Description of Services and Fees Hughes Warren, Inc. is a registered investment adviser based in Edmond, Oklahoma. We are organized as a corporation under the laws of the State of Oklahoma. We have been providing investment advisory services since 2007. Theodore J. Hughes is our principal owner. Currently, we offer Wealth Planning Services personalized to each individual client.
We are a "fee-only" investment advisory firm. The definition of "fee-only" as defined by the Certified Financial Planner Board of Standards is as follows: "Fee-only denotes a method of compensation in which compensation is received solely from a client with neither the personal financial planning practitioner nor any related party receiving compensation which is contingent upon the purchase or sale of any financial product". We do not sell any financial products.
The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Hughes Warren, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Wealth Planning Services We offer Wealth Planning Services by incorporating financial planning, investment portfolio management, and other aggregated financial services. The combination of industry experience and comprehensive research allows our firm to provide quality advisory services to our clients.
The financial planning areas which may be addressed with each of our clients include, but are not limited to, cash flow, tax analysis and planning, insurance analysis and planning, employee benefit analysis and/or planning, business ownership issues, education planning, estate planning, and retirement planning as well as budgeting and net worth and investment analysis and planning. Investment analysis and planning may include, but is not limited to, reviews of current holdings, risk tolerance, asset allocation, historical performance, retirement projections and tax analysis. We will not provide a written report.
Our Wealth Planning Services include discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information at the beginning of our advisory relationship. We will use the information we gather to develop an Investment Policy Statement ("IPS") that communicates the investment philosophy, guidelines and constraints to be adhered to. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for

your account without your approval prior to each transaction. Discretionary authority is typically granted by 5 the investment advisory agreement you sign with our firm, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
Sub-Advisory Services As part of our portfolio management services, we may use a sub-adviser to manage a portion of your account on a discretionary basis. Using model portfolios created by Hughes Warren, the sub- adviser will provide tax-efficient strategy and tax-loss harvesting recommendations. We will regularly monitor the performance of your accounts managed by the sub-adviser, and maintain discretion to hire and fire the sub-adviser. The advisory fees you pay are not increased because we use these services. These services allow us to provide our clients with operational and advisory efficiencies which may create a conflict of interest since the models can use mutual funds and exchange-traded funds affiliated with the service provider. It is possible that there are other mutual funds and exchange- traded funds not included in these models that may be in our clients' best interest. In all cases we strive to recommend only products and services that we believe are in your best interest.
Types of Investments We primarily offer advice on mutual funds and exchange-traded funds.
Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:  Meet a professional standard of care when making investment recommendations (give prudent advice);  Never put our financial interests ahead of yours when making recommendations (give loyal advice);  Avoid misleading statements about conflicts of interest, fees, and investments;  Follow policies and procedures designed to ensure that we give advice that is in your best interest;  Charge no more than is reasonable for our services; and  Give you basic information about conflicts of interest. 6 We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2022, we provide continuous management services for $131,360,826 in client assets on a discretionary basis.