Overview
- Headquarters
- Lexington, KY
- Total Firm Assets
- $404 million
- Average High-Net-Worth Client Portfolio Size
- $2.0 million
- Minimum Account Size
- $25,000
Fee Structure
Primary Fee Schedule (DUPREE FINANCIAL GROUP | ADV PART 2 | AMENDED)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 0.90% |
| $1,000,001 | $2,000,000 | 0.75% |
| $2,000,001 | $3,000,000 | 0.60% |
| $3,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,750 | 1.08% |
| $5 million | $34,250 | 0.68% |
| $10 million | $59,250 | 0.59% |
| $50 million | $259,250 | 0.52% |
| $100 million | $509,250 | 0.51% |
Clients
- High-Net-Worth Share of Firm Assets
- 55.51%
- Number of High-Net-Worth Clients
- 114
- Total Client Accounts
- 1,655
- Discretionary Accounts
- 1,655
Services Offered
Services: Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 131091
Primary Brochure: DUPREE FINANCIAL GROUP | ADV PART 2 | AMENDED (2026-08-24)
View Document Text
Item 1 – Cover Page
Form ADV Part 2A: FIRM BROCHURE
DUPREE FINANCIAL GROUP, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
compliance@dupreefinancial.com
www.dupreefinancial.com
August 24, 2026
This brochure provides information about the qualifications and business practices of Dupree
Financial Group, LLC.
Should you have any questions about the contents of this brochure, please contact us at (859) 233-
0400 or e-mail D. Hudson Kemp, Chief Compliance Officer (CCO) of the Firm at
compliance@dupreefinancial.com. Please note that the information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by
any state securities authority.
Dupree Financial Group, LLC is an investment adviser registered with the SEC under the
Investment Advisers Act of 1940, as amended. Registration of an investment adviser does not
imply any level of skill or training. The oral and written communications of an adviser provide
you with information you can use to determine to hire or retain an adviser.
Additional information about Dupree Financial Group, LLC also is available on the SEC’s website
at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Pursuant to SEC rules, Dupree Financial Group will provide a summary of material changes to its
brochure within 120 days of the close of its fiscal year. Dupree Financial Group will provide
further disclosures about material changes, as deemed necessary. Additionally, Dupree Financial
Group will provide to clients a new brochure as necessary, without charge.
• Staffing Changes
o Chief Compliance Officer Retired
■ 04/08/2026
• William B. Ambrose Retired from Dupree Financial Group
■ 04/08/2026
• D. Hudson Kemp was named Chief Compliance Officer
• Dupree Financial Group has added disclosure language related to a third-party money
manager ("TPMM") arrangement, directing certain clients to Fidelity Institutional Wealth
Advisor LLC through the Fidelity Managed Account Xchange ("FMAX") platform.
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Item 3 – Table of Contents
Item 1 – Cover Page ...................................................................................................................... 1
Item 2 – Material Changes ........................................................................................................... 2
Item 3 – Table of Contents ........................................................................................................... 3
Item 4 – Advisory Business ........................................................................................................... 4
Item 5 – Fees and Compensation ................................................................................................. 5
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 ............................................................................................. 10
Item 10 – Other Financial Industry Activities and Affiliations .............................................. 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ............................................................................................................................. 12
Item 12 – Brokerage Practices ................................................................................................... 15
Item 13 – Review of Accounts .................................................................................................... 18
Item 14 – Client Referrals and Other Compensation .............................................................. 19
Item 15 – Custody ........................................................................................................................ 19
Item 16 – Investment Discretion ................................................................................................ 20
Item 17 – Voting Client Securities ............................................................................................. 21
Item 18 – Financial Information ................................................................................................ 22
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Item 4 – Advisory Business
Describe your advisory firm, including how long you have been in business. Identify
A.
your principal owner(s).
Founded in 2003 by Thomas P. Dupree, Dupree Financial Group, LLC (“Dupree Financial Group”
or “we” or “our” or the “Firm”) is registered as an investment adviser with the SEC. Dupree
Financial Group is a limited liability company formed under the laws of the Commonwealth of
Kentucky.
Dupree Financial Group is owned by Thomas P. Dupree.
B.
Describe the types of advisory services you offer. If you hold yourself out as
specializing in a particular type of advisory service, such as financial planning, quantitative
analysis, or market timing, explain the nature of that service in greater detail. If you provide
investment advice only with respect to limited types of investments, explain the type of
investment advice you offer, and disclose that your advice is limited to those types of
investments.
Dupree Financial Group’s primary purpose is managing investment assets for retirees and those
planning to retire. We tailor investment advisory services to the specific needs of each of our
clients. Our investment recommendations are typically generated from Dupree Financial Group’s
original research. We provide two types of investment advisory services for our clients: portfolio
management services and asset management services. Client accounts for which we provide
portfolio management services to are held at independent brokerage firms; our primary investment
custodians are Fidelity and Charles Schwab. We also provide asset management advice for
retirement accounts held in Institutional Retirement Plan for the University of Kentucky held at
Fidelity.
Dupree Financial Group works with each client to establish an investment policy, including
determining investment goals and risk tolerance, establishing asset allocation parameters,
establishing cash flow and liquidity requirements and setting reasonable expectations for
investment returns. Based on the risk and return objectives set forth in each client’s investment
policy, Dupree Financial Group recommends investments to create a diversified portfolio that best
fits with the client’s goals and priorities and the opportunity set presented by changing market
conditions.
Dupree Financial Group may direct clients to third-party investment advisers. Before selecting
other advisers for clients, Dupree Financial Group will verify that all recommended advisers are
properly licensed, notice filed, or exempt in the states where Dupree Financial Group is
recommending the adviser to clients.
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Dupree Financial Group utilizes Fidelity Institutional Wealth Advisor LLC ("FIWA") through the
Fidelity Managed Account Xchange ("FMAX") platform, setting trading thresholds within which
FIWA manages client accounts. There is no additional advisory fee or added compensation to
Dupree Financial Group for this arrangement; clients are only responsible for applicable custodial
transaction fees.
Dupree Financial Group does not represent, warrant or imply that the services or methods of
analysis employed by it can or will predict future results, successfully identify market tops or
bottoms, or insulate clients from losses due to market corrections or declines.
C.
