FORM ADV PART 2A- KELLER FINANCIAL GROUP

Keller Financial Group, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Keller Financial Group, Inc. If you have any questions about the contents of this brochure, please contact us at (717) 516-0700 or by email at: info@kellercpa.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Keller Financial Group, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Keller Financial Group, Inc.’s CRD number is: 328195 3815 Market Street Camp Hill, PA 17011 (717) 516-0700 info@kellercpa.com https://www.kellercpa.com/ Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 10/09/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment on March 25, 2026, of Keller Financial Group, Inc., are described below. Material changes relate to Keller Financial Group, Inc.’s policies, practices or conflicts of interest. Keller Financial Group, Inc. has no material changes ii  Item 3: Table of Contents Item 2: Material Changes .................................................................................................................................................... 2 Contents Item 3: Table of Contents .................................................................................................................................................... 3 Item 4: Advisory Business ................................................................................................................................................... 2 Item 5: Fees and Compensation ......................................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................. 8 Item 7: Types of Clients ....................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ............................................................................ 8 Item 9: Disciplinary Information...................................................................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ..................................................................................... 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 13 Item 12: Brokerage Practices ............................................................................................................................................. 14 Item 13: Review of Accounts ............................................................................................................................................ 15 Item 14: Client Referrals and Other Compensation ...................................................................................................... 16 Item 15: Custody ................................................................................................................................................................ 16 Item 16: Investment Discretion ........................................................................................................................................ 16 Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................... 17 Item 18: Financial Information ......................................................................................................................................... 17 iii  Item 4: Advisory Business A. Description of the Advisory Firm Keller Financial Group, Inc. (hereinafter “KFG”) is a Corporation organized in the State of Pennsylvania. The firm was formed in September 1998, and the principal owner is Dwayne D Keller. B. Types of Advisory Services Portfolio Management Services KFG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KFG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • KFG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KFG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. KFG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KFG’s economic, investment or other financial interests. To meet its fiduciary obligations, KFG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KFG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is KFG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Selection of Other Advisers KFG has entered into a sub-advisory relationship with AssetMark, an investment adviser registered with the U.S. Securities and Exchange Commission. Through this relationship 2  clients can utilize the AssetMark investment platform to access various third-party investment solutions, including specialized tactical strategy portfolios, diversified baskets of exchange traded funds, indexing mutual funds, portfolios of individual equity securities, or strategists specializing in other alternative styles. AssetMark provides KFG with research, due diligence, and a curated list of the various third-party managers that have been fully vetted, rated for their expertise, categorized for their trading style, and are monitored by the AssetMark investment team. KFG will remain responsible for determining the client’s investment objectives and whether one or more of the available managers is best suited to meet the designed investment objective of a specific account. Pension Consulting Services KFG offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • • • • • identifying investment objectives and restrictions providing guidance on various assets classes and investment options recommending money managers to manage plan assets in ways designed to achieve objectives monitoring performance of money managers and investment options and making recommendations for changes recommending other service providers, such as custodians, administrators and broker-dealers creating a written pension consulting plan • These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance recommendations; tax concerns; retirement planning; college planning; and debt/credit planning. KFG offers two types of Financial Planning: One-Time Financial Planning and Ongoing Financial Planning. Each financial planning service is tailored to address different client needs. Services Limited to Specific Types of Investments KFG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital 3  funds and private placements. KFG may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client 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. C. Client Tailored Services and Client Imposed Restrictions KFG will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by KFG on behalf of the client. KFG may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent KFG from properly servicing the client account, or if the restrictions would require KFG to deviate from its standard suite of services, KFG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. KFG does not participate in wrap fee programs. 4  E. Assets Under Management KFG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 130,934,696 $4,390,920.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Maximum Advisory Fee: Total Assets Under Management Annual Fees $0 - $500,000 1.50% $500,001 - $1,000,000 1.38% $1,000,001 - $2,000,000 1.25% $2,000,001 - $3,000,000 1.11% $3,000,001 - $5,000,000 1.00% $5,000,001 - $10,000,000 0.89% $10,000,001 - AND UP 0.56% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of KFG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Selection of Other Advisers Fees KFG has entered into a sub-advisory relationship with AssetMark. Clients will pay KFG its standard fee in addition to the standard fee for AssetMark. Fees and compensation for using the AssetMark Platform are provided in more detail in the AssetMark Platform Disclosure Brochure. The Client should consider all applicable fees. The notice of termination requirement and payment of fees are disclosed in AssetMark’s Form ADV. 5  Pension Consulting Services Fees Hourly Fees The hourly fee for these services is between $250 and $500. The final fee schedule will be memorialized in the client’s advisory agreement. Financial Planning Fees One-Time Fixed Fees The negotiated fixed rate for creating client financial plans is between $300 and $30,000. One-Time Hourly Fees The negotiated hourly fee for these services is between $250 and $500. Ongoing Fixed Fees The negotiated monthly fixed rate for ongoing financial planning is between $100 and $700. Clients may terminate the agreement without penalty, for full refund of KFG’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in advance. Payment of Pension Consulting Services Fees Hourly pension consulting fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Payment of Selection of Other Advisers Fees Fees for selection of AssetMark as third-party adviser are withdrawn directly by AssetMark from the client's accounts with client's written authorization. Fees are paid quarterly in advance. 