfolio management fees are generally payable quarterly, in arrears. The client’s
total asset value at the end of each month in the quarter are averaged to calculate the “average
monthly balance” for the quarter. The average monthly balance is applied to the annual fee
schedule set out in the client’s Agreement and then divided by four (4) to calculate the quarterly
fee. Clients with a fixed fee arrangement may be charged quarterly in advance or arrears. Our
policy is to round fee values to the nearest whole dollar. Each client’s specific fee arrangement is
detailed in the client’s Agreement with us.
If management begins after the start of a quarter, fees will be prorated accordingly. With client
authorization and unless other arrangements are made, fees are normally debited directly from
client account(s).
Either we or the client may terminate the Agreement at any time, subject to any written notice
requirements in the Agreement. In the event of termination, any paid but unearned fees will be
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promptly refunded to the client based on the number of days that the account was managed, and
any fees due us from the client will be invoiced or deducted from the client’s account prior to
termination.
Private Fund Fees
When a client invests in a Private Fund, the fees and other expenses assessed by the Private Fund
will be separate from and in addition to our fee. Additionally, some of the Private Funds that we
recommend charge performance-based fees. The applicable fees and expenses of each Private Fund
are outlined in its offering documents and should be reviewed by investors prior to investing. We
do not receive any portion of these fees.
Separate Account Manager Fees
Each Manager will assess its own fee, which will be charged according to the Manager’s established
fee schedule. This will be disclosed to the client prior to the time of the engagement.
Item 6 - Performance-Based Fees and Side-By-Side Management
We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a
situation in which the same firm manages accounts that are billed based on a percentage of assets
under management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because we have no performance-based fee accounts, we have no side-by-
side management.
Item 7 - Types of Clients
We serve individuals, pension and profit-sharing plans, trusts, foundations, and estates. We may
impose a minimum portfolio value eligible for conventional investment advisory services and/or a
minimum fee.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
In accordance with the Investment Plan, we will primarily invest in ETFs, mutual funds, managed
accounts, some common stock, and bonds. Some clients have financial objectives and needs which
support consideration of Private Funds, which may include, without limitation, hedge funds,
investments in real estate, private equity and private debt.
ETFs and Mutual funds are generally evaluated and selected based on a variety of factors, including,
without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings
for safety and returns, and other factors.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity
or income needs in a portfolio, or to add a component of capital preservation. We will generally
evaluate and select individual bonds or bond funds based on a number of factors including, without
limitation, rating, yield and duration.
Directly held equities may be used where tax efficiency, avoidance of third-party management fees,
and the potential for long-term dividend streams are desired by clients. We generally rely on third-
party research reports from vendors like Refinitiv, Morningstar, and the Center for Financial
Research and Analysis (CFRA) to evaluate the appropriateness of directly held equities.
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Private Funds are generally evaluated based on the previous performance and reputation of the
manager, fee structure, overall risk and returns, portfolio transparency, liquidity and other factors
specific to the type of investments involved.
Investment Strategies
Our strategic approach is to invest each portfolio in accordance with the Plan that has been
developed specifically for each client. This means that the following strategies may be used in
varying combinations over time for a given client, depending upon the client’s individual
circumstances.
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of
the securities’ short-term price fluctuations.
Risk of Loss
While we seek to diversify clients’ investment portfolios across various asset classes consistent
with their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject
to risks. Accordingly, there can be no assurance that client investment portfolios will be able to
fully meet their investment objectives and goals, or that investments will not lose money.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks.
While we manage client investment portfolios based on our experience,
research and proprietary methods, the value of client investment portfolios will change daily based
on the performance of the underlying securities in which they are invested. Accordingly, client
investment portfolios are subject to the risk that we allocate client assets to individual securities
and/or asset classes that are adversely affected by unanticipated market movements, and the risk
that our specific investment choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described above, we will
usually invest client portfolios in mutual funds, ETFs and other investment pools (“pooled
investment funds”). Investments in pooled investment funds are generally less risky than investing
in individual securities because of their diversified portfolios; however, these investments are still
subject to risks associated with the markets in which they invest. In addition, pooled investment
funds’ success will be related to the skills of their particular managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory
restrictions applicable to registered investment companies under the Investment Company Act of
1940.
Equity Market Risks.
We may invest portions of client assets directly into equity investments,
primarily stocks, or into pooled investment funds that invest in the stock market. As noted above,
while pooled investments have diversified portfolios that may make them less risky than
investments in individual securities, funds that invest in stocks and other equity securities are
nevertheless subject to the risks of the stock market. These risks include, without limitation, the
risks that stock values will decline due to daily fluctuations in the markets, and that stock values
will decline over longer periods (e.g., bear markets) due to general market declines in the stock
prices for all companies, regardless of any individual security’s prospects.
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Fixed Income Risks.
We may invest portions of client assets directly into fixed income instruments,
such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes.
