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Brochure
Form ADV Part 2A
Item 1 - Cover Page
Burkett Financial Services, LLC
CRD# 140168
Home Office
Branch Office
3101 Sunset Blvd.
West Columbia, South Carolina 29169
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
(803) 794-3712
www.BurkettFS.com
February 3, 2026
kevins@burkettfs.com
This Brochure provides information about the qualifications and business practices of Burkett
Financial Services, LLC. If you have any questions about the contents of this Brochure, please
. The information in this Brochure has not
contact us at (803) 980-3232 or
been approved or verified by the United States Securities and Exchange Commission or by any state
authority.
Burkett Financial Services, LLC is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
www.AdviserInfo.sec.gov
information about Burkett Financial Services, LLC also is available on the SEC’s website at
.
Item 2 - Material Changes
This Brochure is prepared in the revised format required beginning in 2011. Registered
Investment Advisers are required to use this format to inform clients of the nature of advisory
services provided, types of clients served, fees charged, potential conflicts of interest and other
information. The Brochure requirements include providing a Summary of Material Changes (the
“Summary”) reflecting any material changes to our policies, practices, or conflicts of interest made
since our last required “annual update” filing. In the event of any material changes, such Summary
is provided to all clients within 120 days of our fiscal year-end. Our last annual update was filed on
February 13, 2025. Of course, the complete Brochure is available to you at any time upon request.
Item 3 - Table of Contents
Page
Item 1 - Cover Page ............................................................................................................................................................ 1
Item 2 - Material Changes................................................................................................................................................ 1
Item 3 - Table of Contents ............................................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................................. 3
Item 5 - Fees and Compensation .................................................................................................................................. 6
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................ 7
Item 7 - Types of Clients .................................................................................................................................................. 7
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 8
Item 9 - Disciplinary Information ................................................................................................................................ 9
Item 10 - Other Financial Industry Activities and Affiliations ......................................................................... 9
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .. 10
Item 12 - Brokerage Practices ..................................................................................................................................... 10
Item 13 - Review of Accounts ...................................................................................................................................... 13
Item 14 - Client Referrals and Other Compensation .......................................................................................... 13
Item 15 - Custody .............................................................................................................................................................. 13
Item 16 - Investment Discretion ................................................................................................................................. 13
Item 17 - Voting Client Securities .............................................................................................................................. 14
Item 18 - Financial Information .................................................................................................................................. 14
Brochure Supplements…………………..………………………...…………………….…………………………… Exhibit A
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Item 4 - Advisory Business
General Information
Burkett Financial Services, LLC (“BFS”) was formed in 2000, and provides financial planning,
portfolio management, and general consulting services to our clients.
Brochure Supplements, Exhibit A
Donald H. Burkett, Ronald H. Burkett and Phillip K. Smiley are the principal owners of BFS. Please
see
, for more information on these principal owners and other
individuals who formulate investment advice and have direct contact with clients, or have
discretionary authority over client accounts.
As of December 31, 2025, BFS managed $554,234,190 on a discretionary basis, and $18,358,437 on
a non-discretionary basis.
SERVICES PROVIDED
At the outset of each client relationship, we spend time with you, asking questions, discussing your
investment experience and financial circumstances, and broadly identifying your major goals.
You may elect to retain us to prepare a full financial plan. This written report is presented to you
for consideration. In most cases, clients subsequently retain us to manage their investment
portfolio on an ongoing basis.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain us for portfolio management services, based on all the information
initially gathered, we generally develop:
•
•
a financial outline for you based on your financial circumstances and goals, and your risk
tolerance level (the “Financial Profile” or “Profile”); and
your investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of your current financial picture and a look to your future goals.
The Investment Plan outlines the types of investments we will make on your behalf to meet those
goals. The Profile and the Plan are discussed regularly with you, but are not necessarily written
documents.
Where we provide general consulting services, we will work with you to prepare an appropriate
summary of the specific project(s) to the extent necessary or advisable under the circumstances.
Financial Planning
One of the services offered by us is financial planning, described below. This service may be
provided as a stand-alone service, or may be coupled with ongoing portfolio management.
Financial planning may include advice that addresses one or more areas of your financial situation,
such as estate planning, risk management, budgeting and cash flow controls, retirement planning,
education funding, and investment portfolio design. Depending on your particular situation,
financial planning may include some or all of the following:
•
Gathering factual information concerning your personal and financial situation;
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•
•
•
•
•
•
•
•
Assisting you in establishing financial goals and objectives;
Analyzing your present situation and anticipated future activities in light of your financial
goals and objectives;
Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
Making recommendations to help achieve retirement plan goals and objectives;
Designing an investment portfolio to help meet the your goals and objectives;
Providing estate planning;
Assessing risk and reviewing basic health, life and disability insurance needs; or
Reviewing goals and objectives and measuring progress toward these goals.
Once financial planning advice is given, you may choose to have us implement your financial plan
and manage the investment portfolio on an ongoing basis. However, you are under no obligation to
act upon any of the recommendations made by us under a financial planning engagement and/or
engage the services of any recommended professional.
