Description of Advisory Firm
Key Financial, Inc. (hereinafter referred to as the “Advisor” or “KFI”) is registered as an
Investment Adviser with the Securities and Exchange Commission. KFI was formed in March of
1997 and Patricia (also referred to as “Patti”) Clark Brennan (CRD Number 1454607) is the one
hundred percent (100%) equity owner. Mrs. Brennan also acts as the firm’s CEO, and Chief
Compliance Officer. The Advisor is not publicly owned or traded. There are no indirect owners
of the Advisor or intermediaries that have any ownership interest in the Advisor. The Advisor
provides investment management services on a continuous and ongoing basis. Client cases are
managed on an individualized basis and services are tailored to meet clients’ specified needs,
goals, and objectives. Clients may impose restrictions on their accounts. The Advisor does not
sponsor any wrap programs.
As of December 31, 2023, KFI manages $ 1,894,480,054 on a discretionary basis and
$271,711,514 on a non-discretionary basis.
Types of Advisory Services
Principal Business:
Advisor believes financial decisions should be based on the client’s desired financial outcomes
with portfolio management and the deployment of financial resources serving the overall goals
of each client. Therefore, KFI’s principal business purpose is to provide comprehensive financial
planning services and investment recommendations that are intended to adhere closely to the
client’s stated goals and objectives. In certain instances, advice regarding investments and asset
allocation as deemed appropriate may be provided without comprehensive financial planning.
Estate planning may be done on a modular basis with retirement cash flow analysis in order to
help determine the probability of a client maintaining their lifestyles and standards of living in
retirement. KFI manages client accounts on a discretionary or non-discretionary basis according
to the client’s preference (as designated in the client’s advisory agreement). For accounts
managed on a discretionary basis, the Advisor is authorized to implement recommendations
and effect investment transactions related to the assets in clients’ Account(s). Clients authorize
the Advisor, without prior consultation, consent, or approval to give instructions regarding the
amount of securities to be bought or sold and/or the timing of such transactions to the
custodian to implement securities transactions on behalf of clients. This authority does not
extend to the withdraw or transfer of funds from clients’ account(s).
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 5
For accounts managed on a non-discretionary basis, the Advisor may provide periodic
recommendations to clients and if such recommendations are approved/authorized, the
Advisor will make the authorized transaction for the clients’ accounts. See Non-Discretionary
Service Limitations below.
As previously mentioned, KFI does not believe clients should prepay for services and has
adopted a policy of billing in arrears. As such, fees are due and payable on the first business day
of each calendar quarter based on the value of the client's account on the last business day of
the previous calendar quarter. Advisor may choose to “grandfather” existing clients and bill
them according to previously agreed upon fee schedules. Clients are directed to Item 12
(below) for a discussion of the Advisor’s brokerage practices.
Comprehensive Financial Planning Services (Phase One – Initial Financial Plan):
KFI, through its Investment Adviser Representatives, meets with prospective clients to explore
basic points of personal and/or business financial planning. There is no charge for this initial
consultation. Once the Advisor has been engaged to prepare an Initial Financial Plan, under the
terms of the Phase One Agreement, the client is required to complete a Financial Planning
Questionnaire and provide necessary or requested documents to aid in the development of the
financial plan. Once the relevant information is received, the Advisor evaluates client’s asset
allocation, securities, income taxes, estate planning, retirement planning, personal investments,
insurance, financing options, cash flow, company benefits, and any other financial aspects
applicable to the services of the Financial Planning Agreement.
After the financial plan has been developed and stress tested, a follow-up meeting is scheduled
where the written financial plan is delivered. The written financial plan generally includes an
overview of the planning assumptions, an analysis of the clients’ projected long-term cash flow,
and the potential impact of current strategies on the clients’ financial circumstances. In many
cases, alternative planning scenarios may be presented to offer potential solutions to allow
clients to achieve their stated goals and objectives. The financial plan and all assumptions are
carefully reviewed for accuracy with the client, and it is clearly communicated that the client is
under no obligation to implement any of the recommendations through the Advisor or the firm.
If the client is satisfied and agrees to the proposed recommendations of the Initial Financial
Plan, the client may proceed to an ongoing Financial Planning and Asset Monitoring (“Phase
Two”) relationship with the Advisor. If a Phase Two Agreement is signed, the Advisor will
implement the recommendations approved by the client.