While investing in fixed income instruments, either directly or through pooled investment funds, is
generally less volatile than investing in stock (equity) markets, fixed income investments
nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks
that changes in interest rates will devalue the investments), credit risks (risks of default by
borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance
to maturity).
Foreign Securities Risks.
We may invest portions of client assets directly into foreign securities or
into pooled investment funds that invest internationally. While foreign investments are important
to the diversification of client investment portfolios, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial
reporting or disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency
risk, which is the risk that the value of the foreign security will decrease due to changes in the
relative value of the U.S. dollar and the security’s underlying foreign currency.
Risks Related to Private Funds
. From time to time and as appropriate, we may invest a portion of a
client’s portfolio in Private Funds. The value of client portfolios will be based in part on the value of
Private Funds in which they are invested, the success of each of which will depend heavily upon the
efforts of their respective Managers. When the investment objectives and strategies of a Manager
are out of favor in the market or a Manager makes unsuccessful investment decisions, the Private
Fund may lose money. A client account may lose a substantial percentage of its value if the
investment objectives and strategies of many or most of the Private Funds in which it is invested
are out of favor at the same time, or many or most of the Managers make unsuccessful investment
decisions at the same time. Private Funds are generally subject to various risk factors and liquidity
constraints, a complete discussion of which is set forth in each fund’s offering documents, which
will be provided to clients for review and consideration prior to investing. Investing in Private
Funds is intended only for experienced and sophisticated investors who are willing to bear the high
economic risks of the investment. Clients should carefully review and consider potential risks
before investing in private funds. Certain of these risks may include loss of all or a substantial
portion of the investment due to leveraging, short-selling, or other speculative practices, lack of
liquidity because of redemption terms and conditions and that there may not and will not be a
secondary market for the fund, volatility of returns, restrictions on transferring interests in the
fund, a potential lack of diversification, higher fees than mutual funds, lack of information regarding
valuations and pricing.
Real Estate Risk
. We may gain exposure to the real estate sector by investing in real estate or funds
that invest in real estate. These investments are subject to risks including loss to casualty or
condemnation, increases in property taxes and operating expenses, zoning law amendments,
changes in interest rates, overbuilding and increased competition, variations in market value, and
possible environmental liabilities.
Margin Risk.
We do not use margin as an investment strategy. However, you may elect to borrow
funds against your investment portfolio. For accounts with a margin balance, you are assessed the
management fee based on the gross value of the assets in your account. In other words, your
account value on which the fee is calculated is not reduced by the margin balance. This could create
a conflict of interest where we may have an incentive to encourage the use of margin as this could
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result in a higher market value and therefore an increased management fee. When securities are
purchased, they may be paid for in full or the client may borrow part of the purchase price from the
account custodian. If a client borrows part of the purchase price, the client is engaging in margin
transactions and there is risk involved with this. The securities held in a margin account are
collateral for the custodian that loaned the client money. If those securities decline in value, then
the value of the collateral supporting the client’s loan also declines. As a result, the brokerage firm
is required to take action in order to maintain the necessary level of equity in the client’s account.
The brokerage firm may issue a margin call and/or sell other assets in the client’s account to
accomplish this. It is important that clients fully understand the risks involved in trading securities
on margin, including but not limited to:
•
•
•
•
•
•
Item 9 - Disciplinary Information
It is possible to lose more funds than is deposited into a margin account;
The account custodian can force the sale of assets in the account;
The account custodian can sell assets in the account without contacting the client first;
The account holder is not entitled to choose which assets in a margin account may be sold
to meet a margin call;
The account custodian can increase its “house” maintenance margin requirements at any
time without advance written notice; and
The accountholder is not entitled to an extension of time on a margin call.
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of us or the integrity of our
management. We have no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
Neither NHCO nor its Management Persons have any other financial industry activities or
affiliations to report.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. Our Code has several goals. First, the Code is designed to assist us in complying with
applicable laws and regulations governing its investment advisory business. Under the Investment
Advisers Act of 1940, we owe fiduciary duties to its clients. Pursuant to these fiduciary duties, the
Code requires persons associated with us (managers, officers and employees) to act with honesty,
good faith and fair dealing in working with clients. In addition, the Code prohibits such associated
persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for NHCO’s associated persons.
Under the Code’s Professional Standards, NHCO expects its associated persons to put the interests
of its clients first, ahead of personal interests. In this regard, NHCO associated persons are not to
take inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, NHCO’s associated persons may invest in the
same securities recommended to clients. In the Code, we have adopted procedures designed to
reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal
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trading policies include procedures for limitations on personal securities transactions of associated
persons, reporting and review of such trading and pre-clearance of certain types of personal
trading activities. These policies are designed to discourage and prohibit personal trading that
would disadvantage clients. The Code also provides for disciplinary action as appropriate for
violations.
Participation or Interest in Client Transactions
Because client accounts are primarily invested in open end mutual funds, pooled investment
vehicles and independently managed accounts there is little opportunity for a conflict of interest
between personal trades by NHCO associated persons and trades in client accounts, even when
such accounts invest in the same securities. However, in the event of other identified potential
trading conflicts of interest, our goal is to place client interests first.