Explain whether (and, if so, how) you tailor your advisory services to the individual
needs of clients. Explain whether clients may impose restrictions on investing in certain
securities or types of securities.
As mentioned above, Dupree Financial Group tailors its investment advisory services to the
individual needs of its clients. In addition to investment advice for retirement accounts, we may
provide advice on private placements, pooled investment vehicles and other alternative
investments. Dupree Financial Group may also, at its discretion, advise a client on any other type
of investment that we deem appropriate based on that client’s stated goals and objectives or on any
type of investment(s) held in that client’s portfolio. Clients can impose restrictions on investing in
certain securities or types of securities.
D.
If you participate in wrap fee programs by providing portfolio management services,
(1) describe the differences, if any, between how you manage wrap fee accounts and how you
manage other accounts, and (2) explain that you receive a portion of the wrap fee for your
services.
Dupree Financial Group does not participate in wrap fee programs.
E.
If you manage client assets, disclose the amount of client assets you manage on a
discretionary basis and the amount of client assets you manage on a non-discretionary basis.
Disclose the date “as of” which you calculated the amounts.
As of December 31, 2025, Dupree Financial Group manages $404,368,661, one hundred (100%)
percent of it is on a discretionary basis.
Item 5 – Fees and Compensation
Describe how you are compensated for your advisory services. Provide your fee
A.
schedule. Disclose whether the fees are negotiable.
Dupree Financial Group is paid a fee in consideration for the investment management services
provided to its advisory clients at the rates agreed to in written advisory contracts. Our annual fees
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for portfolio management services and asset management advice are equal to a percentage of the
market value of a client’s account, as shown in the tables below. Portfolio management services
include $385,950,551 as of December 31, 2025. Asset management advice includes
$18,418,110.00 as of December 31, 2025. These annual fees are pro-rated and paid quarterly in
advance based on the quarter-end market value of each client’s account. The percentage
calculation of the annual fee will not be increased without prior written notice to a client. Fees are
not negotiable, but Dupree Financial Group has deviated in certain circumstances from the
investment fees listed below at its sole discretion.
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Portfolio Management Services
Account Size
$0 to $499,999.99
$500,000 to $999,999.99
$1,000,000 to $1,999,999.99
$2,000,000 to $2,999,999.99
$3,000,000 and above
Annualized Fee
1.25%
0.90%
0.75%
0.60%
0.50%
Asset ManagementAdvice
Account Size
$0 to $1,000,000
Over $1,000,000
Annualized Fee
0.75%
0.50%
B.
Describe whether you deduct fees from clients’ assets or bill clients for fees incurred.
If clients may select either method, disclose this fact. Explain how often you bill clients or
deduct your fees.
Generally, the qualified custodian holding a client’s funds and securities will charge a client’s
account for the amount of the investment management services fee quarterly in advance and will
remit such fee directly to Dupree Financial Group. If the terms of a client’s account do not allow
for direct withdrawal of the management and/or asset allocation advice fee, the client will be
required to pay the fee directly to Dupree Financial Group within 30 days of receipt of an invoice
from Dupree Financial Group. The qualified custodian delivers a quarterly account statement
directly to the client, showing all holdings, additions and disbursements from the account. Clients
are strongly encouraged to review all account statements for accuracy.
C.
Describe any other types of fees or expenses clients may pay in connection with your
advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will
incur brokerage and other transaction costs, and direct clients to the section(s) of your
brochure that discuss brokerage.
Clients will incur certain charges imposed by custodians, brokers, third-party investment and other
third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees and other fees and taxes on
brokerage accounts and securities transactions. Mutual funds and exchange-traded funds also
charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees
and commissions are exclusive of and in addition to Dupree Financial Group’s fee, and Dupree
Financial Group does not presently receive any portion of these commissions, fees and costs.
For clients participating in the Fidelity Managed Account Xchange ("FMAX") platform, Dupree
Financial Group charges its standard advisory fee as described above; there is no additional
advisory fee charged by Fidelity Institutional Wealth Advisor LLC or paid by the client for this
service. Clients participating in FMAX may incur custodial transaction fees charged by the account
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custodian, which are separate from and in addition to Dupree Financial Group's advisory fee.
D.
If your clients either may or must pay your fees in advance, disclose this fact. Explain
how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated
before the end of the billing period. Explain how you will determine the amount of the
refund.
As mentioned above in 5.B., generally the qualified custodian holding a client’s funds and
securities will charge a client’s account for the amount of the investment management services fee
quarterly in advance and will remit such fee directly to Dupree Financial Group. If the terms of a
client’s account do not allow for direct withdrawal of the management and/or asset allocation
advice fee, the client will be required to pay the fee directly to Dupree Financial Group within 30
days of receipt of an invoice from Dupree Financial Group. Fees will be assessed pro rata in the
event an investment advisory services agreement is executed at any time other than the first day of
a calendar quarter. Dupree Financial Group or the client may terminate such investment advisory
services agreement upon written notice to the other party. In the event of termination, fees will be
charged on a pro-rata basis and any unearned fees will be refunded to the client.
E.
If you or any of your supervised persons accepts compensation for the sale of
securities or other investment products, including asset-based sales charges or service fees
from the sale of mutual funds, disclose this fact and respond to Items 5.E.1, 5.E.2, 5.E.3 and
5.E.4.
Neither Dupree Financial Group nor any supervised person accepts compensation for the sale of
securities or other products.
Item 6 – Performance-Based Fees and Side-By-Side Management
If you or any of your supervised persons accepts performance-based fees – that is, fees based
on a share of capital gains on or capital appreciation of the assets of a client (such as a Client
that is a hedge fund or other pooled investment vehicle) – disclose this fact. If you or any of
your supervised persons manage both accounts that are charged a performance-based fee
and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-
based fee, disclose this fact. Explain the conflicts of interest that you or your supervised
persons face by managing these accounts at the same time, including that you or your
supervised persons have an incentive to favor accounts for which you or your supervised
persons receive a performance-based fee, and describe generally how you address these
conflicts.
Dupree Financial Group does not accept performance-based fees.
Item 7 – Types of Clients
8
Describe the types of clients to whom you generally provide investment advice, such as
individuals, trusts, investment companies, or pension plans. If you have any requirements
for opening or maintaining an account, such as a minimum account size, disclose the
requirements.