6  Payment of Financial Planning Fees One-Time Financial planning fees are paid via check and wire. One-Time Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. One-Time Hourly financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Ongoing Monthly Fixed financial planning fees are paid via check, wire, or secure third- party credit card processor. Ongoing Monthly Fixed financial planning fees are paid in advance at the beginning of each month. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by KFG. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees KFG collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. E. Outside Compensation For the Sale of Securities to Clients Dwayne D. Keller does not accept compensation for the sale of investment products to KFG clients. 7  Item 6: Performance-Based Fees and Side-By-Side Management KFG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients KFG generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Charitable Organizations ❖ ❖ ❖ ❖ There is no account minimum for any of KFG’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis KFG’s methods of analysis include Fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Investment Strategies KFG uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in 8  stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Selection of Other Advisers: Although KFG will seek to select only money managers who will invest clients' assets with the highest level of integrity, KFG's selection process cannot ensure that money managers will perform as desired and KFG will have no control over the day-to-day operations of any of its selected money managers. KFG would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and 9  credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or 10  changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 11  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither KFG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither KFG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Dwayne D. Keller is the owner and an accountant with Keller Financial Group. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. KFG always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of KFG in connection with such individual’s activities outside of KFG. Keller Financial Group is also an accounting firm. From time to time, clients may be offered advice or products from those activities and clients should be aware that these services may involve a conflict of interest. KFG always acts in the best interest of the client 12  and clients always have the right to decide whether or not to utilize the services. Keller Financial Group owns the following entities: 3815 Market Investments, LLC, Vista Wealth Management, LLC, KFG Accounting and Advisory, LLC, and KFG Wealth Management LLC. 3815 Market Investments, LLC owns the building that Keller Financial Group, Inc. occupies. Vista Wealth Management, LLC, KFG Accounting and Advisory, LLC, and KFG Wealth Management LLC are inactive entities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections KFG may direct clients to third-party investment advisers. Clients will pay KFG its standard fee in addition to the standard fee for the advisers to which it directs those clients. The fees will not exceed any limit imposed by any regulatory agency. KFG will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. KFG will ensure that all recommended advisers are exempt, licensed or notice filed in the states in which KFG is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics KFG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. KFG's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests KFG does not recommend that clients buy or sell any security in which a related person to KFG or KFG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of KFG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of KFG to buy or sell the same securities before or after recommending the same securities 13  to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. KFG will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of KFG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of KFG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, KFG will never engage in trading that operates to the client’s disadvantage if representatives of KFG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on KFG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and KFG may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in KFG's research efforts. KFG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. KFG recommends AssetMark Trust, Pershing Advisor Solutions, LLC, Capital Client Group, Inc. (formerly American Funds), SEI Private Trust, and ADP Retirement Services. 1. Research and Other Soft-Dollar Benefits KFG receives no research, product, or services other than execution from broker- dealers or custodians in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals KFG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use 14  KFG will require clients to use a specific broker-dealer to execute transactions. B. Aggregating (Block) Trading for Multiple Client Accounts KFG does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for KFG's advisory services provided on an ongoing basis are reviewed at least annually by Dwayne D Keller, Managing Member, Chief Compliance Officer, and President, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at KFG are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Dwayne D Keller, Managing Member, Chief Compliance Officer, and President,. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, KFG’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of KFG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 15  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients KFG has a relationship with AssetMark, Inc., an SEC registered investment adviser CRD #109018, to use the asset allocation and individual account management platform sponsored by AssetMark. AssetMark, Inc. is notice filed in New York. Client will sign an Account Set-up and Application Form to establish an account on the platform. AssetMark, Inc. will not provide any advisory services to the client account. KFG is encouraged to utilize AssetMark, Inc.’s advisor-directed tools, templates and best practices, or to engage with AssetMark Inc. to provide education and guidance in implementing a growth plan for their business. Certain Financial Advisors can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Financial Advisor based on their participation in AssetMark sponsored events, marketing initiatives, or use technology resources and tools. This program creates a financial incentive for Financial Advisors to recommend that Clients invest assets through the AssetMark Platform. Clients will be given AssetMark's brochure which will describe the platform and services of AssetMark, Inc. in greater detail. There is no referral fee received by KFG as the firm's fee is separate from AssetMark, Inc. KFG has a relationship with FWL Investment Management, LLC dba Lear Investment Management (Lear) in which Lear agrees to pay KFG a fee in exchange for the referral and introduction of potential clients to Lear. KFG is an independent contractor to Lear. Clients are given a disclosure document in accordance with regulatory guidelines. B. Compensation to Non – Advisory Personnel for Client Referrals KFG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, KFG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion KFG provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, KFG generally manages the client’s account and 16  makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, KFG’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to KFG. Item 17: Voting Client Securities (Proxy Voting) KFG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet KFG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither KFG nor its management has any financial condition that is likely to reasonably impair KFG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years KFG has not been the subject of a bankruptcy petition in the last ten years. 17