Consistent with the foregoing, we maintain policies regarding participation in initial public
offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts with
client transactions. If a NHCO associated person wishes to participate in an IPO or invest in a
private placement, he or she must submit a pre-clearance request and obtain the approval of the
Chief Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated person’s shares will be removed from the block,
and the balance of shares will be allocated among client accounts in accordance with our written
policy.
Item 12 - Brokerage Practices
The custodians and brokers we use
Item 15 – Custody
We do not maintain custody of your assets that we manage or on which we advise, although we may
be deemed to have custody of your assets if you give us authority to withdraw assets from your
account (see
, below).
Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer
or bank. We recommend that most of our clients use Charles Schwab & Co., Inc. (“Schwab”), as the
qualified custodian. In certain limited instances, we may recommend the custodial services of
Fidelity Institutional Wealth Services (“Fidelity”), a division of Fidelity Brokerage Services LLC, for
ultra-high-net-worth clients who would benefit from Fidelity’s suite of family office services.
Schwab and Fidelity (together, the “Custodians”) are registered broker-dealers, members SIPC. We
are independently owned and operated and are not affiliated with the Custodians.
The account custodian will hold your assets in a brokerage account and buy and sell securities
when we (or you) instruct them to. While we recommend that you use Schwab (or Fidelity in
limited instances) as custodian/broker, you will decide whether to do so and will open your
account with the custodian by entering into an account agreement directly with them. We do not
open the account for you, although we may assist you in doing so. Even though your account is
maintained at one of our recommended custodians, we can still use other brokers to execute trades
for your account as described below (see “Your brokerage and custody costs”)
Page 12
How we select brokers/custodians
We seek to recommend a custodian/broker that will hold your assets and execute transactions on
terms that are overall most advantageous when compared with other available providers and their
services. We consider a wide range of factors, including, but not limited to:
•
•
•
•
•
•
•
•
•
•
•
Combination of transaction execution services and asset custody services (generally
without a separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill
payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds (ETFs), etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates,
other fees, etc.) and willingness to negotiate the prices
Reputation, financial strength, security and stability
Prior service to us and our clients
Availability of other products and services that benefit us, as discussed below (see
“Products and services available to us from the Custodians”)
Your brokerage and custody costs
The Custodians generally do not charge you separately for custody services but are compensated by
charging you commissions or other fees on trades that they execute or that settle into your account.
Certain trades may not incur commissions or transaction fees. The Custodians are also
compensated by earning interest on the uninvested cash in your account. In addition to
commissions, you may be charged a flat dollar amount as a “prime broker” or “trade away” fee for
each trade that we have executed by a different broker-dealer but where the securities bought or
the funds from the securities sold are deposited (settled) into your account. These fees are in
addition to the commissions or other compensation you pay the executing broker/dealer. Because
of this, in order to minimize your trading costs, we have your account custodian execute most
trades for your account. We have determined that having you account custodian execute most
trades is consistent with our duty to seek “best execution” of your trades. Best execution means the
most favorable terms for a transaction based on all relevant factors, including those listed above
(see “How we select brokers/custodians”).
Products and services available to us from the Custodians
The Custodians provide our clients and us with access to their institutional brokerage services
(trading, custody, reporting and related services), many of which are not typically available to their
retail customers. They also make available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow our business.
These support services are generally available on an unsolicited basis (we don’t have to request
them) and at no charge to us. Following is a more detailed description of the support services
offered by the Custodians:
Services That Benefit You.
The Custodians’ brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. They make investment products
Page 13
available to us that include some to which we might not otherwise have access or that would
require a significantly higher minimum initial investment by our clients. Such services generally
benefit you and your account.
Services that may not directly benefit you.
The Custodians also make available to us other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both their own and that of
third parties. We may use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at the custodian from which we obtained the research.
In addition to investment research, the Custodians also make available software and other
technology that:
•
•
•
•
•
provide access to client account data (such as duplicate trade confirmations and account
statements)
facilitate trade execution and allocate aggregated trade orders for multiple client
accounts
provide pricing and other market data
facilitate payment of our fees from our clients’ accounts
assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us.
The Custodians also offer other services intended to help us manage and further develop our
business enterprise. These services include:
•
•
•
•
•
Educational conferences and events
Consulting on technology, compliance, legal, and business needs
Publications and conferences on practice management and business succession
Access to employee benefits providers, human capital consultants, and insurance
providers
Marketing consulting and support
The Custodians may provide some of these services themselves. In other cases, they will arrange for
third-party vendors to provide the services to us. They may also discount or waive their fees for
some of these services or pay all or a part of a third party’s fees. We also may be provided with
other benefits such as occasional business entertainment of our personnel.