Recommendations can be made for retail accounts or advisory accounts (subject to the client’s
preference), and Advisor shall disclose whether the Advisor will be compensated on the basis of
asset-based fees (earned by KFI) or whether commissions will be earned (earned by the KFI
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 6
representative in his/her separate individual capacity as a registered representative of Osaic
Wealth-see below). If the client does not choose to proceed to Phase Two, no ongoing
planning or asset monitoring will be provided, and the client is solely responsible for the (1)
decision to implement, and (2) the act of implementation for any of the recommendations that
the client deems to be appropriate. Access to staff and online portals will cease according to
the terms of the Phase One Agreement.
Comprehensive and modular planning may include the following services as requested by the
client and deemed appropriate by the Advisor:
Services & Fees
SCHEDULE A
Services to be performed by the Planner for the Client can include (Check those that apply):
Include
1. Goal Setting ________
2. Cash Flow Projections ________
3. Net Worth Statement ________
4. Retirement
Needs analysis and retirement income projections ________
Asset Projections ________
Monte Carlo Analysis (Probability of Success Back test) ________
5. Risk Capacity Analysis ________
6. Review of Current Portfolio
Review of Current Asset Allocation and investments ________
Specific Allocation and Investment Recommendations ________
Proposed Portfolio ________
6. Insurance
Life Insurance Analysis ________
Disability Analysis ________
Long Term Care Analysis ________
7. Income Tax Projections, Analysis and Planning ________
8. Estate Planning ________
9. Education Needs and Funding Analysis ________
10. Other Services (as needed) ________
Clients should be mindful that the value and usefulness of financial planning services of the
Advisor will be dependent upon accuracy and timeliness of information provided, and upon the
client’s active participation in the formulation of financial planning objectives and
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 7
implementation of plans to attain those objectives. The client will provide copies of insurance
policies, wills, tax returns, and other documents and information as the Advisor may reasonably
request to permit complete evaluation and prepare planning and investment recommendations
to the client.
KFI recognizes that the value of any financial plan goes beyond the written plan and involves
carefully monitoring clients’ progress toward their financial goals and objectives. Without this,
a static plan can become obsolete as changes in a client’s financial situation, the economy, tax
laws, and markets can have a significant impact on the success of the Initial Financial
Plan. Further, recommendations made based on these factors may cause any Phase One
recommendations to become less appropriate, outdated, or no longer advisable. As such, KFI’s
investment advisory structure is designed to align the firm’s interests with the best interests of
the client.
Ongoing Financial Planning & Asset Management (Phase Two – Advisory Services):
If subsequently engaged to do so, the Advisor will monitor the clients’ financial plan and furnish
periodic updates recommendations (as needed) regarding the allocation of present financial
resources among different types of assets (including investments, savings, and life insurance). If
a comprehensive financial plan has not been prepared, the clients can request these services at
any time, generally for a separate initial planning fee. These services will be performed with
the intent to better correlate the investment strategies and deployment of assets with the
clients’ financial planning objectives. Clients may continue to utilize the Advisor in an
investment program of Asset Allocation and to monitor clients’ objectives, risk tolerance, and
financial constraints.
In order to manage clients’ portfolios as an element of the ongoing financial planning services,
the Advisor will offer Key Advisory Services Accounts (“KAS Accounts”), which are accounts that
authorize the Advisor to purchase no-load mutual funds, load-waived funds, and other equity,
ETF's, debt, and option securities on behalf of the clients. No initial sales charges or
commissions will be assessed in these accounts, nor will the Advisor charge any amount over
and above the minimum broker-dealer commission and clearing charges. As such, in addition to
the quarterly account fees described below, clients generally could also be required to pay
separate per-trade transaction charges. Please see the client agreement for a complete list of
transaction charges. Neither the Advisor, nor any of its representatives, will receive any portion
of the transaction charges for KAS advisory accounts. The Advisor will request the relevant
financial data from clients and assist in the selection of appropriate investments. The
investment strategy will be tailored to the specific needs of each client and will depend on each
client’s financial goals and individual or personal/family situation. For the avoidance of doubt,
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 8
the client retains the opportunity to place reasonable restrictions on investments held within
their KAS Account, and if applicable, the client should promptly notify the Advisor by providing
such restrictions in writing.