Portfolio Management
As described above, at the beginning of a client relationship, we meet with you, gather information,
and perform research and analysis as necessary to develop your Investment Plan. The Investment
Plan will be updated from time to time when requested by you, or when determined to be
necessary or advisable by us based on updates to your financial or other circumstances.
To implement your Investment Plan, we will manage your investment portfolio on a discretionary
or a non-discretionary basis. As a discretionary investment adviser, we will have the authority to
supervise and direct your portfolio without prior consultation with you. Under a non-discretionary
arrangement, you must be contacted prior to the execution of any trade in the account(s) under
management. This can result in a delay in executing recommended trades, which could adversely
affect the performance of your portfolio. This delay also normally means the affected account(s)
will not be able to participate in block trades, a practice designed to enhance the execution quality,
timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, you
retain the responsibility for the final decision on all actions taken with respect to your portfolio.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the
management of your investment portfolio, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. You should note, however, that restrictions
imposed by you may adversely affect the composition and performance of your investment
portfolio. You should also note that your investment portfolio is treated individually by giving
consideration to each purchase or sale for your account. For these and other reasons, performance
of your investment portfolios within the same investment objectives, goals and/or risk tolerance
may differ and you should not expect that the composition or performance of your investment
portfolio would necessarily be consistent with similar clients of ours.
Individual Retirement Advice
When we are making investment recommendations to you regarding your retirement plan account
or individual retirement account, we are acting as fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which
laws governing retirement accounts. The way we make money or otherwise are
are
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compensated creates some conflicts with your financial 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) to you;
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 what is reasonable for our services; and
Give you basic information about our conflicts of interest.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. We will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The
particular services provided will be detailed in the consulting agreement. The appropriate Plan
Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i)
make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and
(iii) make the ultimate decision as to accepting any of the recommendations that we may provide.
The Plan Fiduciaries are free to seek independent advice about the appropriateness of any
recommended services for the Plan. Retirement Plan consulting services may be offered
individually or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, we will be considered a fiduciary under ERISA. For example, we will act as an
ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan
Fiduciaries by recommending a suite of investments as choices among which Plan Participants may
select. Also, to the extent that the Plan Fiduciaries retain us to act as an investment manager within
the meaning of ERISA § 3(38), we will provide discretionary investment management services to
the Plan.
Consulting
Fiduciary
Services
Investment Selection Services
•
We will provide Plan Fiduciaries with recommendations of investment options consistent
with ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination
of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment
advice regarding asset classes and investments.
Investment Monitoring
•
We will assist in monitoring the plan’s investment options by preparing periodic
fund
investment reports that document
investment performance, consistency of
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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. The details of this aspect of service will be enumerated in the
engagement agreement between the parties.
Management
Services
Fiduciary
• Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), we provide
continuous and ongoing supervision over the designated retirement plan assets. We will
actively monitor the designated retirement plan assets and provide ongoing management of
the assets. When applicable, we will 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 the Plan Fiduciaries. 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
We will monitor the investment options of the Plan and add or remove investment options
for the Plan without prior consultation with the Plan Fiduciaries. We will have discretionary
authority to make and implement all decisions regarding the investment options that are
available to Plan Participants.
Investment Management via Model Portfolios
•
We will provide discretionary management of Model Portfolios among which the
participants may choose to invest as Plan options. Plan Participants will also have the
option of investing only in options that do not include Model Portfolios (i.e., the Plan
Participants may elect to invest in one or more of the mutual fund options made available in
the Plan, and choose not to invest in the Model Portfolios at all).
General Consulting
In addition to the foregoing services, we may provide general consulting services you. These
services are generally provided on a project basis, and may include, without limitation, minimal
cash flow planning for certain events such as education expenses or retirement, estate planning
analysis, income tax planning analysis and review of your insurance portfolio, as well as other
matters specific to you as and when requested by you and agreed to by us. The scope and fees for
consulting services will be negotiated with you at the time of engagement for the applicable project.
Item 5 - Fees and Compensation
Item 12 - Brokerage Practices
General Fee Information
Fees paid to us are exclusive of all custodial and transaction costs paid to your custodian, brokers or
other third party consultants. Please see
for additional information.
Fees paid to us are also separate and distinct from the fees and expenses charged by mutual funds,
ETFs (exchange traded funds) or other investment pools to their shareholders (generally including
a management fee and fund expenses, as described in each fund’s prospectus or offering materials).
You should review all fees charged by funds, brokers, BFS and others to fully understand the total
amount of fees paid by you for investment and financial-related services.
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Portfolio Management and Financial Planning Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
First $1,000,000
From $1,000,001 to $2,000,000
From $2,000,001 to $5,000,000
From $5,000,001 to $10,000,000
From $10,000,001 and above
1.00% (with a maximum quarterly fee of $2,500)
0.85% (with a maximum quarterly fee of $4,625)
0.65% (with a maximum quarterly fee of $7,875)
0.50% (with a maximum quarterly fee of $14,125)
0.40% (with no maximum quarterly fee)
We require a minimum portfolio value of $500,000. We may, at our discretion, make exceptions to
the foregoing or negotiate special fee arrangements where we deem it appropriate under the
circumstances.