Our interest in the Custodians’ services
The availability of these services from the Custodians benefits us because we do not have to
produce or purchase them. These services are not contingent upon us committing any specific
amount of business to the Custodians in trading commissions or assets in custody. However, the
benefits that we and our clients receive create an incentive to recommend that you maintain your
account with the Custodians, based on our interest in receiving their services that benefit our
business and their payment for services for which we would otherwise have to pay rather than
based on your interest in receiving the best value in custody services and the most favorable
execution of your transactions. This is a conflict of interest.
We believe, however, that our recommendation of the Custodians is in the best interests of our
clients. Our selection is primarily supported by the full scope, quality, and price of their services
(see “How we select brokers/ custodians”) and not the services that benefit only us.
Page 14
Directed Brokerage
Clients may direct us to use a particular broker for custodial or transaction services on behalf of the
client’s portfolio. In directed brokerage arrangements, the client is responsible for negotiating the
commission rates and other fees to be paid to the broker. Accordingly, a client who directs
brokerage should consider whether such designation may result in certain costs or disadvantages
to the client, either because the client may pay higher commissions or obtain less favorable
execution, or the designation limits the investment options available to the client.
The arrangements that we have with the Custodians is designed to maximize efficiency and to be
cost effective. By directing brokerage arrangements, the client acknowledges that these economies
of scale and levels of efficiency are generally compromised when alternative brokers are used.
While every effort is made to treat clients fairly over time, the fact that a client chooses to use the
brokerage and/or custodial services of these alternative service providers can in fact result in a
certain degree of delay in executing trades for their account(s) and otherwise adversely affect
management of their account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and
agree with us that they have the authority to make the direction, that there are no provisions in any
client or plan document which are inconsistent with the direction, that the brokerage and other
goods and services provided by the broker or dealer through the brokerage transactions are
provided solely to and for the benefit of the client’s plan, plan participants and their beneficiaries,
that the amount paid for the brokerage and other services have been determined by the client and
the plan to be reasonable, that any expenses paid by the broker on behalf of the plan are expenses
that the plan would otherwise be obligated to pay, and that the specific broker or dealer is not a
party in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We typically direct trading in individual client accounts as and when trades are appropriate based
on the client’s Investment Plan, without regard to activity in other client accounts. However, from
time to time, we may aggregate trades together for multiple client accounts, most often when these
accounts are being directed to sell the same securities. If such an aggregated trade is not
completely filled, we will allocate shares received (in an aggregated purchase) or sold (in an
aggregated sale) across participating accounts on a pro rata or other fair basis; provided, however,
that any participating accounts that are owned by us or our officers, directors, or employees will be
Item 13 - Review of Accounts
excluded first.
Managed portfolios are generally reviewed quarterly but may be reviewed more often if requested
by the client, upon receipt of information material to the management of the portfolio, or at any
time such review is deemed necessary or advisable by us. These factors generally include but are
not limited to, the following: change in general client circumstances (marriage, divorce,
retirement); or economic, political or market conditions. Nicholas J. Hoffman, a designated
Principal, or a Senior Investment Advisor of the firm, review all accounts.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. In addition, we provide at least
an annual report for each managed portfolio. This written report normally includes a summary of
Page 15
portfolio holdings and performance results. Additional reports are available at the request of the
client.
Item 14 - Client Referrals and Other Compensation
Item 12 - Brokerage Practices.
As noted above, we receive an economic benefit from the Custodians in the form of support
products and services they make available to us and other independent investment advisors whose
clients’ accounts they maintain. These products and services, how they benefit our firm, and the
related conflicts of interest are described in
The availability of the
products and services the Custodians provide to us are based solely on our participation in their
programs and not on the provision of any particular investment advice.
Item 15 - Custody
Schwab is the custodian of the large majority of our client accounts. From time to time however,
clients may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms and at least
quarterly account statements. Clients are advised to review this information carefully, and to notify
us of any questions or concerns. Clients are also asked to promptly notify us if the custodian fails to
provide statements on each account held.
From time to time and in accordance with our Agreement with clients, we will provide additional
reports. The account balances reflected on these reports should be compared to the balances
shown on the brokerage statements to ensure accuracy. At times, there may be small differences
Item 16 - Investment Discretion
due to the timing of dividend reporting and pending trades or similar issues.
Item 4 - Advisory Business
discretionary accounts
, we will accept clients on either a discretionary or non-
As described in
discretionary basis. For
, a Limited Power of Attorney (“LPOA”) is executed
by the client, giving us the authority to carry out various activities in the account, generally
including the following: trade execution; the ability to request checks on behalf of the client; and
the withdrawal of advisory fees directly from the account. We then direct investment of the client’s
portfolio using its discretionary authority. The client may limit the terms of the LPOA to the extent
consistent with the client’s Agreement with us and the requirements of the client’s custodian.
non-discretionary
For
accounts, the client also generally executes an LPOA, which allows us to carry
out trade recommendations and approved actions in the portfolio. However, in accordance with
the Agreement between us and the client, we do not implement trading recommendations or other
actions in the account unless and until the client has approved the recommendation or action. As
with discretionary accounts, clients may limit the terms of the LPOA, subject to our Agreement with
the client and the requirements of the client’s custodian.