Please Note: Planning Limitations. Advisor believes that it is important for the client to address
financial planning issues on an ongoing basis. Advisor’s advisory fee, as set forth at Item 5
below, will remain the same regardless of whether or not the client determines to address
financial planning issues with the Advisor. It remains each client’s responsibility to promptly
notify Advisor if there is ever any change in his/her/its financial situation or investment
objectives for the purpose of reviewing/evaluating/revising our previous recommendations
and/or services.
Alternative Advisory Service Arrangements
Advisor Managed Accounts (Key Investment Clients (KIC)/ Investment Only Service) – While
the Advisor believes that every client can benefit from a financial plan, from time to time,
clients may decide that comprehensive financial planning services are not necessary given their
financial situation or preference. Under such circumstances, clients may choose to engage the
Advisor for discretionary asset management services that do not include comprehensive
financial planning services. These clients will be billed according to the KAS Account fee
schedule as the Advisor does charge a separate fee for Phase One financial planning services.
Outside Accounts - Asset allocation selection and portfolio monitoring services may be provided
for clients with external pension, profit sharing, 401k, 403b, mutual fund or brokerage accounts
held at custodians or broker-dealers outside of the Advisor's broker-dealer, as part of the
financial planning advisory services. Aggregation of outside accounts into clients’ personal
website (eMoney) is an accommodation, and advisor takes no responsibility to ensure outside
accounts are connected, aggregating properly, or being updated in clients’ financial plans. For
the avoidance of doubt, continuous management and ongoing performance reporting will not be
provided for outside accounts. Since data feeds come directly from the Advisor’s Custodian,
ongoing monitoring, continuous management, and performance reporting will only be provided
for assets under custody of Osaic Wealth or its clearing firm, Pershing LLC. Neither KFI, nor any
of its representatives, maintain passwords from clients/ pension, profit sharing, 401k, 403b,
mutual fund or brokerage accounts held at broker-dealers/custodians other than Osaic Wealth
and Pershing.
Grandfathered Retail Accounts - Clients who engaged the Advisor for services prior to the
availability of discretionary asset management services (KAS Accounts) are grandfathered under
the Advisor’s previous asset-based fee structure of one-third of one percent (0.333%) of assets
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 9
under management for financial planning and asset monitoring. Recommendations are made
on a periodic basis. This program is not available to new clients, except for new clients related
to an existing grandfathered retail account client
Grandfathered Converted KAS Accounts –Grandfathered Retail Account clients who desire
access to institutional pricing, discretionary investment services, and continuous and ongoing
management of client portfolios can choose to convert to a KAS Account. Clients who take
advantage of this account conversion will receive the grandfathered advisory fee rate of sixty-
five basis points Grandfathered Third-Party Managed Accounts - In certain circumstances the
Advisor may utilize the services of RTD Financial Advisors (“RTD”) serving as a third-party
money manager. RTD utilizes Charles Schwab (“Schwab”) as the broker-dealer firm. In general,
the minimum account size is $250,000. The Advisor provides recommendations regarding asset
allocation which is the process of selecting a mix of asset allocation of capital to those assets
based on the client's objectives, risk tolerance, and time constraints.
Quarterly status and repositioning reports are provided by RTD. As part of KFI’s agreement with
RTD, the Advisor will be compensated sixty-five percent (65%) of advisory fees collected from
clients that pertain to services rendered pursuant to this agreement.
Assets Held or Managed Away: As part of an initial financial planning analysis and engagement,
the Advisor will assist clients in determining their investment goals and objectives, risk
tolerance, and retirement plan investment time horizon(s). The Advisor will then recommend
an initial asset allocation. However, if such assets are custodied outside of the control and
oversight of the Advisor or Advisor’s broker-dealer (Osaic Wealth , Inc.) or custodian (Pershing
LLC), the client is responsible for the implementation of the Advisor’s recommendations and
ongoing monitoring of asset allocation and performance.
Termination - Clients can terminate their relationship with the Advisor by providing written
notice in accordance with the terms of their signed agreement. KFI bills for ongoing financial
planning and asset monitoring services in arrears so issues related to the refunding of prepaid
fees generally do not apply. If an extraordinary circumstance involving the termination of
services after a prepayment, the client would then receive, where applicable, a prorated refund
of any prepaid advisory fees. Such prorated refund will be based upon actual services and
termination costs incurred up to and at the time of termination of the Advisor’s services.