Portfolio management fees are generally payable quarterly, in arrears. If management begins after
the start of a quarter, fees will be prorated accordingly. With your authorization and unless other
arrangements are made, fees are normally debited directly from your account(s).
Either BFS or you may terminate your Investment Management Agreement at any time, subject to
any written notice requirements in the agreement. In the event of termination, any paid but
unearned fees will be promptly refunded to you based on the number of days that the account was
managed, and any fees due to us from you will be invoiced or deducted from your account prior to
termination.
Financial Planning Fees
From time to time, we are asked to provide a financial plan separate from portfolio management
services, the fee for these services is negotiated at the time of the engagement, and is normally
based on an hourly fee basis.
General Consulting Fees
When we provide general consulting services to you, these services are generally separate from our
financial planning and portfolio management services. Fees for general consulting are negotiated at
the time of the engagement for such services, and are normally based on an hourly or fixed fee
Item 6 - Performance-Based Fees and Side-By-Side Management
basis.
We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a
situation in which the same firm manages accounts that are billed based on a percentage of assets
under management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because we have no performance-based fee accounts, we have no side-by-
side management.
Item 7 - Types of Clients
We serve individuals, pension and profit-sharing plans, trusts, and estates. We impose a minimum
portfolio value of $500,000. Under certain circumstances and in our sole discretion, we may
negotiate such minimums.
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Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
In accordance with the Investment Plan, we will primarily invest in mutual funds, exchange traded
funds (“ETFs”) and fixed income investments for the overall construction and design of an account
for you.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors, including,
as applicable and without limitation, past performance, fee structure, portfolio manager, fund
sponsor, overall ratings for safety and returns, and other factors.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity
or income needs in a portfolio, or to add a component of capital preservation. We may evaluate and
select individual bonds or bond funds based on a number of factors including, without limitation,
rating, yield and duration.
Investment Strategies
Our strategic approach is to invest your portfolio in accordance with the Plan that has been
developed specifically for you. This means that the following strategies may be used in varying
combinations over time for you, depending upon your individual circumstances.
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of
the securities’ short term price fluctuations.
Margin Transactions – a securities transaction in which an investor borrows money to
purchase a security, in which case the security serves as collateral on the loan.
Risk of Loss
While we seek to diversify your investment portfolio across various asset classes consistent with
your Investment Plan in an effort to reduce risk of loss, all investment portfolios are subject to risks.
Accordingly, there can be no assurance that your investment portfolio will be able to fully meet
your investment objectives and goals, or that investments will not lose money.
Below is a description of several of the principal risks that your investment portfolio faces.
Management Risks.
While we manage your investment portfolio based on our experience, research
and proprietary methods, the value of your investment portfolio will change daily based on the
performance of the underlying securities in which it is invested. Accordingly, your investment
portfolio is subject to the risk that we allocate your assets to individual securities and/or asset
classes that are adversely affected by unanticipated market movements, and the risk that our
specific investment choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described above, we will
invest your portfolio in mutual funds, ETFs and other investment pools (“pooled investment
funds”). Investments in pooled investment funds are generally less risky than investing in
individual securities because of their diversified portfolios; however, these investments are still
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subject to risks associated with the markets in which they invest. In addition, pooled investment
funds’ success will be related to the skills of their particular managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory
restrictions applicable to registered investment companies under the Investment Company Act of
1940.
Equity Market Risks.
We may invest portions of your assets directly into pooled investment funds
that invest in the stock market. As noted above, while pooled investments have diversified
portfolios that may make them less risky than investments in individual securities, funds that invest
in stocks and other equity securities are nevertheless subject to the risks of the stock market.
These risks include, without limitation, the risks that stock values will decline due to daily
fluctuations in the markets, and that stock values will decline over longer periods (e.g., bear
markets) due to general market declines in the stock prices for all companies, regardless of any
individual security’s prospects.
Fixed Income Risks.
We may invest portions of your assets directly into fixed income instruments,
such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes.
While investing in fixed income instruments, either directly or through pooled investment funds, is
generally less volatile than investing in stock (equity) markets, fixed income investments
nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks
that changes in interest rates will devalue the investments), credit risks (risks of default by
borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance
to maturity).
Foreign Securities Risks.
We may invest portions of your assets into pooled investment funds that
invest internationally. While foreign investments are important to the diversification of your
investment portfolio, they carry risks that may be different from U.S. investments. For example,
foreign investments may not be subject to uniform audit, financial reporting or disclosure
standards, practices or requirements comparable to those found in the U.S. Foreign investments
are also subject to foreign withholding taxes and the risk of adverse changes in investment or
exchange control regulations. Finally, foreign investments may involve currency risk, which is the
risk that the value of the foreign security will decrease due to changes in the relative value of the
Item 9 - Disciplinary Information
U.S. dollar and the security’s underlying foreign currency.
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of BFS or the integrity of our
management. We have no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
BFS is majority owned by members who are shareholders of Burkett Burkett & Burkett Certified
Public Accountants, P.A. (“Burkett CPAs”). Donald H. Burkett, Ronald H. Burkett, and Larry D.