Item 17 - Voting Client Securities
As a policy and in accordance with our Agreement, we do not vote proxies related to securities held
in client accounts. The custodian of the account will normally provide proxy materials directly to
the client. Clients may contact us with questions relating to proxy matters; however, we do not
generally perform detailed research regarding proxy voting options.
Page 16
Item 18 - Financial Information
We do not require nor solicit prepayment of more than $1,200 in fees per client, six months or more
in advance, and therefore has no disclosure required for this item.
Page 17
Set forth below is the Summary of Material Changes for Nicholas Hoffman & Company, LLC
(“NHCO”) since the last annual update of the Brochure made on March 27, 2024:
Date of Change
Description of Item
•
March 2025
Effective March 1, 2025, NHCO moved to a new location. The firm’s
new address is listed below:
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
Item 5 – Fees and Compensation
•
was updated to reflect that our
advisory fees are rounded to the nearest whole dollar.
Item 15 – Custody
•
was revised to reflect we no longer have
arrangements allowing us to access certain client accounts to
assist with bill payments.
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Nicholas J. Hoffman
CRD# 1513288
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Nick Hoffman, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Nick is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Nicholas J. Hoffman (year of birth 1957) founded NHCO in 2007 and has overall responsibility for its
management and the investment strategies for all clients. From 2002 until 2007, Nick was a partner
with Diversified Trust, a southeastern based Private Trust Company. Prior to that, he was a partner
with Balentine & Company (1992 - 2001) a local Investment Advisory firm now a part of Wilmington
Trust, where Nick designed and directed the firm’s integrated approach to strategic tax and financial
planning.
Money and Finance
th
Grade at Pace Academy on
Nick served for over sixteen years on the Board of Goodwill Industries (Atlanta), including serving as
Chairman. He also serves on the Board and is a past Chairman of the Society of International Business
fellows (“SIBF”). As the founder of “The Responsibility of Wealth Forum”, he has been featured on
National Public Radio (“NPR”) as well as in several national publications. He has also taught a course
and conducts an annual summer program
to the 12
on “Money & Responsibility” at Cambridge University.
Exhibit A-1
Nick was born and educated in England, where he received an honors degree in Law from the
University of Exeter. He began his career as a Chartered Accountant with KPMG in London and
Item 3 - Disciplinary Information
Germany. He is a Fellow of the Institute of Chartered Accountants.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Nick has no such disciplinary
information to report.
Item 4 - Other Business Activities
Nick is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Nick has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Nick and
may be reached at (404) 815-5050.
Exhibit A-2
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Gary B. Martin, CFA
CRD# 1686747
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Gary Martin, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Gary is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Gary B. Martin (year of birth 1961) is a Principal of NHCO with responsibilities that include client
account management and general firm directives. Gary is also a member of NHCO’s Investment
Management Committee, which oversees the investment process. He has over forty years of financial
services experience. For more than thirty years, Gary has worked extensively with individuals and
their families providing comprehensive wealth management. Gary’s expertise includes investment
management and allocation, manager research and all aspects of the financial planning process.
Prior to joining NHCO in 2009, Gary was with Wilmington Trust Company as the senior team leader
responsible for managing the largest private wealth group within the Atlanta office for six years.
Prior to that, he was a senior partner with Balentine & Company an Atlanta based investment
advisory firm that was acquired by Wilmington Trust in 2002. Gary began his career on Wall Street
spending the first seven years with Bankers Trust Company and then UBS Securities where he
worked in various institutional sales and trading functions.
Exhibit A-3
®
designation* in 1997.
Gary was born in Chicago, received his undergraduate degree from Harvard University, and his
graduate degree in business administration from Emory University. He received his Chartered
Financial Analyst
Gary and his wife live in the Virginia Highland neighborhood of Atlanta and have five adult children.
Gary is an avid cyclist, ice hockey player and fitness enthusiast.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
Item 3 - Disciplinary Information
candidate must hold a bachelor’s degree.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Gary has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Gary is not engaged in any other business activities.
Gary has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Gary and
may be reached at (404) 815-5050.
Exhibit A-4
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
A. Carl Gambrell
CRD# 1270376
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Carl Gambrell, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Carl is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
A. Carl Gambrell (year of birth 1955) is a Principal of NHCO with responsibilities that include client
account management and general firm directives. Carl is also a member of NHCO’s Investment
Management Committee, which oversees the investment process. He has extensive experience as an
investment professional with over forty-five years as a portfolio manager and an institutional fixed
income specialist. Prior to joining NHCO in 2009, Carl was a director with Merrill Lynch (eleven
years) and Credit Suisse First Boston (fourteen years). His depth of product expertise covers all fixed
income securities.
Over the course of his career, Carl has had client relationship responsibilities for some of the largest
and most sophisticated institutional accounts in the country including international money
managers, life insurance companies, public pension funds, hedge funds and major US commercial
banks. During the first seven years of his career, Carl was a Senior Vice President and head of the
investment department at two financial institutions in the Southeast with responsibilities for security
selection, market timing, and asset liability management.
