DBK FINANCIAL COUNSEL, LLC

DBK FINANCIAL COUNSEL, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of DBK Financial Counsel, LLC. If you have any questions about the contents of this brochure, please contact us at 330-923-3038 or by email at: dbkearns@dbkfinancial.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 DBK Financial Counsel, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. DBK Financial Counsel, LLC’s CRD number is: 170688. 198 W. Portage Trail Ext., Ste. 105 Cuyahoga Falls, OH, 44223 330-923-3038 dbkearns@dbkfinancial.com www.dbkfinancial.com Registration does not imply a certain level of skill or training. 02/19/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of DBK Financial Counsel LLC on 02/25/2025 are described below. Material changes relate to DBK Financial Counsel LLC’s policies, practices or conflicts of interests only. • DBK Financial Counsel LLC has updated its assets under management. (Item 4.E) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .......................................................................................................................................................................................... ii Item 3: Table of Contents ......................................................................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................................................................... 5 A. Description of the Advisory Firm................................................................................................................................................................... 5 B. Types of Advisory Services.............................................................................................................................................................................. 5 Financial Planning ............................................................................................................................................................................................ 6 Written Acknowledgement of Fiduciary Status ........................................................................................................................................... 6 C. Client Tailored Services and Client Imposed Restrictions .......................................................................................................................... 6 D. Wrap Fee Programs .......................................................................................................................................................................................... 7 E. Assets Under Management .............................................................................................................................................................................. 7 Item 5: Fees and Compensation ................................................................................................................................................................................ 7 A. Fee Schedule ...................................................................................................................................................................................................... 7 Financial Planning Fees ................................................................................................................................................................................... 7 B. Payment of Fees................................................................................................................................................................................................. 8 Payment of Financial Planning Fees .............................................................................................................................................................. 8 C. Client Responsibility For Third Party Fees .................................................................................................................................................... 8 D. Prepayment of Fees .......................................................................................................................................................................................... 8 E. Outside Compensation For the Sale of Securities to Clients ........................................................................................................................ 8 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................ 8 Item 7: Types of Clients ............................................................................................................................................................................................. 9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................................................................................... 9 A. Methods of Analysis and Investment Strategies .......................................................................................................................................... 9 B. Material Risks Involved ................................................................................................................................................................................. 10 C. Risks of Specific Securities Utilized .............................................................................................................................................................. 11 Item 9: Disciplinary Information ............................................................................................................................................................................ 12 A. Criminal or Civil Actions .............................................................................................................................................................................. 12 B. Administrative Proceedings .......................................................................................................................................................................... 12 C. Self-regulatory Organization (SRO) Proceedings ....................................................................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................. 12 A. Registration as a Broker/Dealer or Broker/Dealer Representative ......................................................................................................... 13 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .......................... 13 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .................................................... 13 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections .......................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................... 13 iii  A. Code of Ethics ................................................................................................................................................................................................. 13 B. Recommendations Involving Material Financial Interests ........................................................................................................................ 14 C. Investing Personal Money in the Same Securities as Clients .................................................................................................................... 14 D. Trading Securities At/Around the Same Time as Clients’ Securities ...................................................................................................... 14 Item 12: Brokerage Practices.................................................................................................................................................................................... 14 A. Factors Used to Select Custodians and/or Broker/Dealers ...................................................................................................................... 14 1. Research and Other Soft-Dollar Benefits ................................................................................................................................................. 14 2. Brokerage for Client Referrals................................................................................................................................................................... 15 3. Clients Directing Which Broker/Dealer/Custodian to Use ................................................................................................................. 15 B. Aggregating (Block) Trading for Multiple Client Accounts ...................................................................................................................... 15 Item 13: Reviews of Accounts ................................................................................................................................................................................. 15 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ....................................................................................... 16 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..................................................................................................... 16 C. Content and Frequency of Regular Reports Provided to Clients ............................................................................................................. 16 Item 14: Client Referrals and Other Compensation ............................................................................................................................................. 16 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ............... 16 B. Compensation to Non – Advisory Personnel for Client Referrals ............................................................................................................ 16 Item 15: Custody ....................................................................................................................................................................................................... 16 Item 16: Investment Discretion ............................................................................................................................................................................... 17 Item 17: Voting Client Securities (Proxy Voting) .................................................................................................................................................. 17 Item 18: Financial Information ................................................................................................................................................................................ 17 A. Balance Sheet ................................................................................................................................................................................................... 17 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........................................ 17 C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................... 