Montague, Jr. are shareholders of Burkett CPAs and are also members of BFS. BFS and Burkett CPAs
may share information that is beneficial to you.
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Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. Our Code has several goals. First, the Code is designed to assist us in complying with
applicable laws and regulations governing our investment advisory business. Under the Investment
Advisers Act of 1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties, the
Code requires persons associated with us (managers, officers and employees) to act with honesty,
good faith and fair dealing in working with clients. In addition, the Code prohibits such associated
persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for our associated persons. Under
the Code’s Professional Standards, we expect our associated persons to put the interests of our
clients first, ahead of personal interests. In this regard, our associated persons are not to take
inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, our associated persons may invest in the same
securities recommended to you. Under our Code, we have adopted procedures designed to reduce
or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated
persons, reporting and review of such trading and pre-clearance of certain types of personal
trading activities. These policies are designed to discourage and prohibit personal trading that
would disadvantage clients. The Code also provides for disciplinary action as appropriate for
violations.
Participation or Interest in Client Transactions
Because client accounts are invested almost exclusively in open-end mutual funds and ETFs, there
is little opportunity for a conflict of interest between personal trades by our associated persons and
trades in client accounts, even when such accounts invest in the same securities. However, in the
event of other identified potential trading conflicts of interest, our goal is to place client interests
first.
Consistent with the foregoing, we maintain policies regarding participation in initial public
offerings (“IPOs”) and private placements in order to comply with applicable laws and avoid
conflicts with client transactions. If our associated person wishes to participate in an IPO or invest
in a private placement, he or she must submit a pre-clearance request and obtain the approval of
the Chief Compliance Officer.
Finally, if associated persons trade with client accounts (e.g., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated persons’ shares will be removed from the block,
and the balance of shares will be allocated among client accounts in accordance with our written
Item 12 - Brokerage Practices
policy.
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in your account, we
seek “best execution” for your trades, which is a combination of a number of factors, including,
without limitation, quality of execution, services provided and commission rates. Therefore, we
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may use or recommend the use of brokers who do not charge the lowest available commission in
the recognition of research and securities transaction services, or quality of execution. Research
services received with transactions may include proprietary or third party research (or any
combination), and may be used in servicing any or all of our clients. Therefore, research services
received may not be used for the account for which the particular transaction was effected.
We recommend that you establish a brokerage account with the Charles Schwab & Co., Inc.
(“Schwab”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to maintain
custody of your assets. We may also effect trades for your accounts at Schwab, or may in some
instances, consistent with our duty of best execution and specific agreement with you, elect to
execute trades elsewhere. Although we may recommend that you establish an account at Schwab, it
is ultimately your decision to custody assets with Schwab. We are independently owned and
operated and are not affiliated with Schwab.
Schwab Advisor Services provides us with access to its institutional trading, custody, reporting and
related services, which are typically not available to Schwab retail investors. Schwab also makes
available various support services. Some of those services help us manage or administer our
clients’ accounts while others help us manage and grow our business. These services generally are
available to independent investment advisors on an unsolicited basis, at no charge to them. These
services are not soft dollar arrangements, but are part of the institutional platform offered by
Schwab. Schwab’s brokerage services include the execution of securities transactions, custody,
research, and access to mutual funds and other investments that are otherwise generally available
only to institutional investors or would require a significantly higher minimum initial investment.
For our client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions or other fees on
trades that it executes or that settle into your Schwab account. Certain trades may not incur Schwab
commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested
cash in your account. Schwab Advisor Services also makes available to us other products and
services that benefit us but may not directly benefit our clients’ accounts. Many of these products
and services may be used to service all or a substantial number of our accounts, including accounts
not maintained at Schwab.
Schwab’s products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade
orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate
payment of our fees from our clients’ accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
Schwab Advisor Services also offers other services intended to help us manage and further develop
our business enterprise. These services may include: (i) technology, compliance, legal and business
consulting; (ii) publications and conferences on practice management and business succession; and
(iii) access to employee benefits providers, human capital consultants and insurance providers.
Schwab may make available, arrange and/or pay third-party vendors for the types of services
rendered to us. Schwab Advisor Services may discount or waive fees it would otherwise charge for
some of these services or pay all or a part of the fees of a third-party providing these services to us.
Schwab Advisor Services may also provide other benefits such as educational events or occasional
business entertainment of our personnel. In evaluating whether to recommend that clients custody
their assets at Schwab, we may take into account the availability of some of the foregoing products
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and services and other arrangements as part of the total mix of factors it considers and not solely
on the nature, cost or quality of custody and brokerage services provided by Schwab, which may
create a potential conflict of interest.
Directed Brokerage
You may direct us to use a particular broker for custodial or transaction services on behalf of your
portfolio. In directed brokerage arrangements, you are responsible for negotiating the commission
rates and other fees to be paid to the broker. Accordingly, if you choose to direct brokerage you
should consider whether such designation may result in certain costs or disadvantages to you,
either because you may pay higher commissions or obtain less favorable execution, or the
designation limits the investment options available to you.