9
Dupree Financial Group provides personalized investment advisory and portfolio management
services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations and other organizations and business entities. Although the
minimum requirement to maintain an account is $25,000, this minimum may be waived, for a
particular client with special circumstances, at the sole discretion of management.
Dupree Financial Group provides personal investment advisory and asset management services
for the pension plans of individuals that are employees of the University of Kentucky. Dupree
Financial Group negotiates the terms of such services as well as the fees of such services with
these individual clients. For these asset management clients, there is no minimum requirement to
maintain an account.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A.
Describe the methods of analysis and investment strategies you use in formulating
investment advice or managing assets. Explain that investing in securities involves risk of
loss that clients should be prepared to bear.
Dupree Financial Group utilizes a modified value-based investment strategy. In its original
meaning, this term was used to describe the purchase of securities which were trading below their
net liquidating values. Today, these types of securities are more difficult to find. Value investing
has come to mean investing in any security, which for various reasons may be trading lower than
similar securities in the marketplace. In addition, we seek securities with a history of long-term
dividends payout that increases over time with earnings and cash flow.
Dupree Financial Group invests in equity and fixed-income Exchange Traded Funds (ETFs) that
track broad indexes (eg. S&P 500, short-term US Treasury etc.). The firm also invests in sector
ETFs (Financial, Industrial etc.) if it deems certain sectors/industries to have a favorable outlook.
Additionally, the firm invests in individual securities including stocks and bonds by conducting
due-diligence using a bottom-up security analysis approach.
In researching companies, a company’s financial information is studied in detail, namely balance
sheet, cash flow and income statements. Based on this information, Dupree Financial Group
evaluates certain performance metrics (e.g., profit margin, debt/equity, return on equity, interest
coverage, dividend payout ratios) to determine operational efficiencies. We also evaluate certain
valuation metrics (e.g., price/earnings, price/cash flow, book value) to determine relative value.
While investing in exchange-traded funds or mutual funds, the goal is to understand the fund’s
investment objectives, the investment manager’s track record and performance of the fund over a
period of time.
In addition, Dupree Financial Group also considers various economic and market data published
by the Federal Reserve and other governmental and private agencies. Dupree Financial Group
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also studies report(s) published by third-party investment managers and analysts, newsletters,
newspapers and magazines to assess the state of the economy and obtain investment ideas.
Dupree Financial Group invests in securities that appear to be trading at or below a valuation
metric we deem appropriate. We tend to be long-term investors and constantly monitor the price
in relation to what we deem to be fair value of a security. We determine the proper diversification
strategy on a case-by-case basis.
If a particular security represents a very low or high
percentage of a portfolio, we may rebalance by buying or selling that security. In addition, we
recommend dividend reinvestment to clients who are not in need of income and have a longer
investment horizon.
B.
For each significant investment strategy or method of analysis you use, explain the
material risks involved. If the method of analysis or strategy involves significant or unusual
risks, discuss these risks in detail. If your primary strategy involves frequent trading of
securities, explain how frequent trading can affect investment performance, particularly
through increased brokerage and other transaction costs and taxes.
Dupree Financial Group invests in Exchange Traded Funds (ETFs) and individual securities that
we deem appropriate based on valuations and the risk-profile of the client. An investment using
the Dupree Financial Group modified value-based investment strategy (as specified above) entails
risks, including, but not limited to, the possibility of a complete loss of the amount invested. Many
market-related and other factors, some of which cannot be anticipated, could result in an investor
losing a material portion or all of their investment or prevent a client account from generating
earnings. Dupree Financial Group investment strategies are subject to general investment risks,
such as the following: securities market volatility and illiquidity; adverse political or economic
events, negative global developments, unforeseen developments in a particular industry, changes
in interest rates; operational risks; and in the case of debt securities, reinvestment risk and credit risk;
inaccuracies in company-issued financial statements; and sustained periods of adverse securities
market performance.
C.
If you recommend primarily a particular type of security, explain the material risks
involved. If the type of security involves significant or unusual risks, discuss these risks in
detail.
Investing in securities involves risk of loss that clients should understand and be prepared to bear.
All securities that Dupree Financial Group invests in have both business and market risk associated
with them. In addition, fixed-income investments such as bonds or certain REIT’s can be
susceptible to interest rate, duration, pre-payment and default risk. Securities of companies based
in overseas markets carry political and currency risk. Commodity-related investments might also
carry additional volatility risk. Business risk is inherent in any investment in the stock or bonds
of a private or publicly traded company, such as the risk that the underlying business may not
succeed and might be unable to meet its financial obligations in a timely fashion. Market risk is
the risk that even though the business may be solvent, its stock or bonds may drop in value because
11
of market conditions beyond the company's control. Interest rate risk primarily affects bonds and
other fixed-income investments. This is the risk that higher general interest rates lead to lower
bond prices as the fixed coupon from bonds becomes less attractive in a higher interest rate
environment. A longer bond duration can potentially make the price more volatile. Prepayment
risk is the opposite of duration risk; it is the risk that the investor gets money back from the
investment quicker than expected, thereby lowering the yield on the investment. Default risk is
the same as business risk, except in the case of a technical default which occurs because of a bond
issuer’s failure to comply with a legal requirement of the bond issue.
Item 9 – Disciplinary Information
If there are legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of your advisory business or the integrity of your management, disclose all
material facts regarding those events.
Like other registered investment advisers, Dupree Financial Group is required to disclose all
material facts regarding any legal or disciplinary events that would materially impact an investor’s
evaluation of Dupree Financial Group or the integrity of Dupree Financial Group’s management.
On October 5, 2016, the Securities and Exchange Commission issued an Administrative Order
against the firm for failure to conduct annual compliance reviews over a multi-year period,
pursuant to Section 206(4) of the Advisers Act. Under the order, Dupree Financial Group, LLC
accepted a censure for its compliance lapses and agreed to pay a $25,000 fine while also explicitly
committing to avoid repeat violations of the relevant provisions of the Investment Advisers Act.
Item 10 – Other Financial Industry Activities and Affiliations
A.
If you or any of your management persons are registered, or have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer,
disclose this fact.
