This document, offered by Hub Investment Advisors (“HIA”), discloses information about the investment advisory services we provide and the manner in which we provide them to you, the client. We are a fee-based investment management and financial planning firm located in Omaha, Nebraska, specializing in proactive investment advisory and planning services for investors and retirement plans. HIA was established in 2004 and became registered as an investment adviser in 2012. HIA was established by SilverStone Holdings, Incorporated, and was previously known as Silverstone Asset Management, Inc. HIA was purchased by HUB International Limited in 2019. Silverstone Asset Management changed its name to HIA in March 2021. We are committed to help build, manage, and to provide assistance to clients to help achieve their stated financial goals. We may offer an initial complimentary meeting; however, investment advisory services are initiated only after you execute a client agreement with us. Asset Management Services We offer asset management services, which involve providing you with continuous and ongoing supervision over your specified accounts. In order to receive our asset management services, you must appoint HIA as the investment adviser of record on the specified accounts that will receive our asset management services (collectively hereafter referred to as your “Account”). Your Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of your Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You have the ability to impose reasonable restrictions on the management of your Account, including the ability to instruct us not to purchase certain securities. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell, or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. When recommending that a client rollover his or her account from current retirement plan to an IRA, HIA and its investment adviser representatives have a conflict of interest. HIA and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA; however, HIA and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds in the retirement plan (unless a client retained HIA to provide advice about the client’s retirement plan account or the retirement plan has retained HIA to provide advice at the plan level). Thus, HIA and its investment adviser representatives have an economic incentive to recommend a rollover of the retirement plan account, which is a conflict of interest. HIA has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA. HIA and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in HIA receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by HIA and its supervised persons and any material conflicts of interest related to HIA recommending the rollover of funds from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. HIA will not recommend or make a decision to purchase inverse or leveraged ETFs in a client’s account when providing a client with investment advisory services. Clients may direct HIA to implement trades involving inverse or leveraged ETFs on their behalf, however HIA will not actively manage or monitor these assets. 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. Financial Planning Services We offer financial planning services, which involve preparing a written financial plan, covering specific or multiple topics. Our financial planning services may include analysis of your situation and assistance in identifying and implementing appropriate techniques to help you meet your specific financial objectives. Such services may include a written financial analysis and specific or general investment and/or planning recommendations. We provide written financial plans, which typically address any or all of the six areas of financial planning established by the National Endowment for Financial Education and endorsed by the Certified Financial Planner Board of Standards. These include: 1) financial position; 2) protection planning; 3) investment planning; 4) income tax planning; 5) retirement planning; and 6) estate planning. Other services that may be covered in the written financial plan include:
• Appropriate income strategies for both pre- and post-retirement;
• Review of existing and proposed asset allocation in light of your objectives. This would include a review of risk/return issues and a suggested plan of action consistent with the same;
• Calculation of your pre-retirement savings and investing needs;
• Assessment of your overall financial position including net worth, cash flow, and debt; e) analysis of IRA-related issues including rollover, distribution, and inheritance planning options;
• Evaluation of strategies designed to maximize the utilization and protection of your IRA assets;
• Overview and recommendations regarding estate planning issues;
• Review and determination of your life insurance needs;
• Suggestions for minimizing your federal and state income tax obligations; and
• Development of investment strategies consistent with your business ownership succession and transition planning. Consulting Services We offer consultations in order to discuss financial planning issues when you do not need a written financial plan. Consulting services may be appropriate if you are seeking limited advice on one or more isolated areas of concern such as estate planning, real estate, retirement planning, insurance, annuities, non-securities matters, or any other specific topic. We offer one-time consultations for the purpose of addressing a specific area or areas of concern related to investments or financial planning. We offer as-needed consultations, which are provided in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice. In providing consulting services, we may provide portfolio review and advice for assets that are not part of our discretionary asset management services. Any portfolio review provided as part of our consulting services will be limited to a one-time or periodic review based on information provided to us by you. General Disclosures Regarding Financial Planning and Consulting Services When providing financial planning and consulting services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. There are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a written financial plan. Written financial plans prepared by us do not typically include specific recommendations of individual securities. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through HIA or retain HIA to actively monitor and manage your investments, you must execute a separate written agreement with HIA for our asset management services. Retirement Plan Services We offer retirement plan services to retirement plan sponsors and to individual participants in retirement plans. Our retirement plan services are offered to ERISA plans and non-ERISA plans and to certain non-qualified retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to the services described below. The following services may be provided to both ERISA and non-ERISA retirement plans. When provided to ERISA plans, these services are considered fiduciary services. The exact services provided to a client will be indicated in the Retirement Plan Services Agreement. We provide the following Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. We will help you develop an investment policy statement. The investment policy statement establishes the

investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. We will provide you with general, non-discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement. We will not have investment discretion nor any authority to add or remove investment options or trade securities of the Plan. Client will determine whether or not to implement HIA’s advice. You will have the sole responsibility for the implementation of any of our advice.