The arrangement that we have with Schwab is designed to maximize efficiency and to be cost
effective. By directing brokerage arrangements, you acknowledge that these economies of scale
and levels of efficiency are generally compromised when alternative brokers are used. While every
effort is made to treat clients fairly over time, the fact that you choose to use the brokerage and/or
custodial services of these alternative service providers can in fact result in a certain degree of
delay in executing trades for your account(s) and otherwise adversely affect management of your
account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and
agree with us that they have the authority to make the direction, that there are no provisions in any
client or plan document which are inconsistent with the direction, that the brokerage and other
goods and services provided by the broker or dealer through the brokerage transactions are
provided solely to and for the benefit of the client’s plan, plan participants and their beneficiaries,
that the amount paid for the brokerage and other services have been determined by the client and
the plan to be reasonable, that any expenses paid by the broker on behalf of the plan are expenses
that the plan would otherwise be obligated to pay, and that the specific broker or dealer is not a
party in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We typically direct trading in your account as and when trades are appropriate based on your
Investment Plan, without regard to activity in other client accounts. However, from time to time,
we may aggregate trades together for multiple client accounts, most often when these accounts are
being directed to sell the same securities. If such an aggregated trade is not completely filled, we
will allocate shares received (in an aggregated purchase) or sold (in an aggregated sale) across
participating accounts on a pro rata or other fair basis; provided, however, that any participating
accounts that are owned by us or our officers, directors, or employees will be excluded first.
Cross Trades
From time to time, we may direct a “cross trade” of securities (including, without limitation, fixed
income securities) between client accounts, whereby BFS arranges for one client account to
purchase a security directly from another client. In such cases, we will seek to obtain a price for the
security from one or more independent sources. We are not a broker-dealer and receive no
compensation from a cross trade; however, the broker-dealer facilitating the cross trade normally
charges administrative fees to the clients’ accounts.
We may direct a cross trade when we believe that the transaction is in your best interest, that no
client will be disfavored by the transaction, and that the transaction is consistent with our duty to
seek best execution.
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Item 13 - Review of Accounts
Managed portfolios are reviewed in depth at least annually but may be reviewed more often if
requested by you, upon receipt of information material to the management of your portfolio, or at
any time such a review is deemed necessary or advisable by us. These factors generally include, but
are not limited to, the following: change in your general circumstances (marriage, divorce,
retirement); or economic, political or market conditions. Performance of managed portfolios is
monitored throughout the year.
Phillip K. (“Kevin”) Smiley, Wealth Advisor and Member, Neil A. Brown, Lemuel H. Mitchum and
Jana Morrison, Wealth Advisors of BFS, all review accounts.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in your account as well as transactions in your account,
including fees paid from your account. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. In addition, we provide at least a
quarterly report for each managed portfolio. This written report normally includes a summary of
portfolio holdings and performance results. Additional reports are available at your request.
Item 14 - Client Referrals and Other Compensation
Item 12 - Brokerage Practices.
As noted above, we receive an economic benefit from Schwab in the form of support products and
services it makes available to us and other independent investment advisors that have their clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the
related conflicts of interest are described in
The availability of
Schwab’s products and services to us is based solely on our participation in the programs and not
on the provision of any particular investment advice. Neither Schwab nor any other party is paid to
Item 15 - Custody
refer clients to us.
Schwab is the custodian of nearly all client accounts at BFS. From time to time however, you may
select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide you with confirmations of trading activity, tax forms and at least quarterly
account statements. You are advised to review this information carefully, and to notify us of any
questions or concerns. You are also asked to promptly notify us if the custodian fails to provide
statements on each account held.
From time to time and in accordance with our agreement with you, we will provide additional
reports. The account balances reflected on these reports should be compared to the balances
shown on the brokerage statements to ensure accuracy. At times there may be small differences
due to the timing of dividend reporting, pending trades or other similar issues.
Item 16 - Investment Discretion
Item 4 - Advisory Business
As described above under
, we manage portfolios on a discretionary
basis and non-discretionary basis. This means that after an Investment Plan is developed for your
investment portfolio, we will execute that plan without specific consent from you for each
transaction. For discretionary accounts, a Limited Power of Attorney (“LPOA”) is executed by you,
giving us the authority to carry out various activities in your account, generally including the
following: trade execution; the ability to request checks on your behalf; and, the withdrawal of
Page 13
advisory fees directly from your account. We then direct investment of your portfolio using our
discretionary authority. You may limit the terms of the LPOA to the extent consistent with your
investment advisory agreement with us and the requirements of your custodian. The discretionary
relationship is further described in the agreement between you and BFS.
Item 17 - Voting Client Securities
As a policy and in accordance with our client agreement, we do not vote proxies related to
securities held in your account. The custodian of the account will normally provide proxy materials
directly to you. You may contact us with questions relating to proxy procedures and proposals;
however, we generally do not research particular proxy proposals.
Item 18 - Financial Information
We do not require nor solicit prepayment of more than $1,200 in fees per client, six months or more
in advance.