Neither Dupree Financial Group nor any of its Supervised Persons are registered or have an
application pending to register as a broker-dealer, or associated person of the foregoing, and
Dupree Financial Group does not anticipate such affiliations in the future.
B.
If you or any of your management persons are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a
commodity trading adviser, or an associated person of the foregoing entities, disclose this
fact.
Neither Dupree Financial Group nor any of its Supervised Persons are registered or have an
application pending to register as a futures commission merchant, commodity pool operator,
12
commodity trading adviser, or associated person of the foregoing. Dupree Financial Group does
not anticipate such affiliations in the future.
C.
Describe any relationship or arrangement that is material to your advisory business
or to your clients that you or any of your management persons have with any related person
listed below. Identify the related person and if the relationship or arrangement creates a
material conflict of interest with clients, describe the nature of the conflict and how you
address it.
1. Broker-dealer, municipal securities dealer, or government securities dealer or broker
2. Investment company or other pooled investment vehicle (including a mutual fund,
closed-end investment company, unit investment trust, private investment company
or “hedge fund,” and offshore fund)
3. Other investment adviser or financial planner
4. Futures commission merchant, commodity pool operator, or commodity trading
advisor
5. Banking or thrift institution
6. Accountant or accounting firm
7. Lawyer or law firm
8. Insurance company or agency
9. Pension consultant
10. Real estate broker or dealer
11. Sponsor or syndicator of limited partnerships.
Dupree Financial Group does not have arrangements with a related person who is a broker-dealer,
investment company, other investment adviser, financial planning firm, commodity pool operator,
commodity trading advisor or futures commission merchant, banking or thrift institution,
accounting firm, law firm, pension consultant, or real estate broker or dealer that are material to
its advisory services.
Dupree Financial Group has and will continue to develop relationships with professionals who
provide services it does not provide, including legal, accounting, banking, tax preparation,
insurance brokerage, and other personal services. None of the above relationships, however, create
a material conflict of interest with clients.
From time to time, Dupree Financial Group receives training, information, promotional material,
meals, gifts, or prize drawings from vendors and others with whom it does business or to whom it
makes referrals. At no time will Dupree Financial Group accept money, benefits, gifts, or other
arrangements that are conditioned on directing individual client transactions to a specific security,
product, or provider. Gifts over a reasonable amount are to be given to charity or returned to the
giver.
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D.
If you recommend or select other investment advisers for your clients and you receive
compensation directly or indirectly from those advisers that creates a material conflict of
interest, or if you have other business relationships with those advisers that create a material
conflict of interest, describe these practices and discuss the material conflicts of interest these
practices create and how you address them.
Dupree Financial Group may direct clients to third-party investment advisers. Clients will pay
Dupree Financial Group its standard fee; there is no additional fee paid to the third-party adviser
to which Dupree Financial Group directs those clients. Dupree Financial Group will always act in
the best interests of the client, including when determining which third-party investment adviser
to recommend to clients. Dupree Financial Group will ensure that all recommended advisers are
exempt, licensed, or notice filed in the states in which Dupree Financial Group is recommending
them to clients.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
A.
If you are an SEC-registered adviser, briefly describe your Code of Ethics adopted
pursuant to SEC rule 204A-1 or similar state rules. Explain that you will provide a copy of
your Code of Ethics to any client or prospective client upon request.
Code of Ethics
As fiduciaries, Dupree Financial Group and its employees have certain legal obligations to put the
clients’ best interests ahead of their own. Dupree Financial Group has adopted a written code of
ethics based on principles of openness, honesty, integrity and trust. At least once a year, each
Dupree Financial Group employee is required to acknowledge this code and agree to be bound by
it.
Dupree Financial Group’s code of ethics covers standards of business conduct, supervised persons
prohibited business practices; personal trading procedures; reporting of personal securities
transactions; insider trading; procedures designed to detect and prevent insider trading; gifts and
entertainment; outside business activities; and administration of the code of ethics.
Dupree Financial Group expects every employee to adhere strictly to these guidelines and
demonstrate the highest standard of ethical conduct for continued employment with Dupree
Financial Group. Firm personnel who violate the code of ethics may be subject to remedial actions,
including, but not limited to, profit disgorgement, fines, censure, suspension or dismissal.
Personnel are also required to promptly report to the Chief Compliance Officer any violations of
the code of ethics of which they become aware.
Dupree Financial Group will provide a copy of its Code of Ethics to any existing or prospective
its Chief Compliance Officer, D. Hudson Kemp, at
investor upon
request
to
14
compliance@dupreefinancial.com or (859) 233-0400.
If you or a related person recommends to clients, or buys or sells for client accounts,
B.
securities in which you or a related person has a material financial interest, describe your
15
practice and discuss the conflicts of interest it presents. Describe generally how you address
conflicts that arise.
Examples: (1) You or a related person, as principal, buys securities from (or sells securities
to) your clients; (2) you or a related person acts as general partner in a partnership in which
you solicit client investments; or (3) you or a related person acts as an investment adviser to
an investment company that you recommend to clients.
Participation or Interest in Client Transactions
Dupree Financial Group officers and employees carry on investment activities for their own
account(s) and for family members, friends or others, and give advice and recommend securities
to vehicles or accounts which differ from advice given to, or securities recommended or bought
for, Dupree Financial Group clients, even though their investment objectives may not be the same
or similar. Dupree Financial Group officers and employees may also trade in the securities and
derivatives markets or make other investments for their own accounts, including the use of margin
and option trading.
Neither Dupree Financial Group nor an officer or employee will engage in principal transactions
between a proprietary account and a client account without first obtaining the prior written
approval of the Chief Compliance Officer and the consent of the client.
Although it does not expect to, from time to time, Dupree Financial Group may, in rare occasions,
complete securities trades (including outright purchases and sales) between a client account,
known as a “cross trade.” In the rare event this occurs, any cross-trading transactions conducted
between client accounts will be made at the then market rate for similar transactions between
unrelated parties and only where an independent pricing mechanism (such as the last sales price
on the exchange where the security is principally traded) is available.
