A. Hart & Patterson Financial Group, LLC (the “Adviser,” “we,” “us,” or “our”) is an investment
adviser founded in 1992, registered with the U.S. Securities and Exchange Commission (“SEC”),
and principally owned by Vikki Lenhart.
B. Adviser offers the following types of advisory services:
i.Discretionary Investment Management. Adviser provides ongoing discretionary
investment management services to its clients based upon each client’s current financial
condition, goals, risk tolerance, income, liquidity requirements, investment time horizon,
and other information that is relevant to the management of clients’ account(s). This
information will then be used to make investment decisions that reflect clients’ individual
needs and objectives on an initial and ongoing basis. Adviser’s investment decisions will
allocate portions of clients’ account(s) to various asset classes classified according to
historical and projected risks and rates of return.
In most instances, Adviser uses a third-party investment adviser manager or sub-advisor
(“Third-Party Adviser”) to provide investment management services. When investment
management services are provided, it is on a discretionary basis. This means that the
client’s specific approval of securities transactions in his/her accounts or the selection of
a Third-Party Adviser to manage the account is not required. Because discretion is used
when managing accounts, the client will be asked to complete documentation granting
discretionary authority over their accounts. This authority is given in both Adviser’s
investment management agreement, which outlines the responsibilities of the client and
Adviser, and the account application required by the Third-Party Adviser. Clients may
impose restrictions on investing in certain securities or types of securities so long as such
restrictions may reasonably be implemented by Adviser and the Third-Party Adviser, as
applicable.
Adviser generally implements its investments strategy by allocating clients’ investable
assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange
traded funds (“ETFs”), stocks, bonds, municipal securities, U.S. Government securities,
and money market funds.
ii.Financial Planning. When rendering financial planning services (which may be provided
either in connection with investment management services or as a standalone service),
Adviser will evaluate and make recommendations with respect to various financial
planning topics that are relevant to a particular client. Such topics can include, for
example, retirement planning, education savings, cash flow management, debt reduction,
estate planning, insurance needs, risk mitigation, tax planning, charitable giving
strategies, and/or financial goal tracking. Implementation of Adviser’s recommendations
will be at the discretion of the client.
When rendering financial planning services, a conflict exists between Adviser’s interests
and the interests of its clients; clients are under no obligation to act upon Adviser’s
financial planning recommendations. If a client elects to act on any of the
recommendations made by Adviser, the client is under no obligation to effect the
transaction through Adviser or any of its personnel.
iii.Selection of other investment advisers. As mentioned above, Adviser will usually
recommend or retain a Third-Party Adviser to manage all or a portion of a client’s
portfolio. Third-Party Advisers are evaluated based on a variety of factors,
not the least of
which include performance return history, asset class specialization, management tenure,
and risk profile. Adviser will conduct due diligence as appropriate to confirm that such
Third-Party Advisers are duly registered and otherwise well-equipped to manage such
clients’ accounts. Adviser generally retains the discretionary authority to hire or fire such
Third-Party Advisers with or without notice to the client. As of the date of this brochure,
Adviser generally recommends the utilization of SEI Private Trust Company and SEI
Investments Management Company (collectively referred to as “SEI” along with their
affiliates) as the Third-Party Advisers.
iv.Pension Consulting Services. To the extent Adviser is retained by a pension or profit
sharing plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk
tolerance, and goals, and shall work in partnership with applicable third-parties (such as
the Plan’s recordkeeper, third-party administrator, and/or discretionary investment
manager) to establish an appropriate investment policy statement and deploy applicable
investment options into the Plan’s account. Adviser shall periodically review the
investment options available to the Plan and, if applicable, will make recommendations to
assist the Plan with respect to the selection of the Plan’s qualified default investment
alternative (“QDIA”). Adviser will provide reports, information and recommendations, on a
reasonably requested basis, to assist the Plan in monitoring the selected investments. If
elected by the Plan, Adviser may also provide various services related to the Plan’s
governance, the education of Plan participants, and the review of other service providers
to the Plan. In connection with Plans subject to the Employee Retirement Income
Security Act of 1974 (“ERISA”) and applicable provisions of the Internal Revenue Code of
1986, as amended (the “Code”) Adviser acknowledges that it is a fiduciary under ERISA
and the Code, shall render prudent investment advice that is in Plan’s best interest, shall
avoid making misleading statements, and shall receive no more than reasonable
compensation.
C. Adviser does not participate in any wrap fee programs.
D. 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 (“ERISA”) and/or the Internal Revenue Code (the “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:
i.Meet a professional standard of care when making investment recommendations (give
prudent advice);
ii.Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
iii.Avoid misleading statements about conflicts of interest, fees, and investments;
iv.Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
v.Charge no more than is reasonable for our services; and
vi.Give you basic information about conflicts of interest.
E. Adviser manages the following amount of discretionary and non-discretionary client assets
calculated as of December 31, 2023:
i.Discretionary:$251,373,494
ii.Non-Discretionary:$0
iii.Total:$251,373,494