Page 14
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
P. Kevin Smiley, CPA, CFP®
CRD# 4120309
of
Burkett Financial Services, LLC
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
www.BurkettFS.com
February 3, 2026
This Brochure Supplement provides information about Kevin Smiley, and supplements the Burkett
Financial Services, LLC (“BFS”) Brochure. You should have received a copy of that Brochure. Please
contact us at (803) 980-3232 if you did not receive our Brochure, or if you have any questions about
the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Kevin is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Phillip Kevin Smiley (year of birth 1971) co-founded BFS in July of 2000 and serves as Chief
Compliance Officer and Wealth Adviser. Kevin was born in Blacksburg, South Carolina, and graduated
from Winthrop University in December 1994 with a Bachelor of Science degree in Business
Administration with an emphasis in Accounting.
While attending Winthrop University, Kevin was employed at Geo. G. Scott & Co. in Charlotte, North
Carolina, as an intern. After graduation, he was promoted to junior accountant. In May of 1997, Kevin
joined Burkett Burkett & Burkett Certified Public Accountants, P.A. in the Rock Hill office. Kevin
worked on audit engagements and tax preparation for individuals and small businesses. In November
of 1999, Kevin left Burkett Burkett & Burkett Certified Public Accountants, P.A. to work with Legg
Mason Wood Walker, Inc. During this employment, he passed the Series 66, Uniform Combined State
Law Exam, and the Series 7, General Securities Representative Exam, to become licensed to sell
securities. Kevin gained experience with investment strategies and financial planning until Legg
Mason closed the Rock Hill office in July of 2000.
Exhibit A-1
Kevin became a Certified Public Accountant* (CPA) in 1998 and is also a CERTIFIED FINANCIAL PLANNER™
professional**. In September of 2003, he passed the Series 24, General Securities Principal
Examination.
Kevin is a member of the American Institute of Certified Public Accountants and the South Carolina
Association of Certified Public Accountants. He is a member of Trinity United Methodist Church where
he serves as Chairperson of the finance committee.
* A CPA is a Certified Public Accountant. All CPA candidates must pass the Uniform CPA Examination
to qualify for a CPA certificate and license to practice public accounting. While the exam is the same
regardless of where it is taken, every state/jurisdiction has its own set of education and experience
requirements that individuals must meet. However, most states require at least a bachelor’s degree
and a concentration in accounting, and at least one year of public accounting experience under the
supervision of or verification by a CPA. Once the designation is attained, the CPA is required to meet
continuing education requirements.
**
®
The CFP
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such as
the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
Item 3 - Disciplinary Information
professionals must complete 30 hours of continuing education accepted by CFP Board every two years.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Kevin has no such disciplinary
Item 4 - Other Business Activities
information to report.
Kevin is not engaged in any other business activities.
Item 5 - Additional Compensation
Kevin has no other income or compensation to disclose.
Item 6 - Supervision
Kevin is a co-owner and Chief Compliance Officer of BFS. He is also a Wealth Adviser and serves on the
investment committee.
Overall investment decisions are made as a team by the investment committee, and portfolio activity
based on these decisions will be carried by these individuals, as assisted by other staff members of the
firm.
As Chief Compliance Officer, Kevin is responsible for providing compliance oversight to the staff. He
also participates as a team member in the investment and trading processes, and may be contacted at
(803) 980-3232.
Exhibit A-2
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Neil A. Brown, CPA, CFP®
CRD# 5145080
3101 Sunset Blvd.
West Columbia, South Carolina 29169
(803) 794-3712
of
Burkett Financial Services, LLC
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
www.BurkettFS.com
February 3, 2026
This Brochure Supplement provides information about Neil Brown, and supplements the Burkett
Financial Services, LLC (“BFS”) Brochure. You should have received a copy of that Brochure. Please
contact us at (803) 980-3232 if you did not receive our Brochure, or if you have any questions about
the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Neil is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Neil A. Brown (year of birth 1969) joined BFS in 2003 and serves as a Wealth Adviser. Neil has
significant experience in financial planning and brings a wide variety of financial service and tax
expertise to the firm. He advises clients on various personal financial planning issues including
distribution, retirement, income tax, insurance, education, investment and estate tax. Prior to joining
BFS, Neil headed the financial planning department at a large fee-only financial planning firm in
Columbia. Prior to that, Neil was a senior consultant with the Carolinas Financial Counseling Services
Practice of Deloitte & Touché in Charlotte, North Carolina where he spent the majority of his time
advising executives and employees of a Fortune 500 company on retirement, insurance, investment,
income and estate planning.
Exhibit A-3
Neil received a Masters of Accountancy, magna cum laude, from The University of South Carolina in
1993 and Bachelors in Business, magna cum laude, from The University of South Carolina in 1992. He
is a CERTIFIED FINANCIAL PLANNER™ practitioner* and a Certified Public Accountant** (CPA).
®
®
Certification Examination.
Bloomberg Wealth Manager
The State, Financial Advisor
Kiplinger’s Personal Finance
Financial Planning
Neil is a member of the American Institute of CPAs, the South Carolina Association of CPAs, the
Columbia Estate Planning Council, the Columbia Tax Study Group and the National Association of
Certification Education
Personal Financial Advisors. He is the Program Coordinator for the CFP
Programs at Midlands Technical College. Neil is also a national instructor for Keir Educational
Resources’ Review for the CFP
Research Magazine
Midlands Woman
Neil has been quoted in and authored articles in
,
,
,
,
and
.