Educational Seminars - KFI offers free financial education seminars as a means of introducing
the knowledge, expertise, and services of the Advisor to the public. The Advisor also hosts
client appreciation events and meetings from time to time. Mutual fund companies and
annuity companies may participate in covering the costs associated with these events and
seminars. Such participation presents a potential conflict of interest. However, the client’s best
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 10
interest shall always be placed ahead of the interests of the Advisor and/or its associated
persons.
Trust Services - KFI participates in Pershing’s Trust Network and may recommend clients who
need personal trust services to certain corporate trustees in the Trust Network. If a client
employs a corporate trustee, neither KFI, nor its associated persons, receive compensation
from the corporate trustee. All fees paid to the corporate trustee for services performed are
separate from, and in addition to, fees paid to KFI for financial planning and advisory services
performed. Clients are under no obligation to use any recommended corporate trustee(s) for
personal trust services.
Miscellaneous - Limitations of Financial Planning and Non-Investment
Consulting/Implementation Services. Subsequent to completion of Phase One, as engaged by
the client, KFI will generally provide financial planning and related consulting
services regarding
non-investment related matters, such as tax and estate planning, insurance, etc., inclusive of its
advisory fee set forth at Item 5 below (exceptions could occur based upon assets under
management, special projects, extraordinary events, stand-alone planning engagements, etc.
for which Advisor may charge a separate or additional fee). Please Note: KFI believes that it is
important for the client to address financial planning issues on an ongoing basis. KFI’s advisory
fee, as set forth in Item 5 below, will remain the same regardless of whether or not the client
determines to address financial planning issues with KFI. Please Also Note: KFI does not serve
as an attorney, accountant, or insurance agent, and no portion of our services should be
construed as same. Accordingly, KFI does not prepare legal documents, prepare tax returns, or
sell insurance products. To the extent requested by a client, we may recommend the services of
other professionals for non-investment implementation purpose (i.e. attorneys, accountants,
insurance, etc.), including some KFI representatives in their separate individual capacities as
Registered Representatives of Osaic Wealth, Inc. (“Osaic Wealth”), an SEC registered and FINRA
member broker-dealer, and as licensed insurance agents. See Item 10 below. The client is under
no obligation to engage the services of any such recommended professional. The client retains
absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from KFI and/or its representatives. If the client engages any recommended
unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client
agrees to seek recourse exclusively from and against the engaged professional. At all times, the
engaged licensed professional[s] (i.e. attorney, accountant, insurance agent, etc.), and not KFI,
shall be responsible for the quality and competency of the services provided. Please Further
Note - Conflict of Interest: The recommendation by a KFI representative that a client purchase a
securities or insurance commission product from a KFI representative in his/her individual
capacity as a representative of Osaic Wealth and/or as an insurance agent, presents a conflict
of interest, as the receipt of commissions may provide an incentive to recommend investment
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 11
and/or insurance products based on commissions to be received, rather than on a particular
client’s need. No client is under any obligation to purchase any securities or insurance
commission products from a KFI representative. Clients are reminded that they may purchase
securities and insurance products recommended by a KFI representative through other, non-
affiliated broker-dealers and/or insurance agents.
questions that a client or prospective client may have regarding the above conflicts of interest.
Please Note: Retirement Rollovers - Potential for Conflict of Interest: A client or prospective
client leaving an employer typically 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 KFI recommends that a client roll over their retirement plan assets into an
account to be managed by KFI, such a recommendation creates a conflict of interest if KFI will
earn new (or increase its current) compensation as a result of the rollover. If KFI provides a
recommendation as to whether a client should engage in a rollover or not (whether it is from
an employer’s plan or an existing IRA), KFI is acting as a fiduciary 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. No client is under any obligation to roll over
retirement plan assets to an account managed by KFI, whether it is from an employer’s plan or
an existing IRA. KFI’s Chief Compliance Officer, Patti Brennan, remains available to address any
questions that a client or prospective client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Portfolio Activity - KFI has a fiduciary duty to provide services consistent with the client’s best
interest. If engaged for ongoing management (referred to as Phase 2) KFI will review client
portfolios on an ongoing basis to determine if any changes are necessary based upon various
factors, including, but not limited to, investment performance, market conditions, fund
manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time when
KFI determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients
remain subject to the fees described in Item 5 below during periods of account inactivity.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from account
transactions or cash deposits be swept into and/or initially maintained in the custodian’s sweep
account. The yield on the sweep account is generally lower than those available in money
market accounts. To help mitigate this issue, Advisor shall generally purchase a higher yielding
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 12
money market fund available on the custodian’s platform with cash proceeds or deposits,
unless Advisor reasonably anticipates that it will utilize the cash proceeds during the
subsequent 30-day period to purchase additional investments for the client’s account.