• Investment Selection Services. We will provide you with recommendations of investment options for the retirement plan. If specified in your contract for retirement plan services, we may provide recommendations for the retirement plan that are intended to be consistent with ERISA section 404(c).
• Investment Due Diligence Review. We will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. We will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund 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.
• Default Investment Alternative Advice. We will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5).
• Individualized Participant Advice. Upon request, we will provide one-on-one advice to Plan participants regarding their individual situations. For the Retirement Plan Consulting Services described above, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. The retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Retirement Plan Consulting Services are not management services, and we do not serve as administrator or trustee of the retirement plan. We do not act as custodian for any client account or have access to client funds or securities (with the exception of, for some accounts, having written authorization from the client to deduct our fees). If the Retirement Plan Consulting Services are provided to a retirement plan that is governed by ERISA, then HIA acknowledges that in performing the Retirement Plan Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. HIA will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause HIA to be a fiduciary as a matter of law. However, in providing the Retirement Plan Consulting Services, HIA (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of a client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of a client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of a client’s retirement plan or the interpretation of a client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of a client’s retirement plan as defined in ERISA. Fiduciary Management Services HIA provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. HIA will provide you with continuous and ongoing supervision over the designated retirement plan assets. HIA will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. HIA will monitor the investment options of the Plan and add or remove investment options for the Plan. HIA will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants.
• Default Investment Alternative Management. HIA will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. If you elect to utilize any of Advisor’s Fiduciary Management Services, then HIA will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and HIA hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Other Advisory Services to Retirement Plans We also provide the following other services to retirement plans: The services described below are not considered fiduciary services for the purposes of ERISA but are considered fiduciary services under the Investment Adviser Act of 1940. Basically, this means that for the services below we are considered a fiduciary under the Advisers Act and required to meet the fiduciary duties as defined by the Advisers Act, but are not considered fiduciary for the purposes of ERISA as defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to a client will be indicated in the Qualified Retirement Plan Agreement.
• Participant Education. We will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Our assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. We will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Qualified Plan Development. We will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we will assist you with the review and selection of a Third Party Administrator for the Plan.
• Due Diligence Review. We will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers.
• Benchmarking. We will provide you benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. We strive to render our best judgment for clients. Still, we cannot assure that investments will be profitable or assure that no losses will occur in client portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. To the extent that it is required by ERISA Regulation Section 2550.408b-2(c), we will disclose to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Retirement Plan Services Agreement and any compensation or fees received in connection with that Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Tailored Advisory Services to Individual Needs of Clients Our advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. No Wrap Fee Programs We do not participate in wrap fees programs in our portfolio services. Client Assets Under Management HIA provides investment advisory and management services to clients. As of December 31, 2023, HIA reflects $1,511,396,033 in assets under advisement. This includes approximately $1,221,391,602 in nondiscretionary institutional assets under advisement, primarily comprised of ERISA qualified retirement plans where HIA acts as a 3(21) fiduciary, as well as $290,004,431 in total Wealth Client assets under management.