Exhibit A-5
Carl graduated from Mississippi State University with a degree in Finance. He and his wife have two
daughters. Carl is a member of the First Presbyterian Church of Atlanta. He is passionate about
Item 3 - Disciplinary Information
college football and loves working on renovation projects around his home.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Carl has no such disciplinary
information to report.
Item 4 - Other Business Activities
Carl is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Carl has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Carl and
may be reached at (404) 815-5050.
Exhibit A-6
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Eleanor D. Quarles
CRD# 1422288
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Eleanor Quarles, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have
any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Eleanor is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Eleanor D. Quarles (year of birth 1960) is the Director of Client Services for NHCO, where she is
responsible for client account administration and operations. Prior to joining NHCO in 2007, Eleanor
worked as a Client Service Officer for Wilmington Trust Wealth Advisory Services, servicing high net
worth families, individuals and foundations for seventeen years. She was a member of Wilmington
Trust’s Diversity Council to the National Offices.
Eleanor began her career at Merrill Lynch Pierce Fenner and Smith in Princeton, New Jersey. She is
a graduate of Douglas College, Rutgers University.
Eleanor is a founding member of Transformational Ministries International, formerly known as First
Congregation Ministries of Stone Mountain, Georgia, where she participates in various community
outreach initiatives from finances to emotional health. She was a founding member of New Creation
Christian Fellowship where she served as the Director of the Children’s Church and facilitated
Restored, a divorce support outreach ministry. She was a founding member of the women’s
Exhibit A-7
investment club, Increasing Wealth Amongst My Sisters, better known as IWAMS and served as
president for one term. Eleanor currently Serves on the Advisory Committee of Transformational
Ministries Global Network, a 501(c)(3) initiative that promotes financial literacy through its program
called In The Black On The Plus Side. She and her husband have 3 sons.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Eleanor has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Eleanor is not engaged in any other business activities.
Eleanor has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Eleanor
and may be reached at (404) 815-5050.
Exhibit A-8
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Cameron R. Simonds
CRD# 5389633
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Cam Simonds, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Cam is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Cameron R. Simonds (year of birth 1984) is Senior Investment Advisor for NHCO with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in the private investing arena. Cam works with clients on investment
strategy and allocation, strategic planning, and cash flow management.
Prior to joining NHCO in 2011, Cam was with Executive Advisor Group as an Associate where he
gained experience in portfolio management operations and comprehensive financial planning.
Cam grew up in Atlanta, attended Pace Academy and is a graduate of Presbyterian College with a
bachelor’s degree in Business Administration.
Exhibit A-9
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Cam has no such disciplinary
information to report.
Item 4 - Other Business Activities
Cam is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Cam has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Cam and
may be reached at (404) 815-5050
Exhibit A-10
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Richard Rushton
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Richard Rushton, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact NHCO at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you
have any questions about the contents of this Supplement.
Item 2 - Educational Background and Business Experience
Richard Rushton (year of birth 1958) serves as Chief Compliance Officer and Chief Operating Officer
and advises NHCO on all operational and compliance matters. Richard is also a member of NHCO’s
Investment Management Committee, which oversees the investment process. Richard initially
assisted with the formation of NHCO and continued to serve in a dedicated consulting role until
formally joining the firm in 2015. He has over twenty-six years of experience in business
management, consulting, and economic analysis.
After working initially as an economist and policy advisor in London, England, Richard spent ten
years consulting for, and then managing, fast growing retail banking operations including mortgages,
savings and investment services. In the U.S., he jointly led the growth of a Federal services provider
from annual revenues of $15 million to $350 million over a ten-year period. In 2001, the Company
was sold to a publicly quoted UK company. Richard subsequently served as CEO of the U.S. Company,
and as a member of the Executive Board of the British parent company.
Richard was born and educated in England. He received his undergraduate degree from the
University of Reading, and his graduate degree in Economics from the University of Oxford. Richard
is a past Chair of Soccer in the Streets, and Goodwill Industries of North Georgia. He and his wife have
three sons and a daughter.
Exhibit A-11
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Richard has no such disciplinary
information to report.
Item 4 - Other Business Activities
Richard is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Richard has no other income or compensation to disclose.
As the firm’s Chief Operating Officer and Chief Compliance Officer, Richard is responsible for
oversight of the firm's advisory services activities and its associated staff. As sole owner of the firm,
Nicholas Hoffman is responsible for oversight of Mr. Rushton. Please address questions relative to
the firm, staff, its services, or this ADV Part 2 or any Advisory Supplemental Brochure to the attention
of Richard or Nick at (404) 815-5050. Additional information about our firm, other advisory firms,
or an associated representative is available at www.adviserinfo.sec.gov.
Exhibit A-12
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Michael W. Masters, MBA
CRD# 5495395
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Mike Masters, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Mike is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Michael W. Masters (year of birth 1964) is a Senior Investment Advisor for NHCO with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in public investing and hedge funds. Mike works with clients on
investment strategy, asset allocation and security selection, performance monitoring, and cash flow
management.