Conflicts of Interest
As an investment adviser, Dupree Financial Group owes a fiduciary duty to its clients. As part of
its fiduciary duty, the Firm must put the interests of its clients ahead of its own and, in doing so,
must take reasonable steps to avoid conflicts of interest between the Firm and its clients. The
Firm’s fiduciary duty requires it to: (i) identify any actual or potential conflicts of interest; (ii)
disclose them to clients; and (iii) take reasonable steps to mitigate the effects of such conflicts of
interests on its clients.
Dupree Financial Group makes every reasonable effort to disclose actual or potential conflicts of
interests to its clients. In addition, Dupree Financial Group considers it a best practice to
continually evaluate its potential conflicts of interest and take action or make disclosures when
appropriate. The Chief Compliance Officer will evaluate on an ongoing basis any conflicts of
interest encountered; how to best address the conflict; what mitigation, if any, is required; and
16
whether disclosure is required to its clients. The Firm considers its entire compliance program as
part of the Firm-wide integrated effort to further these goals.
In the event that Dupree Financial Group encounters what it determines to be an actual conflict of
interest in connection with a client or investment, Dupree Financial Group will take such actions
as necessary and appropriate to resolve the conflict. These actions may include disposing of the
asset giving rise to the conflict, appointing an independent fiduciary or obtaining advice from
outside counsel. There can be no assurance that all conflicts of interest will be successfully
resolved.
C.
If you or a related person invests in the same securities (or related securities, e.g.,
warrants, options or futures) that you or a related person recommends to clients, describe
your practice and discuss the conflicts of interest this presents and generally how you address
the conflicts that arise in connection with personal trading.
Personal Trading
Dupree Financial Group’s officers and employee personal trading presents potential conflicts of
interest in that an employee could make improper use of information regarding clients’ holdings
or future transactions or research paid for by the Firm.
Dupree Financial Group manages the potential conflicts of interest inherent in employee trading
by strict enforcement of its code of ethics, which includes certain pre-clearance and reporting
requirements. The Firm has adopted procedures regarding personal trading by employees that are
designed to prevent abuses that could occur as a result of the potential conflict of interest involved
in such personal trading. For example, the code of ethics requires employees to submit on a
periodic basis, personal securities transactions and holdings reports for review by the Chief
Compliance Officer.
Dupree Financial Group’s employees are permitted to make securities transactions in their
personal accounts, subject to certain limitations. In particular, Dupree Financial Group employees
are not to knowingly trade for their own accounts in a manner that is detrimental to clients and
they are not to profit from their knowledge that clients intend to engage in particular transactions.
Dupree Financial Group purchases or sells securities for its clients which it and/or its employees
own, have owned, or may own.
D.
If you or a related person recommends securities to clients, or buys or sells securities
for client accounts, at or about the same time that you or a related person buys or sells the
same securities for your own (or the related person’s own) account, describe your practice
and discuss the conflicts of interest it presents. Describe generally how you address conflicts
that arise.
Please refer to Items 11.A, 11.B, and 11.C.
17
Item 12 – Brokerage Practices
A.
Describe the factors that you consider in selecting or recommending broker-dealers
for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
1. Research and Other Soft Dollar Benefits. If you receive research or other products or
services other than execution from a broker-dealer or a third party in connection with
client securities transactions (“soft dollar benefits”), disclose your practices and
discuss the conflicts of interest they create.
a. Explain that when you use client brokerage commissions (or markups or
markdowns) to obtain research or other products or services, you receive a benefit
because you do not have to produce or pay for the research, products or services.
b. Disclose that you may have an incentive to select or recommend a broker-dealer
based on your interest in receiving the research or other products or services,
rather than on your clients’ interest in receiving most favorable execution.
c. If you may cause clients to pay commissions (or markups or markdowns) higher
than those charged by other broker-dealers in return for soft dollar benefits
(known as paying-up), disclose this fact.
d. Disclose whether you use soft dollar benefits to service all of your clients’ accounts
or only those that paid for the benefits. Disclose whether you seek to allocate soft
dollar benefits to client accounts proportionately to the soft dollar credits the
accounts generate.
e. Describe the types of products and services you or any of your related persons
acquired with client brokerage commissions (or markups or markdowns) within
your last fiscal year.
f. Explain the procedures you used during your last fiscal year to direct client
transactions to a particular broker-dealer in return for soft dollar benefits you
received.
Dupree Financial Group has the authority to determine which broker, dealer or custodian to use
for client accounts. We consider the following factors in recommending brokers, dealers or
custodians to a client: the entity’s financial strength, reputation, execution, pricing and service; the
quality of the investment research; our prior experience with the entity; and any special execution,
clearance, settlement, and custody or recordkeeping capabilities. As a result, we do not select the
broker or entity with the lowest commission rate. In selecting brokers to execute transactions, we
18
need not solicit competitive bids and do not have an obligation to seek the lowest available
commission. In return for effecting securities transactions through certain brokers, dealers or
custodians, Dupree Financial Group does receive certain support services that assists it and its
representatives in the investment decision-making process for a client.
Fidelity is an unaffiliated SEC-registered broker-dealer and FINRA member. Fidelity offers to
independent investment advisers’ services which include custody of securities, trade execution,
clearance and settlement of transactions. Dupree Financial Group receives some benefits from
Fidelity through its participation in the program (see disclosures under Item 14 for more
information). Dupree Financial Group and/or our representatives may receive benefits such as
assistance with conferences and educational meetings from product sponsors.
Charles Schwab is an unaffiliated SEC-registered broker-dealer and FINRA member. Charles
Schwab offers to independent investment advisers’ services which include custody of securities,
trade execution, clearance and settlement of transactions. Dupree Financial Group receives some
benefits from Charles Schwab through its participation in the program (see disclosures under Item
14 for more information). Dupree Financial Group and/or our representatives may receive benefits
such as assistance with conferences and educational meetings from product sponsors.
Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits
an investment manager to use commissions or “soft dollars” to obtain research and brokerage
services that provide lawful and appropriate assistance in the investment decision-making process.
Dupree Financial Group will limit the use of “soft dollars” to obtain research and brokerage
services to services that constitute research and brokerage within the meaning of Section 28(e).
Research and brokerage services within Section 28(e) may include, but are not limited to: research
reports (including market research); certain financial newsletters and trade journals; software
providing analysis of securities portfolios; analyses concerning specific securities, companies or
sectors; and data services (including services providing market data, company financial data and
economic data); services related to the execution, clearing and settlement of securities transactions
and functions incidental thereto (i.e., connectivity services between an investment manager and a
broker-dealer); and trading software operated by a broker-dealer to route orders.
