A. Firm Information
DHK Financial Advisors Inc. (“DHK” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Sub-S Corporation under the laws of the State of
New Hampshire. DHK was founded in June 1993 and is owned and operated by Timothy W. Dempsey
(Principal, Director, and Chief Compliance Officer). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by DHK.
B. Advisory Services Offered
DHK offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to
mitigate potential conflicts of interest. The Advisor’s fiduciary commitment is further described in the Advisor’s
Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
Investment Management Services
DHK provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services. DHK works closely with each Client to identify their investment
goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. DHK
will then construct an investment portfolio consisting of low-cost, diversified mutual funds and/or exchange-
traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks,
bonds, or options contracts, and alternative investments as appropriate to meet the needs of its Clients. The
Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations.
DHK’s investment approach is primarily long-term focused, but the Advisor may buy, sell, or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. DHK will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance
by the Advisor.
DHK evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. DHK may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. DHK may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement. DHK may recommend
selling positions for reasons that include but are not limited to harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, changes in the risk tolerance of the Client, generating cash to meet the Client’s needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution
from an ERISA retirement account or to roll over
the assets to an IRA or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor earns a new
(or increases its current) advisory fee as a result of the transaction. No client is under any obligation to roll over
a retirement account to an account managed by the Advisor.
At no time will DHK accept or maintain custody of a Client’s funds or securities, except for the limited authority
as outlined in Item 15 - Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Use of Independent Managers
DHK will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s
needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each
Independent Manager to ensure the strategy remains aligned with Clients’ investment objectives and overall
best interests. The Advisor will also assist the Client in the development of the initial policy recommendations
and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form
ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Retirement Plan Advisory Services
DHK provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
● Vendor Analysis
● Investment Oversight Services (ERISA 3(21))
● Performance Reporting
These services are provided by DHK serving in the capacity of a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of DHK’s fiduciary status, the specific services to be rendered,
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging DHK to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and
the Client. These services may include:
● Establishing an Investment Strategy – DHK, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
● Asset Allocation – DHK will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation, and tolerance for risk for each Client.
● Portfolio Construction – DHK will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
● Investment Management and Supervision – DHK will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
DHK does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by DHK.
E. Assets Under Management
As of December 31, 2023, DHK manages $1,514,041,032 in Client assets, $687,280,487 of which are managed
on a discretionary basis and $826,760,545 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.