Mike has over 25 years of financial market experience. Prior to joining Nicholas Hoffman & Company
in 2014, Mike worked as Vice President and Portfolio Manager at Sterling Investment Management,
Inc. where he was responsible for managing the investment portfolios of several affluent families.
Prior to joining Sterling, Mike worked as Portfolio Manager at Daniel Financial Group where he was
responsible for more than $50 million in assets under management. Previously he has worked in the
equity research department of a mutual fund company with more than $500 million in assets under
management. He has also performed buy-side equity research for a private investment partnership
where he supported a team that managed a concentrated stock portfolio.
Exhibit A-13
Mike holds a BA in Philosophy from Emory University where he graduated with honors. He holds an
MBA in Finance and Real Estate from Georgia State University. Mike is a member of the CFA
Institute and the Atlanta CFA Society.
Mike and his wife Kathy are avid cyclists and fitness enthusiasts.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Mike has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Mike is not engaged in any other business activities.
Mike has no other income or compensation to disclose.
Item 6 - Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Mike and
may be reached at (404) 815-5050.
Exhibit A-14
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Lloyd B. Flood, CFA
CRD# 6869285
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Lloyd Flood, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Lloyd is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Lloyd B. Flood (year of birth 1962) joined NHCO in 2017 and serves as a Senior Investment Advisor.
Lloyd has thirty years of experience working as a portfolio manager, trader, and financial analyst. He
has deep knowledge of financial markets, and the importance of asset allocation and due diligence.
Lloyd has been in Atlanta for the entirety of his professional life, spending ten years at Bank
South/Bank of America (1985-1995), and twenty years at ING/Voya (1996-2016). During that time,
he worked in both the public and private asset classes with a primary focus on fixed income. He
managed assets for company accounts and trusts, partnering with clients on the customized mandate
and portfolio construction process. Lloyd has a real insider’s perspective on how Wall Street and the
markets function.
Lloyd was born and raised in the south. He earned a bachelor’s degree in business administration in
finance from Auburn University (1984), a master’s degree in business administration from Mercer
University (1990) and became a CFA charterholder (1997). He is a member of the CFA Institute. Lloyd
also completed the Certified Financial Planner™ practitioner program (2019); however, he no longer
Exhibit A-15
maintains this certification. Lloyd was selected for the ING Business Program in the Netherlands
(2000).
Lloyd’s volunteer activities have been primarily related to his children’s schools starting at the Lovett
School and continuing most recently by serving on the parents’ council at Washington College in
Chestertown, MD. He spends his free time enjoying being with his family in Atlanta, with an
occasional trip to the NC mountains.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
**The CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such
as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
professionals must complete 30 hours of continuing education accepted by CFP Board every two
Item 3 - Disciplinary Information
years.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Lloyd has no such disciplinary
Item 4 - Other Business Activities
information to report.
Lloyd is not engaged in any other business activities.
Item 5 - Additional Compensation
Lloyd has no other income or compensation to disclose.
Item 6 – Supervision
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Lloyd and
may be reached at (404) 815-5050.
Exhibit A-16
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Carey S. Blakley, CFA
®
CRD# 7446075
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Carey Blakley, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Carey is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Carey Blakley (year of birth 1988) is a Senior Manager, Portfolios and Allocations for NHCO. His
responsibilities include general development of the firm’s investment platform with a particular
focus on real estate and public equities, providing oversight and guidance to our client reporting
team, and strategic planning for business initiatives involving technology solutions.
Prior to joining NHCO in 2014, Carey was a full-time student, delivery driver, and construction
contractor.
designation* in 2021.
Carey earned a Bachelor of Business Administration from the Georgia Institute of Technology in
®
2014. He received his Chartered Financial Analyst
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
Exhibit A-17
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
Item 3 - Disciplinary Information
candidate must hold a bachelor’s degree.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Carey has no such disciplinary
information to report.
Item 4 - Other Business Activities
Carey is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 – Supervision
Carey has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Carey and
may be reached at (404) 815-5050.
Exhibit A-18
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Jeffrey S. Buck, CFA
®
CRD# 2239235
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Jeffrey S. Buck, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Jeffrey is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Jeffrey (“Jeff”) S. Buck (year of birth 1966) joined NHCO in 2021 as a Senior Investment Advisor with
responsibilities including client account management and participation in developing the firm’s
investment platform, primarily in private income. Jeff works with clients on investment strategy and
allocation, strategic planning, and cash flow management. Jeff has over 30 years of financial market
experience; providing manager selection, portfolio construction, and asset allocation in close
collaboration with clients and client teams.
Prior to joining Nicholas Hoffman & Company, Jeff was a partner at Diversified Trust Company, a
southeastern based Private Trust Company, for 10 years where he was first an investment generalist
before being promoted to Director of Diversifiers. In 2020, Jeff additionally took over lead of the
firm’s Asset Allocation. Prior to that, Jeff worked at several firms, primarily in the southeast, as a
senior investment team professional, including as lead Portfolio Manager for the hedge fund of funds
at Wilmington Trust Company, and Chief Investment Officer at Homrich Berg in Atlanta.