Research and brokerage services obtained by the use of commissions arising from client
transactions are used by Dupree Financial Group in other investment activities and thus clients
may not always be the direct or indirect beneficiary of the research or brokerage services provided.
2. Brokerage for Client Referrals. If you consider, in selecting or recommending broker-
dealers, whether you or a related person receives client referrals from a broker-dealer
or third party, disclose this practice and discuss the conflicts of interest it creates.
a. Disclose that you may have an incentive to select or recommend a broker-dealer
based on your interest in receiving client referrals, rather than on your clients’
interest in receiving most favorable execution.
19
b. Explain the procedures you used during your last fiscal year to direct client
transactions to a particular broker-dealer in return for client referrals.
Dupree Financial Group has not entered into any such referral arrangements.
3. Directed Brokerage.
a. If you routinely recommend, request or require that a client direct you to execute
transactions through a specified broker-dealer, describe your practice or policy.
Explain that not all advisers require their clients to direct brokerage. If you and
the broker-dealer are affiliates or have another economic relationship that creates
a material conflict of interest, describe the relationship and discuss the conflicts
of interest it presents. Explain that by directing brokerage you may be unable to
achieve most favorable execution of client transactions, and that this practice may
cost clients more money.
b. If you permit a client to direct brokerage, describe your practice. If applicable,
explain that you may be unable to achieve most favorable execution of client
transactions. Explain that directing brokerage may cost clients more money. For
example, in a directed brokerage account, the client may pay higher brokerage
commissions because you may not be able to aggregate orders to reduce
transaction costs, or the client may receive less favorable prices.
When applicable, a client can direct Dupree Financial Group to use a particular broker to execute
some or all transactions for such client’s account, subject to Dupree Financial Group’s right to
decline and/or terminate the engagement. In the event a client directs Dupree Financial Group to
use a particular broker, the client has the sole responsibility for negotiating commission rates and
other transactions costs with the directed broker and will not be included in any aggregate trades
placed, if applicable. As a result, a client directing brokerage may pay higher commissions or
other transaction costs or greater spreads, and thus, receive less favorable net prices, on
transactions for the account that would otherwise be the case and a most favorable execution may
not be obtained.
B.
Discuss whether and under what conditions you aggregate the purchase or sale of
securities for various client accounts. If you do not aggregate orders when you have the
opportunity to do so, explain your practice and describe the costs to clients of not
aggregating.
Generally, Dupree Financial Group will aggregate orders with respect to a security if such
aggregation is consistent with achieving best execution for the various client accounts. When
orders are aggregated, each participating account receives the average share price for the
transaction and bears the standard brokerages fees, as applicable, based upon each account’s
20
participation in the transaction. Block trading may also include proprietary or related accounts of
Dupree Financial Group.
In some cases, based upon the size and holdings of a clients account or any clients’ specific
preferences, clients may not be included in an aggregate order. Accordingly, in some instances,
different clients may receive different prices on securities transactions executed at different date
and time.
Item 13 – Review of Accounts
A.
Indicate whether you periodically review client accounts or financial plans. If you do,
describe the frequency and nature of the review, and the titles of the supervised persons who
conduct the review.
Dupree Financial Group periodically reviews client accounts. Reviews of accounts are performed
by the firm’s Registered Investment Advisors (see Part 2B). Portfolio management accounts are
monitored on a continuous basis and are reviewed on an annual basis. Asset allocation accounts
are also reviewed on an annual basis. Account review involves discussion and analysis of the
client’s goals and objectives, overall market and economic conditions, portfolio composition,
industry composition and change in performance.
If you review client accounts on other than a periodic basis, describe the factors that
B.
trigger a review.
Account reviews on an other-than-periodic basis would occur in the event of performance
anomalies, unexpected market volatility, changes in the fundamentals of an investment or changes
in economic outlook. In addition to regular client account reviews, Dupree Financial Group review
client accounts when there is a major change in the client circumstances, such as death of a spouse
or change in investment objective or outlook.
Describe the content and indicate the frequency of regular reports you provide to
C.
Clients regarding their accounts. State whether these reports are written.
Clients should receive all written reports and confirmations of all transactions directly from the
broker-dealer or custodian for the client accounts.
Item 14 – Client Referrals and Other Compensation
A.
If someone who is not a client provides an economic benefit to you for providing
investment advice or other advisory services to your clients, generally describe the
arrangement, explain the conflicts of interest, and describe how you address the conflicts of
interest. For purposes of this Item, economic benefits include any sales awards or other
prizes.
21
As disclosed under Item 12 above, Dupree Financial Group participates in institutional customer
programs offered by Fidelity and Charles Schwab, and Dupree Financial Group utilizes both for
custody and brokerage services of its client’s accounts. There is no direct link between Dupree
Financial Group’s participation in these programs and the investment advice it gives to its clients,
although Dupree Financial Group receives economic benefits through its participation in these
programs that are typically not available to retail investors. These benefits include the following
products and services (provided without cost or at a discount): receipt of duplicate client
statements and confirmations; research related products and tools; consulting services; access to a
trading desk serving Dupree Financial Group clients; access to block trading (which provides the
ability to aggregate securities transactions for execution and then allocate the appropriate shares
to client accounts); the ability to have advisory fees deducted directly from client accounts; access
to an electronic communications network for client order entry and account information; access to
mutual funds with no transaction fees and to certain institutional money managers; and discounts
on compliance, marketing, research, technology, and practice management products or services
provided to Dupree Financial Group by third party vendors.
Fidelity and Charles Schwab also have paid for business consulting and professional services
received by Dupree Financial Group or its related persons. Some of the products and services
made available through the program benefit Dupree Financial Group but may not directly benefit
its client accounts. These products or services assist Dupree Financial Group in managing and
administering client accounts. Other services made available are intended to help Dupree Financial
Group manage and further develop its business enterprise. The benefits received by Dupree
Financial Group or its personnel through participation in the program do not depend on the amount
of brokerage transactions directed to either custodian.
