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Item 1: Cover Page
Kenora Financial, LLC
CRD No. 123524
information
in
1295 Rand Road, Suite 100
(
Des Plaines, IL 60016
847) 257-7200
This Disclosure Brochure provides information about the
qualifications and business practices of Kenora Financial,
LLC (formerly known as INVESCO, LLC). If you have any
questions about the contents of this Disclosure Brochure,
please contact us by phone at (847) 257-7200, by email at
invest@KenoraFinancial.com, or visit our website at
www.KenoraFinancial.com. The
this
Disclosure Brochure has not been approved or verified by
the United States Securities and Exchange Commission or
by any state securities authority.
www.KenoraFinancial.com
invest@KenoraFinancial.com
Disclosure Brochure
Kenora Financial, LLC is a registered investment adviser.
Registration as an investment adviser does not imply any
level of skill or training.
Form ADV Part 2A
January 1, 2026
Additional information about Kenora Financial, LLC is also
available on the SEC’s website at www.adviserinfo.sec.gov
by conducting a Firm search using our CRD number shown
above.
Item 2: Material Changes
We will promptly update this Disclosure Brochure when
material changes occur. Material changes are summarized
in this section.
We initially provide you with a copy of our Disclosure
Brochure when we enter into an agreement with you. On an
annual basis, we will provide you with a Summary of
Material Changes within 120 days of our fiscal year end. In
the alternative, we may choose to provide you with a
complete copy of our Disclosure Brochure.
•
Since our last annual update of March 14, 2025, we have
made the following material change:
Effective January 1, 2026, our name has been
changed from INVESCO, LLC to Kenora Financial,
LLC to modernize and rebrand the firm’s identity.
No change has been made to the firm’s ownership,
management, services, or regulatory status.
We have made minor edits to correct grammatical or
typographical errors, or to provide additional information
or clarification. We do not consider these material changes.
You may request a current copy of our Disclosure Brochure
Item 1: Cover Page
at any time without charge by contacting us, or by visiting
the SEC’s website, as described in
above.
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Disclosure Brochure
January 1, 2026
Item 3: Table of Contents
Disclosure Brochure .............................................................................. 1
Description of Advisory Services Offered
Kenora specializes in providing investment guidance for
people interested in achieving financial independence. Our
financial services include financial planning, investment
counseling, retirement planning, estate planning, tax
planning, managing customized investment portfolios and
financial education.
Client Tailored Services and Client Imposed
Financial Planning/Investment Counseling Services
Restrictions
•
Our firm's success in helping clients realize financial
security is based on three basic principles:
•
Item 1: Cover Page ...................................................................................................... 1
Item 2: Material Changes ......................................................................................... 1
Item 3: Table of Contents ......................................................................................... 2
Item 4: Advisory Business ....................................................................................... 2
Item 5: Fees and Compensation ............................................................................ 5
Item 6: Performance-Based Fees and Side-By-Side Management ........... 5
Item 7: Types of Clients ............................................................................................ 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ... 6
Item 9: Disciplinary Information .......................................................................... 7
Item 10: Other Financial Industry Activities and Affiliations .................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading ................................................................................................ 8
Item 12: Brokerage Practices ................................................................................. 9
Item 13: Review of Accounts ............................................................................... 10
Item 14: Client Referrals and Other Compensation ................................... 10
Item 15: Custody ...................................................................................................... 11
Item 16: Investment Discretion ......................................................................... 11
Item 17: Voting Client Securities ....................................................................... 11
Brochure Supplement ........................................................................ 12
Item 18: Financial Information .......................................................................... 11
their
that
to
include
•
Keith B. Nyborg (CRD No. 4602314) ................................................................ 12
Ryan McNeilly (CRD No. 4507434) ................................................................... 13
Paul N. Linzer (CRD No. 4602316) .................................................................... 13
Privacy Policy ........................................................................................ 15
Nilu Judge (CRD No. 7196985) ........................................................................... 14
Business Continuity Plan Summary .............................................. 17
We take our fiduciary duty to clients very seriously.
We help them make decisions to their benefit, not
ours.
Clients should be personally committed
financial plans
following
managing savings and investments.
We believe in educating our clients on different
types of investments, so they fully understand what
is being recommended for them and can make their
own decisions.
Item 4: Advisory Business
Each of our clients has individual personal and financial
needs and goals; we listen to each and customize our
investment advice accordingly. Some have substantial
savings and investments. Other clients need to save and
invest more income from their jobs or businesses to reach a
secure retirement position. We're large enough to help our
clients accomplish their financial objectives, but small
Retirement Planning
enough to know everyone personally.
typically
Our retirement planning services
include
projected retirement cash flows based on financial assets
and expected income. For situations where projections
show
less than the desired results, we may make
recommendations that include showing you the impact on
those projections by making changes in certain variables
(i.e., working longer, savings more, spending less, taking
more risk with investments).