Exhibit A-19
®
designation* and is a member of the CFA Institute and the CFA Society Atlanta.
Jeff earned a Bachelor of Arts in Economics from Syracuse University. He holds the Chartered
Financial Analyst
In addition to raising their two sons, he and his wife have served as foster parents.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and security
analysis. Before a candidate is eligible to become a CFA charterholder, he/she must meet minimum
experience requirements in the area of investment/financial practice. To enroll in the program, a
candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Jeff has no such disciplinary information
to report.
Item 4 - Other Business Activities
Jeff is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 – Supervision
Jeff has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Jeff and
may be reached at (404) 815-5050.
Exhibit A-20
Brochure Supplement
Form ADV Part 2B
Item 1
Cover Page
-
Nirvanna Silva Novelo, CFP®
CRD# 7888895
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Nirvanna Silva Novelo, and supplements the
Nicholas Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that
Brochure. Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have
any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Nirvanna is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Nirvanna Silva Novelo (year of birth 1994) is a Family Office and Investment Advisor of NHCO with
responsibilities that include account management and financial advice. Nirvanna works with clients
on investment strategy and allocation, strategic planning, and cash flow management. Nirvanna is
also intimately involved in the Family Office division of NHCO, with responsibilities that help develop
our clients’ philanthropic endeavors and property management. Nirvanna has been with NHCO since
May 2016.
Nirvanna was born and raised in Mexico City. She received her undergraduate degree in Business
and Organizational Leadership from Brevard College in 2016 and passed the Series 65 – Uniform
Investment Adviser Law Exam in May 2022. Nirvanna became a Certified Financial Planner™
professional in 2024.*
Exhibit A-21
Nirvanna lives in the Vinings neighborhood of Atlanta. She is an avid tennis player and is fluent in
Spanish.
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
* The CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such
as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
professionals must complete 30 hours of continuing education accepted by CFP Board every two
years.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Nirvanna has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Nirvanna is not engaged in any other business activities.
Item 6 - Supervision
Nirvanna has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Nirvanna
and may be reached at (404) 815-5050.
Exhibit A-22
Brochure Supplement
Form ADV Part 2B
Item 1
Cover Page
-
Aaron F. Jeffries
CRD# 5425987
of
Nicholas Hoffman & Company, LLC
Two Midtown Plaza
1349 West Peachtree Street NW
Suite 1050
Atlanta, Georgia 30309-2929
(404) 815-5050
March 14, 2025
This Brochure Supplement provides information about Aaron Jeffries, and supplements the Nicholas
Hoffman & Company, LLC (“NHCO”) Brochure. You should have received a copy of that Brochure.
Please contact us at (404) 815-5050 if you did not receive NHCO’s Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Aaron is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Aaron Frederick Jeffries (year of birth 1982) is an Investment Advisor for NHCO with responsibilities
including client account management and service. He works with clients on investment
strategy, allocation and planning.
Aaron has 15 years of financial services experience. Prior to joining NHCO in 2025, Aaron worked at
SunTrust Investment Services Private Wealth Management focusing on fixed income and equity-
linked structured products.
He was born and raised in Indianapolis. Aaron moved to Atlanta to attend Emory University where
he graduated with a BA in Economics. In 2011, he completed the Chartered Alternative Investment
Analyst program and became a CAIA® charterholder* but no longer maintains the certificate. Most
recently he spent time as a stay-at-home Dad to his two young children.
*Chartered Alternative Investment Analyst (“CAIA”) – The CAIA Program is designed to facilitate self-
directed learning for today’s busy professionals through a comprehensive set of readings on risk-
Exhibit A-23
return attributes of institutional quality alternative assets. Candidates’ knowledge is assessed
through exams, administered globally at computerized testing centers. The program is organized into
two levels of study; the Level I and Level II exams are offered twice each year, in March and
September, giving candidates the opportunity to earn the CAIA 3 Charter within a single year. CAIA
candidates must pass both Level I and Level II of the CAIA exam to qualify for the CAIA Charter. Once
a qualified candidate completes the CAIA Program, he or she is eligible for CAIA membership.
Professional experience includes full time employment in a professional capacity within the bank
regulatory, banking, financial, or related fields. CAIA Charter Holders must have over one year of
professional experience and a U.S. bachelor’s degree (or equivalent) or four years of professional
experience.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Aaron has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Aaron is not engaged in any other business activities.
Item 6 - Supervision
Aaron has no other income or compensation to disclose.
Among other oversight obligations, the firm monitors the personal securities transactions, business
activities, advisory services, and communications of all its personnel. Staff must review and
acknowledge their adherence to the firm's Code of Ethics and other pertinent policies and guidelines.
As Chief Compliance Officer, Richard Rushton is responsible for compliance supervision of Aaron and
may be reached at (404) 815-5050.
Exhibit A-24