* A CPA is a Certified Public Accountant. All CPA candidates must pass the Uniform CPA Examination
to qualify for a CPA certificate and license to practice public accounting. While the exam is the same
regardless of where it is taken, every state/jurisdiction has its own set of education and experience
requirements that individuals must meet. However, most states require at least a bachelor’s degree
and a concentration in accounting, and at least one year of public accounting experience under the
supervision of or verification by a CPA. Once the designation is attained, the CPA is required to meet
continuing education requirements.
**
®
The CFP
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such as
the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
Item 3 - Disciplinary Information
professionals must complete 30 hours of continuing education accepted by CFP Board every two years.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however Neil has no such disciplinary information
to report.
Item 4 - Other Business Activities
Neil is engaged in other business activities, such as teaching for the state Society of CPAs and other
Item 5 - Additional Compensation
financial planners.
Neil has no other income or compensation to disclose.
Item 6 - Supervision
Kevin Smiley, Chief Compliance Officer of BFS, is responsible for providing compliance oversight for
Neil and for reviewing accounts. Kevin can be reached at (803) 980-3232.
Exhibit A-4
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Lem H. Mitchum
CRD# 5268236
3101 Sunset Blvd.
West Columbia, South Carolina 29169
(803) 794-3712
of
Burkett Financial Services, LLC
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
www.BurkettFS.com
February 3, 2026
This Brochure Supplement provides information about Lem Mitchum, and supplements the Burkett
Financial Services, LLC (“BFS”) Brochure. You should have received a copy of that Brochure. Please
contact BFS at (803) 980-3232 if you did not receive our Brochure, or if you have any questions about
the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Lem is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Lemuel Hoyle Mitchum, III (year of birth 1943) joined BFS in 2000 and serves as a Wealth Adviser.
Lem, a native of Florence, South Carolina, graduated from the University of South Carolina as a
Business Economics Major in 1972.
Lem volunteered and served in the United States Marine Corps from 1967-1969 as a NCO. During his
service, he was part of the U.S. Sixth Fleet, stationed in the Mediterranean Sea and served a tour of duty
in Vietnam. After receiving an Honorable Discharge from the Marine Corp, he was employed with
South Carolina National Bank (Wachovia) from 1972 through 1983 as a commercial/consumer lender
and, for a period, primary Business Development Officer for all offices in Columbia, Lexington and
Batesburg-Leesville.
Exhibit A-5
Following three years of preparation through the College of Financial Planning, Denver, Colorado, Lem
became a financial planner in 1983 and began a fee only financial planning service as an employee of
Burkett, Burkett & Burkett CPAs in 1984. For a period of ten years, Lem provided financial planning
services for individuals, families, and businesses that addressed a full spectrum of financial issues from
designing and implementing investment strategies to preparing estate planning designs. He also
provided additional services including qualified retirement plan implementation to business
valuations as well as investment and management critiques of third party providers.
During a period from 1994-1999, Lem and his wife devoted their time and resources to develop, build,
and operate a resort bed and breakfast inn on Bald Head Island in North Carolina. The operating inn
was leased as a “turn-key” operation in 1999, at which time Lem returned to Burkett, Burkett &
Burkett CPAs to assist in a growing financial planning practice to include an asset management service
Item 3 - Disciplinary Information
as a Registered Investment Advisor Representative.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Lem has no such disciplinary information
Item 4 - Other Business Activities
to report.
Lem is not engaged in any other business activities.
Item 5 - Additional Compensation
Lem has no other income or compensation to disclose.
Item 6 - Supervision
Kevin Smiley, Chief Compliance Officer of BFS, is responsible for supervising for providing compliance
oversight for Lem and for reviewing accounts. Kevin can be reached at (803) 980-3232.
Exhibit A-6
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Donald H. Burkett, PFS
CRD# 5259720
3101 Sunset Blvd.
West Columbia, South Carolina 29169
(803) 794-3712
of
Burkett Financial Services, LLC
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
www.BurkettFS.com
February 3, 2026
This Brochure Supplement provides information about Donald (“Donny”) Burkett, and supplements
the Burkett Financial Services, LLC (“BFS”) Brochure. You should have received a copy of that
Brochure. Please contact us at (803) 980-3232 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Donald is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Donald H. Burkett (year of birth 1952) co-founded BFS in 2001 and since 2015 has been serving as a
Wealth Adviser. Donny is a life-long resident of South Carolina and received a Bachelor of Science
degree in Accounting from the University of South Carolina in 1974. He became a Certified Public
Accountant* (“CPA”) in 1976 and a Personal Financial Specialist** (“PFS”) in 2004.
Donny founded Burkett, Burkett & Burkett, Certified Public Accountants, P.A. in West Columbia, South
Carolina, in 1976. He currently serves as an Executive Vice President of the firm. Donny has also
served as a Partner of ResourceOne Health Management Service, LLC since 1996.