Exceptions and/or modifications can and will occur with respect to all or a portion of the cash
balances for various reasons, including, but not limited to, the amount of dispersion between
the sweep account and a money market fund, the size of the cash balance, an indication from
the client of an imminent need for such cash, or the client has a demonstrated history of
writing checks from the account.
Please Note: The above does not apply to the cash component maintained within the Advisors’
actively managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access to
such cash, assets allocated to an unaffiliated investment manager, and cash balances
maintained for fee billing purposes. Please Also Note: The client shall remain exclusively
responsible for yield dispersion/cash balance decisions and corresponding transactions for cash
balances maintained in any of the Advisors’ unmanaged accounts.
Cybersecurity Risk. The information technology systems and networks that Advisor and its
third-party service providers use to provide services to Advisor’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional or
unintentional actions that could cause significant interruptions in Advisor’s operations and
result in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and Advisor are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial losses, cost
and reputational damage to respond to regulatory obligations, other costs associated with
corrective measures, and loss from damage or interruption to systems. Although Advisor has
established its processes to reduce the risk of cybersecurity incidents, there is no guarantee
that these efforts will always be successful, especially considering that Advisor does not directly
control the cybersecurity measures and policies employed by third-party service providers.
Clients could incur similar adverse consequences resulting from cybersecurity incidents that
more directly affect issuers of securities in which those clients invest, broker-dealers, qualified
custodians, governmental and other regulatory authorities, exchange and other financial
market operators, or other financial institutions.
Custodian Charges-Additional Fees - As discussed below, in conjunction with KFI’s employees’
relationship with Osaic Wealth (broker-dealer), who utilizes Pershing LLC as a clearing firm, shall
serve as the broker-dealer/custodian for client investment management assets. Clearing firms,
such as Pershing, charge brokerage commissions, transaction, and/or other type fees for
effecting certain types of securities transactions (i.e., including transaction fees for certain
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 13
mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The
types of securities for which transaction fees, commissions, and/or other type fees (as well as
the amount of those fees) shall differ depending upon the broker-dealer/custodian. However,
the commissions and/or transaction fees charged by Osaic Wealth and Pershing may be higher
or lower than those charged by other broker-dealer/custodians. While certain custodians do
not currently charge fees on individual equity transactions [including ETFs], others do).
Currently, Pershing charges transaction fees or commissions for ETFs and equities utilized by
KFI. Although KFI is not a frequent trader, its primary investment vehicles for client accounts are
ETFs Thus, clients who utilize Pershing will incur transaction fees for ETF transactions that those
at other custodians may not incur do not incur (Please Note: there can be no assurance that
Pershing will not change their transaction fee pricing in the future). These fees/charges are in
addition to KFI’s investment advisory fee in Item 5 (below). KFI does not receive any portion of
these fees/charges.
Any Questions: KFI’s Chief Compliance Officer, Patti Brennan, remains available to address any
questions that a client or prospective client may have regarding the above.
Borrowing Against Assets/Risks. A client who has a need to borrow money could determine to
do so by using a Pledged Assets Loan where, in consideration for a lender (i.e., a bank, etc.) to
make a loan to the client, the client pledges its investment assets held at the account custodian
as collateral.
Collateralized loans are generally utilized because they typically provide more favorable interest
rates than standard commercial loans. These types of collateralized loans can assist with a
pending home purchase, permit the retirement of more expensive debt, or enable borrowing in
lieu of liquidating existing account positions and incurring capital gains taxes. However, such
loans are not without potential material risk to the client’s investment assets. The lender (i.e.
custodian, bank, etc.) will have recourse against the client’s investment assets in the event of
loan default or if the assets fall below a certain level. For this reason, KFI does not recommend
such borrowing unless it is for specific short-term purposes (i.e. a bridge loan to purchase a new
residence). KFI does not recommend such borrowing for investment purposes (i.e. to invest
borrowed funds in the market). Regardless, if the client was to determine to use a pledged asset
loan, rather than liquidating assets in the client’s account, KFI continues to earn a fee on such
Account assets.
Please Note: The Client must accept the above risks and potential corresponding consequences
associated with the use pledged assets loans.