As part of its fiduciary duties to clients, Dupree Financial Group endeavors at all times to put the
interests of its clients first. Clients should be aware, however, that the receipt of benefits by Dupree
Financial Group or its related persons creates a potential conflict of interest may be indirectly
influence Dupree Financial Group’s choice for custody and brokerage services.
B.
If you or a related person directly or indirectly compensates any person who is not
your supervised person for client referrals, describe the arrangement and the compensation.
Under certain circumstances, investment advisers, like Dupree Financial Group, may compensate
other parties for having referred clients or potential clients. These sorts of arrangements are
generally referred to as solicitor arrangements. Dupree Financial Group does not currently
participate in any solicitor arrangement(s), but reserves the right to do so at its discretion.
Item 15 – Custody
If you have custody of client funds or securities and a qualified custodian sends quarterly, or
more frequent, account statements directly to your clients, explain that clients will receive
22
account statements from the broker-dealer, bank or other qualified custodian and that
clients should carefully review those statements. If your clients also receive account
statements from you, your explanation must include a statement urging clients to compare
the account statements they receive from the qualified custodian with those they receive from
you.
Dupree Financial Group does not have custody over client accounts or the assets held within the
account. For those accounts where a client has authorized the custodian to debit fees for advisory
services, the custodian or an independent third party, who is not related to Dupree Financial Group,
makes all fee calculations and deducts the fees from the client’s account; for such clients, Dupree
Financial Group does not calculate the client’s advisory fee and does not send a bill to the client. For
clients where the custodian does not debit advisory fees directly, Dupree Financial Group bills the
client directly for the advisory services fees and the client remits payment to the Firm. These bills are
also calculated as specified above.
In addition, Dupree Financial Group does not maintain physical custody of client assets, but use
various custodians, currently Fidelity or Charles Schwab, to hold client securities as qualified
custodians. Further, we do not accept additional contributions of capital ourselves but direct our
clients either to send their capital contributions directly to the appropriate qualified custodian or
to make their contributions payable to the custodian for the benefit of their respective account. In
the latter case, we transfer the client’s funds directly to Fidelity or Charles Schwab on the same
business day of receipt.
Each client should receive account statements directly from the qualified custodian on at least a
quarterly basis and should carefully review those statements for accuracy and completeness.
Item 16 – Investment Discretion
If you accept discretionary authority to manage securities accounts on behalf of clients,
disclose this fact and describe any limitations clients may (or customarily do) place on this
authority. Describe the procedures you follow before you assume this authority (e.g.,
execution of a power of attorney).
Dupree Financial Group’s investment management services are generally provided on a
discretionary basis. At this time, we do not provide investment management services on a non-
discretionary basis to any clients. Where Dupree Financial Group has discretionary management
authority, Dupree Financial Group will be authorized to determine the securities to be bought or
sold for the client’s account(s), the amount of securities to be bought or sold, the timing of
securities transactions and the broker or dealer to be used to execute client securities transactions.
Dupree Financial Group’s investment advisory services agreement, and the agreement between
the client and the custodian/broker-dealer for the account, grant discretionary authority to Dupree
Financial Group. Once a client executes an investment management agreement or similar
document with Dupree Financial Group, the Firm is not required to contact the client prior to
23
transacting any business, unless otherwise specified. The client’s written agreement with the
custodian also grants a limited power of attorney to Dupree Financial Group to effect transactions
in the client’s custodial account.
Each client may request reasonable limitations be placed on Dupree Financial Group’s
discretionary authority, such as securities or market-sector based limitations. Any such limitations
shall be presented to Dupree Financial Group in writing, and Dupree Financial Group will review
and respond to any such requests on a case-by-case basis.
Item 17 – Voting Client Securities
A.
If you have, or will accept, authority to vote client securities, briefly describe your
voting policies and procedures, including those adopted pursuant to SEC Rule 206(4)-6.
Describe whether (and, if so, how) your clients can direct your vote in a particular
solicitation. Describe how you address conflicts of interest between you and your clients with
respect to voting their securities. Describe how clients may obtain information from you
about how you voted their securities. Explain to clients that they may obtain a copy of your
proxy voting policies and procedures upon request.
Dupree Financial Group does not vote proxies for clients.
B.
If you do not have authority to vote client securities, disclose this fact. Explain
whether clients will receive their proxies or other solicitations directly from their custodian
or a transfer agent or from you, and discuss whether (and, if so, how) clients can contact you
with questions about a particular solicitation.
Dupree Financial Group’s clients maintain exclusive responsibility for: (1) directing the manner
in which proxies solicited by issuers of securities beneficially owned by the client shall be voted;
and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy
proceedings or other events pertaining to the client’s investment assets. The client shall instruct
each custodian of the assets to forward to the client copies of all proxies and shareholder
communications relating to the client’s investment assets.
24
Item 18 – Financial Information
If you require or solicit prepayment of more than $1,200 in fees per client, six months
A.
or more in advance, include a balance sheet for your most recent fiscal year.
1. The balance sheet must be prepared in accordance with generally accepted
accounting principles, audited by an
independent public accountant, and
accompanied by a note stating the principles used to prepare it, the basis of securities
included, and any other explanations required for clarity.
2. Show parenthetically the market or fair value of securities included at cost.
3. Qualifications of the independent public accountant and any accompanying
independent public accountant’s report must conform to Article 2 of SEC Regulation
S-X.
Dupree Financial Group does not require prepayment of more than $1,200 in fees per client, six
months or more in advance.
B.
If you have discretionary authority or custody of client funds or securities, or you
require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance, disclose any financial condition that is reasonably likely to impair your ability to
meet contractual commitments to clients.
Dupree Financial Group has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to investors.
If you have been the subject of a bankruptcy petition at any time during the past ten
C.
years, disclose this fact, the date the petition was first brought, and the current status.
Dupree Financial Group has not been the subject of a bankruptcy proceeding.
25
Form ADV Part 2B: BROCHURE SUPPLEMENT
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
compliance@dupreefinancial.com
www.dupreefinancial.com
April 17, 2026
This brochure supplement provides information about employees of Dupree Financial Group, LLC
(“Dupree Financial Group” or the “Firm”) that supplements Dupree Financial Group’s Brochure.