Donny has been a Board Member of South Carolina Board of Accountancy since 2000. He is the
Current Vice Chair of National Association of State Boards of Accountancy and has served as a Board
Exhibit A-7
Member since 2009. In addition, he is a member of the American Institute of Certified Public
Accountants and Central Chapter of Certified Public Accountants. Donny is a current member and past
President of the Cayce/West Columbia Civitan Club and Cayce/West Columbia Rotary Club, and is the
President of the Airport High School Educational Foundation.
* A CPA is a Certified Public Accountant. All CPA candidates must pass the Uniform CPA Examination
to qualify for a CPA certificate and license to practice public accounting. While the exam is the same
regardless of where it is taken, every state/jurisdiction has its own set of education and experience
requirements that individuals must meet. However, most states require at least a bachelor’s degree
and a concentration in accounting, and at least one year of public accounting experience under the
supervision of or verification by a CPA. Once the designation is attained, the CPA is required to meet
continuing education requirements.
** The PFS designation is granted exclusively to CPAs with the combination of extensive tax expertise
and comprehensive knowledge of personal financial planning. The requirements for the PFS
credential are established by the PFP (Personal Financial Planning) staff at the AICPA (American
Institute of CPAs), the National Accreditation Commission, along with the PFS Credential Committee,
and accurately reflect the depth and breadth of experience and technical expertise required to obtain
this credential. The 5 major requirements are: (1) Obtain CPA licensure (2) join the AICPA and be a
member in good standing (3) complete a comprehensive PFP education, consisting of a minimum of 80
hours of PFP training and education within the five year period preceding the date of the PFS
application (4) fulfill 3,000 hours of personal financial planning business experience and (5) pass a
PFP examination.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Donny has no such disciplinary
information to report.
Item 4 - Other Business Activities
Donny is a shareholder in Burkett Burkett & Burkett CPAs, P.A. (“Burkett CPAs”), which is affiliated
with BFS by common ownership. BFS and Burkett CPAs may share information that is beneficial to
Item 5 - Additional Compensation
you.
Item 6 - Supervision
Other than noted above, Donny has no other income or compensation to disclose.
Kevin Smiley, Chief Compliance Officer of BFS, is responsible for providing compliance oversight for
Donny and for reviewing accounts. Kevin can be reached at (803) 980-3232.
Exhibit A-8
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Jana B. Morrison, CPA, CFP®
CRD# 6194448
of
Burkett Financial Services, LLC
128 East Main Street
Suite 101
Rock Hill, South Carolina 29730
(803) 980-3232
www.BurkettFS.com
February 3, 2026
This Brochure Supplement provides information about Jana Morrison, and supplements the Burkett
Financial Services, LLC (“BFS”) Brochure. You should have received a copy of that Brochure. Please
contact BFS at (803) 980-3232 if you did not receive our Brochure, or if you have any questions about
the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Jana is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Jana B. Morrison (year of birth 1965) has been with BFS since 2014 and serves as a Wealth Adviser.
Originally from Great Falls, South Carolina, Jana received a Bachelor of Science degree in Business
Administration with an emphasis in Accounting, magna cum laude, from the University of South
Carolina in 1992. She became a Certified Public Accountant* (CPA) in 1994 and a CERTIFIED FINANCIAL
PLANNER™ professional** in 2009. In June 2013, she passed the Series 7 and Series 63 exams.
For a brief time in 2022, Jana served as a Wealth Advisor for Buckingham Strategic Wealth before
returning to BFS. Prior to joining BFS in 2014, Jana worked as a Financial Consultant in the Investment
Services division of Founders Federal Credit Union. Prior to that, she was employed for over twenty
years with The Springs Company, a family office, and provided high-net-worth tax and financial
planning for the family members.
Jana is a member of the American Institute of CPAs, the South Carolina Association of CPAs and The
Financial Planning Association. She is also a member of Crestview Baptist Church where she serves on
the finance committee.
Exhibit A-9
* A CPA is a Certified Public Accountant. All CPA candidates must pass the Uniform CPA Examination
to qualify for a CPA certificate and license to practice public accounting. While the exam is the same
regardless of where it is taken, every state/jurisdiction has its own set of education and experience
requirements that individuals must meet. However, most states require at least a bachelor’s degree
and a concentration in accounting, and at least one year of public accounting experience under the
supervision of or verification by a CPA. Once the designation is attained, the CPA is required to meet
continuing education requirements.
®
®
** The CFP
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”).
To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations, such as
the CPA, CFA and others may satisfy the education component, and allow a candidate to sit for the
Certification Examination. A comprehensive examination tests the candidate’s ability to apply
CFP
financial planning knowledge to client situations. Qualifying work experience is also required for
certification. Qualifying experience includes work in the area of the delivery of the personal financial
planning process to clients, the direct support or supervision of others in the personal financial
®
planning process, or teaching all, or any portion, of the personal financial planning process. CFP
Item 3 - Disciplinary Information
professionals must complete 30 hours of continuing education accepted by CFP Board every two years.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Jana has no such disciplinary information
to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Jana is not engaged in any other business activities.
Item 6 - Supervision
Jana has no other income or compensation to disclose.
Kevin Smiley, Chief Compliance Officer of BFS, is responsible for providing compliance oversight for
Jana and for reviewing accounts. Kevin can be reached at (803) 980-3232.
Exhibit A-10