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 14
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
Trustee Directed Plans. KFI may be engaged to provide investment advisory services to
ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the
investment objective designated by the Plan trustees. In such engagements, KFI will
serve as an investment fiduciary as that term is defined under The Employee Retirement
Income Security Act of 1974 (“ERISA”). KFI will generally provide services on an “assets
under management” fee basis per the terms and conditions of an Investment Advisory
Agreement between the Plan and the Firm.
Participant Directed Retirement Plans. KFI may also provide investment advisory and
consulting services to participant directed retirement plans per the terms and
conditions of a Retirement Plan Services Agreement between KFI and the plan. For such
engagements, KFI shall assist the Plan sponsor with the selection of an investment
platform from which Plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by KFI), and, to the
extent engaged to do so, may also provide corresponding education to assist the
participants with their decision-making process.
Client Retirement Plan Assets. If requested to do so, and as an accommodation, KFI can
also provide investment advisory services relative to 401(k) plan assets maintained by
the client in conjunction with the retirement plan established by the client’s employer.
In such event, KFI shall recommend that the client allocate the retirement account
assets among the investment options available on the 401(k) platform. KFI’s
recommendations shall be limited to the allocation of the assets among the investment
alternatives available through the plan. KFI will not be managing the plan on a
continuous and on-going basis and will not receive any communications from the plan
sponsor or custodian. It shall remain the client’s exclusive obligation to notify KFI of
any changes in investment alternatives, restrictions, etc. pertaining to the retirement
account. Neither KFI, nor any of its representatives, maintain passwords from clients/
pension, profit sharing, 401k, 403b, mutual fund or brokerage accounts held at broker-
dealers/custodians other than Osaic Wealth and Pershing.
eMoney: Account Aggregation. We may provide our clients with access to online
platforms hosted by eMoney. The eMoney platform allows a client to view their
complete asset allocation, including those assets that we do not manage (the “Excluded
Assets”). We do not provide investment management, monitoring, or implementation
services for the Excluded Assets. Therefore, we shall not be responsible for the
investment performance of the Excluded Assets. You and/or your other advisors that
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 15
maintain trading authority, and not us, shall be exclusively responsible for the
investment performance of the Excluded Assets. In addition, eMoney also provide
access to other types of information, including financial planning concepts, which should
not, in any manner whatsoever, be construed as services, advice or recommendations
provided by us. We do not provide investment management, monitoring or
implementation services for the Excluded Assets. If we are asked to make a
recommendation as to any Excluded Assets, you are under absolutely no obligation to
accept the recommendation, and we shall not be responsible for any implementation
error (timing, trading, etc.) relative to the Excluded Assets. You may engage us to
provide investment management services for the Excluded Assets pursuant to the terms
and conditions of the Investment Advisory Agreement between us and you. Finally, we
shall not be held responsible for any adverse results a client may experience if you
engage in financial planning or other functions available on the eMoney platform
without our assistance or oversight.
Please Note: Non-Discretionary Service Limitations - Clients that determine to engage
KFI on a non-discretionary investment advisory basis must be willing to accept that the
KFI cannot affect any account transactions without obtaining prior consent to any such
transaction(s) from the client. Thus, in the event that KFI would like to make a
transaction for a client’s account, and client is unavailable, KFI will be unable to affect
the account transaction (as it would for its discretionary clients) without first obtaining
the client’s consent.
Client Obligations. In performing our services, KFI shall not be required to verify any
information received from the client or from the client’s other professionals and is
expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to
promptly notify KFI, in writing, if there is ever any change in their financial situation or
investment objectives for the purpose of reviewing/evaluating/revising our previous
recommendations and/or services.
Disclosure Brochure. A copy of KFI’s written disclosure statement as set forth on Part 2
of Form ADV and our Form CRS ( Relationship Summary) shall be provided to each client
prior to, or contemporaneously with, the execution of KFI’s Investment Advisory
Agreement.
KFI shall provide investment advisory services specific to the needs of each client. Prior
to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, KFI shall allocate and/or
recommend that the client allocate investment assets consistent with the designated
Form ADV - Part 2A (KFI 2024 Firm Brochure) - Page 16
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on KFI’s services.
Please Note: Investment Risk - Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies
recommended or undertaken by KFI) will be profitable or equal any specific
performance level(s).
KFI does not participate in a wrap fee program.