Keating Investment Counselors, Inc. (“KICI”) is an SEC-registered investment adviser, registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940, as amended. KICI has been providing investment advisory services since 1983 and is based in Delray Beach, Florida. Listed below is the firm's principal shareholder (i.e., those individuals and/or entities controlling 25% or more of this company). For information on the ownership structure, please refer to Form ADV Part 1 on the IARD website. Richard T. Keating, CFA - 100% Owner of Keating Investment Counselors, Inc. KICI offers the following investment advisory services, customized for each individual client: · Portfolio Management Services · Advisory Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each service for information on how we customize our advisory services to meet your individual needs. In this brochure, the words “we,” “our,” and “us” refer to Keating Investment Counselors, Inc., and the words “you,” “your,” and “client” refer to you as either a client or as a prospective client. Additionally, the term “Associated Person” refers to our firm’s officers, employees, and all individuals providing investment advice on behalf of our firm. Keating Active ETF Keating Investment Counselors serves as a sub adviser to the Keating Active ETF. This includes providing trade direction/signals, marketing, and distributing the ETF. Richard Keating and Pablo Cavanagh are co-managers of the Keating Active ETF. The ETF is managed under the EA Series Trust operated by ETF Architect. Further, ETF Architect provides trading, execution, and various other administrative services. These include implementing and testing procedures for the ETF including compliance (example ensuring the ETF meets diversification requirements), operational (example exchange listing), cybersecurity, portfolio risk management, and anti-money laundering related to transactions with Authorized Participants. INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Keating Investment Counselors provides continuous portfolio management services with investment advice custom tailored to meet the needs and investment objectives of the client. We offer investment advisory services on both a discretionary and non-discretionary basis. Services offered on a discretionary basis mean you will provide us with written authority to trade your account without contacting you before making investments.

Services offered on a non-discretionary basis require us to obtain your approval before executing our recommendations, and you make the ultimate decision regarding the purchase or sale of investments. Once the portfolio is constructed, Keating provides continuous supervision and rebalancing of the portfolio considering changes in market conditions and client circumstances as needed. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's documented investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual goals, time horizons, risk tolerance, tax considerations, and liquidity needs. As appropriate, we also review and discuss a client's investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: 1. Exchange-listed securities 2. Securities traded over the counter 3. Corporate debt securities (other than commercial paper) 4. Commercial paper 5. Certificates of deposit 6. Municipal securities 7. Mutual fund shares 8. United States governmental securities 9. Warrants Additionally, KICI reserves the right to advise clients on any other type of investment that it deems appropriate based on the client’s stated investment goals and objectives. KICI can also provide advice on any type of investment held in a client’s portfolio at the inception of the advisory relationship or on any investment for which the client requests advice. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Please refer to more detail on risk in Item 8 of this brochure. ASSETS UNDER MANAGEMENT As of 12/31/2023, KICI managed $ 353,140,545 Assets under Management on a discretionary basis and $4,324,866 Assets under Management on a non-discretionary basis. The Total Assets under Management as of 12/31/2023 are $357,465,411 The Total Assets under Advisement as of 12/31/2023 are $6,743,207.