18 iv  Item 4: Advisory Business Business Description Our advisory firm is a SEC registered investment adviser. We provide investment advisory services to high-net-worth individuals concerning various securities, including fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities and all transactions are sent to our qualified custodian which executes, compares, allocates, clears and settles them. Our custodian also maintains our clients’ accounts and may grant clients access to them. A. Description of the Advisory Firm DBK Financial Counsel, LLC (hereinafter “DBK”) is a Limited Liability Company organized and registered as a SEC registered investment adviser. The firm was formed in January 2014, and the principal owner is David B. Kearns. B. Types of Advisory Services Portfolio Management Services DBK offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DBK creates an Investment Policy Statement for each client, 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 DBK evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DBK 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. DBK seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of DBK’s economic, investment or other financial interests. To meet its fiduciary obligations, DBK attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, DBK’s policy is to seek fair and 5  equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is DBK’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax planning; retirement planning; college planning; and debt/credit planning. Services Limited to Specific Types of Investments DBK generally limits its investment advice to fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), mutual funds, treasury inflation protected/inflation linked bonds and non-U.S. securities. Although DBK primarily recommends U.S. and international stocks and bonds to a majority of its clients. DBK 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. 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 DBK will tailor a program for each individual client, based on Client preference, net worth and income, and appropriateness of proposed investment. 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 DBK on behalf of the client. DBK tailors client portfolios with a specific set of recommendations for each client based on their personal restrictions, needs, and 6  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 DBK from properly servicing the client account, or if the restrictions would require DBK to deviate from its standard suite of services, DBK 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, transaction costs, fund expenses, and other administrative fees. DBK does not participate in any wrap fee programs. E. Assets Under Management DBK has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $167,741,671.00 $31,734,583.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee Up to $5,000,000 1.00% $5,000,000 - $10,000,000 0.75% $10,000,000 - and up 0.50% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of DBK's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally on written notice. DBK bills based on the balance on the first day of the billing period. Financial Planning Fees 7  DBK charges a fixed fee for financial planning services unless a client has assets managed by DBK. The hourly fee for these services is $295. The fees are negotiable. B. Payment of Fees Payment of Asset-Based 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. Fees are paid in advance. Payment of Financial Planning Fees Financial Planning fees are paid via check. Fees are generally paid quarterly, but in some cases maybe paid upon completion of work. 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 DBK. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees DBK generally collects fees in advance. Refunds for fees paid in advance will be 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 the balance of the fees collected in advance minus the daily rate* times the number of days 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.) E. Outside Compensation For the Sale of Securities to Clients Neither DBK nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management 8  DBK 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 DBK generally provides advisory services to the following types of clients: ❖ High-Net-Worth Individuals Minimum Account Size for Portfolio Management There is an account minimum of $1,000,000, which may be waived by DBK in its discretion. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis DBK’s methods of analysis include fundamental analysis, technical analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset classes. Investment Strategies DBK uses long term trading. DBK may engage on rare occasions in short sales, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 9  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 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. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies DBK's occasional use of short sales, margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those 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. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. 10  Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized DBK's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. 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. 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 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. 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 or stock (equity) nature, or a mix of multiple underlying security types. 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. 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 11  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. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. 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. 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 12  A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither DBK 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 DBK 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 David Kearns practices law on a part-time basis with the law firm of DBK Legal Counsel, LLC. 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. DBK always acts in the best interest of the client and clients are in no way required to use the services of any representative of DBK in connection with such individual’s activities outside of DBK FINANCIAL COUNSEL, LLC. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections DBK does not utilize nor select third-party investment advisers. All assets are managed by DBK management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics DBK 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. DBK's Code of Ethics is available free upon request to any client or prospective client. 13  B. Recommendations Involving Material Financial Interests DBK does not recommend that clients buy or sell any security in which a related person to DBK or DBK has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of DBK may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of DBK to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. DBK 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 DBK may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of DBK 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, DBK will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on DBK’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 DBK may also consider the market expertise and research access provided by 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 DBK's research efforts. DBK will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. DBK recommends Schwab Institutional, a division of Charles Schwab. 1. Research and Other Soft-Dollar Benefits 14  While DBK has no formal soft dollars program in which soft dollars are used to pay for third party services, DBK may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). DBK may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and DBK does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. DBK benefits by not having to produce or pay for the research, products or services, and DBK will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that DBK’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals DBK 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 DBK may permit clients to direct it to execute transactions through a specified broker- dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to DBK to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts DBK 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: Reviews of Accounts 15  A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client portfolio management accounts are reviewed at least quarterly by Dori Torrens and/or David B. Kearns with regard to clients’ respective investment policies and risk tolerance levels. All accounts at DBK are assigned to this reviewer. All financial planning accounts are reviewed by Dori Torrens and/or David B. Kearns upon financial plan creation and plan delivery by David B. Kearns. There is only one level of review for financial plans, and that is the total review conducted to create the financial plan. 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, DBK’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client will receive a monthly 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. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) DBK does not receive any economic benefit, directly or indirectly from any third party for advice rendered to DBK's clients. B. Compensation to Non – Advisory Personnel for Client Referrals DBK does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody 16  When advisory fees are deducted directly from client accounts at client's custodian, DBK 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. Custody is also disclosed in Form ADV because DBK has authority to transfer money from client account(s), which constitutes a standing letter or authorization (SLOA). Accordingly, DBK will follow the safeguards specified by the SEC rather than undergo an annual audit. Item 16: Investment Discretion DBK provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, DBK generally manages the client’s account and 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, DBK’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 DBK. Item 17: Voting Client Securities (Proxy Voting) DBK votes proxies related to all managed securities. The authority to vote proxies is established in the client’s Client Services Agreement or comparable documents. In accordance with our fiduciary duties and SEC Rule 206(4)-6, we have adopted policies and procedures that we believe are reasonably designed to ensure that proxies are voted in the best interests of our clients. Proxies are normally reviewed and voted upon the Chief Investment Officer. Clients may obtain information on how a proxy on a security held in their account was voted and/or a copy of our proxy voting policy and procedure by calling (330) 923-3038. Item 18: Financial Information A. Balance Sheet DBK 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 17  Neither DBK nor its management has any financial condition that is likely to reasonably impair DBK’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years DBK has not been the subject of a bankruptcy petition in the last ten years. 18