4. A. Advisory Firm Description
Hillman Capital Management, Inc. (“HCM”) was established in 1998. Mark A. Hillman
(Principal Owner, Chief Executive Officer and Chief Investment Officer) founded HCM,
bringing into the firm the assets of predecessor companies he established in the early 1990s,
Custom Asset Management and Menocal Capital Management, where he was the Chief
Investment Officer. HCM’s principal owners are Mark A. Hillman and his spouse, Melba B.
Quizon.
HCM first located in Annapolis, Maryland and, due to growth, moved to Bethesda, Maryland
in April, 2005. The mutual fund, The Hillman Value Fund (“Mutual Fund”), was formed in
2000.
4. B. Types of Advisory Services
HCM provides discretionary and non-discretionary investment advisory services to
separately managed accounts, and a mutual fund. HCM also serves as a discretionary
portfolio manager to clients participating in wrap fee, sub-advisory or “dual contract”
programs. (i.e., programs in which the client enters into contractual relationships with both
HCM and an intermediary).
Our portfolio strategies may include investments in common stocks, preferred stocks,
options, investment-grade and non-investment grade corporate bonds, U.S. Government and
agency securities, convertible securities (including stocks and convertible corporate bonds),
real estate investment trusts, and investment companies.
HCM may provide non-discretionary investment advisory services to certain third parties
such as investment advisers, broker-dealers, account managers and fiduciaries, in the form
of “model portfolios.” A “model portfolio” represents HCM’s recommendations as to the
composition of a portfolio of securities. HCM only provides the recommendations to these
other entities listed above and does not manage those portfolios directly. HCM does not have
any contact with the underlying client using a model portfolio. HCM is currently a model
provider for the following model platforms: Envestnet, SMArtX and Adhesion. These assets
are not included in our Regulatory Assets Under Management.
HCM’s investment advice is limited to these types of investment advisory services.
Retirement Plan Rollovers – No Obligation / Conflict of Interest
A client or prospective client leaving an employer has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in
the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan,
if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement
Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s
age, result in adverse tax consequences). If HCM recommends that a client roll over their
retirement plan assets into an account to be managed by HCM, such a recommendation
creates a conflict of interest if HCM will earn new
(or increases its current) compensation as
a result of the rollover. No client is under any obligation to roll over retirement plan assets
to an account managed by HCM.
4. C. Client Investment Objectives/Restrictions
Investments for separately managed client accounts (including wrap fee, dual contract and
sub-advisory accounts) are managed in accordance with each client’s stated investment
objectives, strategies restrictions and guidelines. Investments for the Mutual Fund are
managed in accordance with its investment objective, strategies and restrictions and are not
tailored to the individualized needs of any particular investor in the Mutual Fund.
4. D. Wrap-Fee Programs
HCM participates as a portfolio manager in certain wrap fee programs. In most wrap fee
programs, the sponsor is responsible for establishing the financial circumstances,
investment objectives and investment restrictions of each wrap fee client through a client
profile, questionnaire and/or investment policy statement (“Profile”) as well as
consultations with the sponsor’s personnel. Each client completes a Profile and enters into
a wrap fee agreement with the sponsor. Generally, wrap fee program sponsors are
responsible for providing wrap fee clients both the sponsor’s own wrap fee brochure or
Appendix 1 (“Wrap Brochure”) as well as the brochure for each discretionary manager used
by the wrap fee clients.
HCM receives a portion of the wrap fee from the sponsor as an investment advisor to these
programs. In these relationships, we do not have direct contact with the underlying client,
as we do with our direct accounts. We attempt to manage these accounts in the same manner
as our non-wrap accounts.
Wrap fee clients should review the sponsor’s Wrap Brochure for further details about the
relevant wrap fee program. Wrap fee clients should consider that, depending on the rate of
the wrap fee charged, the amount of account activity, the value of custodial and other
services provided and other factors, the wrap fee may exceed the aggregate costs of the
services provided if they were to be obtained separately and, with respect to brokerage,
transaction-based commissions. As a general matter, HCM is not responsible for, and does
not attempt to determine, whether, a particular wrap fee program is suitable or advisable
for any given wrap fee client. HCM will only determine whether each wrap fee account
referred to HCM is reasonably appropriate for discretionary management by HCM based on
the wrap fee client’s Profile, as provided by the program sponsor. HCM may accept or reject
a wrap fee client for any reason, including, but not limited to, the wrap fee client’s investment
goals and restrictions.
4. E. Client Assets as of 12/31/2023:
Assets Under Management:
Discretionary basis: $ 329,384,822; 178 accounts
Non-Discretionary basis: None
Assets Under Advisement: $ $332,585,732; 2,452 accounts