Please contact D. Hudson Kemp, the Firm’s Chief Compliance Officer, at (859) 233-0400 or
compliance@dupreefinancial.com if you did not receive Dupree Financial Group’s Brochure or if
you have any questions about the contents of this Brochure Supplement.
Additional information about Dupree Financial Group is available on the SEC’s website at
www.adviserinfo.sec.gov.
1
Thomas P. Dupree
Year of Birth: 1956
Founder and Chief Executive Officer
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Dupree received a B. A. in English from the University of the South. Since 2003, Mr. Dupree
has been the Founder and Chief Executive Officer of Dupree Financial Group.
Item 3 – Disciplinary Information
Mr. Dupree has no legal or disciplinary event, proceeding or action on his record.
Item 4 – Other Business Activities
Mr. Dupree is not actively engaged in any outside business activities or occupation for
compensation that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Mr. Dupree does not receive an economic benefit for providing advisory services, other than the
regular compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Dupree is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief
Compliance Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400.
2
Michael A. Johnson, CFP®
Year of Birth: 1984
Investment Adviser Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Johnson received a B. B. A. in Finance and Management from the University of Kentucky.
Since 2006, Mr. Johnson has been an investment adviser representative of Dupree Financial Group.
Item 3 – Disciplinary Information
Mr. Johnson has never been the object of any legal or disciplinary event, proceeding or action.
Item 4 – Other Business Activities
Mr. Johnson is not actively engaged in any outside business activities or occupation for
compensation that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Mr. Johnson does not receive an economic benefit for providing advisory services, other than the
regular compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Johnson is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief
Compliance Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400.
3
Denise M. Rodriguez
Year of Birth: 1987
Investment Advisor Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Ms. Rodriguez received her BA in Mathematics and Physics from Smith College, Northampton MA.
Prior to joining Dupree Financial Group, Ms. Rodriguez worked as a Market Operations Manager for
Peoples Exchange Bank. She joined Dupree Financial Group in September of 2023.
Item 3 – Disciplinary Information
Ms. Rodriguez has never been the object of any legal or disciplinary event, proceeding or action.
Item 4 – Other Business Activities
Ms. Rodriguez is not actively engaged in any outside business activities or occupation for compensation
that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Ms. Rodriguez does not receive an economic benefit for providing advisory services, other than the
regular compensation paid by Dupree Financial Group.
Item 6 – Supervision
Ms. Rodriguez is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief Compliance
Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400.
4
Thomas Clark Dupree, NSSA®
Year of Birth: 1996
Investment Advisor Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Dupree received his BA in Finance from Samford University in Birmingham, AL. Mr. Dupree
worked as a Financial Advisor for Dupree Financial Group starting August 2020. He moved to Phoenix,
AZ in May 2021 to accept a position with the Arizona Coyotes. He held that position until January of
2022. He then joined Strategy Financial Group in March of 2022. He left that firm in January 2024 and
returned to Dupree Financial Group in February 2024, where he remains today.
Item 3 – Disciplinary Information
Mr. Dupree has never been the object of any legal or disciplinary event, proceeding or action.
Item 4 – Other Business Activities
Mr. Dupree is actively engaged in an outside business activity or occupation. He is the host of the In
the Jar Podcast, a sports podcast, available on YouTube, Spotify, and other podcast streaming platforms.
Mr. Dupree also participates in other non-finance related podcast shows from time to time. No income
had been earned from these activities.
Item 5 – Additional Compensation
Mr. Dupree does not receive an economic benefit for providing advisory services, other than the regular
compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Dupree is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief Compliance
Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400.
5
James P. Dupree,
Year of Birth: 1999
Investment Advisor Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Dupree has no prior business experience and is continuing his college education on a part-time
basis. He joined Dupree Financial Group in February of 2025.
Item 3 – Disciplinary Information
Mr. Dupree has never been the object of any legal or disciplinary event, proceeding or action.
Item 4 – Other Business Activities
Mr. Dupree is not actively engaged in any outside business activities or occupation for compensation
that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Mr. Dupree does not receive an economic benefit for providing advisory services, other than the regular
compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Dupree is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief Compliance
Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400.
6
D. Hudson Kemp
Year of Birth: 1994
Chief Compliance Officer, Investment Advisor Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Kemp is actively pursuing a college education at Kentucky Community and Technical College in
Lexington, KY. He joined Dupree Financial Group in June 2025. Prior to joining Dupree Financial
Group, Mr. Kemp worked as a National Account Executive for iHeart Media, also in Lexington, KY.
Mr. Kemp has garnered vast business ownership and management experience in the years prior to
joining iHeart Media.
Item 3 – Disciplinary Information
Mr. Kemp is the subject of 2 disciplinary concerns. A Federal Tax Lien from 2023, and a Federal Tax
Lien from 2024. Both debts originated from 1099 income in 2021 and 2022. Once the debt was realized,
the income had been invested in another business. Both debts are in active repayment. Payoff should
occur in 2026.
Item 4 – Other Business Activities
Mr. Kemp is not actively engaged in any outside business activities or occupation for compensation
that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Mr. Kemp does not receive an economic benefit for providing advisory services, other than the regular
compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Kemp is supervised on compliance matters by Thomas P. Dupree, the Firm’s Founder and Chief
Executive Officer, who may be reached at tdupree@dupreefinancial.com or (859) 233-0400.
7
Michael Maloof Dawahare
Year of Birth: 1961
Title: Investment Advisor Representative
Dupree Financial Group, LLC
237 East Main Street
Lexington, Kentucky 40507
(859) 233-0400
Item 2 – Educational Background and Business Experience
Mr. Dawahare graduated with a BA in History from Tulane University in 1983, and an MBA From
Duke University in 1987
Item 3 – Disciplinary Information
Mr. Dawahare has no disciplinary events.
Item 4 – Other Business Activities
Mr. Dawahare is not actively engaged in any outside business activities or occupation for compensation
that could potentially create a conflict of interest with clients.
Item 5 – Additional Compensation
Mr. Dawahare does not receive an economic benefit for providing advisory services, other than the
regular compensation paid by Dupree Financial Group.
Item 6 – Supervision
Mr. Dawahare is supervised on compliance matters by D. Hudson Kemp, the Firm’s Chief Compliance
Officer, who may be reached at compliance@dupreefinancial.com or (859) 233-0400
8