Firm Overview
Kenora Financial, LLC (“Kenora”) is an Illinois-based
company formed in 1980 under the name INVESCO, LLC.
Effective January 1, 2026, the firm changed its name to
Kenora Financial, LLC to modernize and rebrand the firm’s
identity. The firm is not a subsidiary of, nor does it control
another entity. The firm was registered as an investment
adviser in Illinois in 1999, and then with the SEC in 2018.
Keith Nyborg, Ryan McNeilly, Paul Linzer, and Nilu Judge
are the firm's managing members. Information regarding
their educational background, business experience,
qualifications, and other important disclosures are found in
the Brochure Supplement (Form ADV Part 2B) attached to
this document.
We hold ourselves to a fiduciary standard, which means our
firm and its associates will act in the utmost good faith and
perform in a manner believed to be in the best interest of
our clients. As fiduciaries, we owe our clients a duty to act
solely in the best interests of each client, which includes, but
it not limited to, a duty of care, loyalty, obedience, and
utmost good faith.
If you are near retirement or already retired, advice may be
given on appropriate distribution strategies to minimize
the likelihood of running out of money or having to
adversely alter spending during your retirement years.
Retirement planning uses certain assumptions and there is
no guarantee that such assumptions will be correct,
meaning that actual retirement cash flows may be more or
less than project cash flows.
When we provide investment advice to you regarding your
retirement plan account or individual retirement account,
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Disclosure Brochure
January 1, 2026
ways for you to minimize or avoid future estate taxes by
implementing appropriate estate planning strategies such
as the use of wills, living trusts, charitable remainder trusts
or family limited partnerships.
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 our interests ahead of yours.
•
Under this special rule’s provisions, we must:
recommendations
•
(give
•
We always recommend that you consult with a qualified
attorney when you initiate, update, or complete estate
planning activities. We may provide you with contact
information for attorneys who specialize in estate planning
when you wish to hire an attorney for such purposes. We do
not receive cash compensation for providing this contact
information, but we may receive reciprocal referrals from
such attorneys. From time to time, we will participate in
meetings or phone calls between you and your attorney
with your approval or request.
•
We strive to ensure clients' families avoid financial
disagreements and hardships upon their death, to minimize
their estate tax, and to name a legal guardian in case of
Tax Planning
incompetence.
•
•
Meet a professional standard of care when making
investment
(give prudent
advice);
Never put our financial interests ahead of yours
when making recommendations
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 (see
PTE 2020-02 on client 401(k) rollovers in our
Investment Adviser Agreement);
Charge no more than is reasonable for our services;
and
Give you basic information about conflicts of
interest.
Ryan McNeilly & Associates, CPAs is a firm owned and
operated by Supervised Persons of our firm, and that shares
office space and clients with Kenora. While Kenora does not
offer tax preparation, we can work with your tax
professional or Ryan McNeilly & Associates, CPAs to assist
in structuring your financial life to identify tax-saving
opportunities.
You have options regarding retirement account rollovers.
When you leave an employer, you typically have four
options regarding assets in your existing retirement plan.
•
You may:
•
•
•
roll over the assets to your new employer’s plan, if
available, and rollovers are permitted;
leave the assets in your former employer’s plan, if
permitted;
roll over the assets to an Individual Retirement
Account (IRA); or
cash out the account value (tax consequences
generally apply).
Clients may, but are not required to, engage Ryan McNeilly
& Associates, CPAs. If you elect to engage Ryan McNeilly &
Associates, CPAs, fees for tax services are in addition to our
advisory services. If we refer you to Ryan McNeilly &
Associates, CPAs, it presents a conflict of interest because
Supervised Persons associated with Kenora will receive
economic benefit from such referral. You should also be
aware that Kenora and Ryan McNeilly & Associates, CPAs,
will share information regarding mutual clients to help
facilitate the coordination of services provided on your
behalf.
If our firm recommends that you roll over retirement assets
into an account
that we will manage, such a
recommendation creates a conflict of interest because our
firm will earn fees as a result of the rollover. As a Fiduciary
Advisor, we mitigate this conflict of interest by disclosing it
and ensuring that a recommendation to roll over retirement
savings is in your best interest.
Ryan McNeilly & Associates, CPAs helps clients plan their
financial decisions to minimize taxes (such as deciding how
large an IRA distribution should be). They file tax returns
not only for individuals, but also businesses, estates and
non-profits organizations. Their expertise helps to ensure
that clients minimize their tax burdens.
You are not under any obligation to roll over retirement
Estate Planning
savings to an account managed by our firm.
This usually includes an analysis of your exposure to estate
taxes and your current estate plan, which may include
whether you have a will, powers of attorney, trusts and
other related documents. Our advice also typically includes
Advice may also include ways to minimize current and
future income taxes as a part of your overall financial
planning picture. For example, recommendations on which
type of account(s) or specific investments should be owned
based in part on their “tax efficiency,” with consideration
that there is always a possibility of future changes to
federal, state or local tax laws, and rates that may impact
your situation.
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Disclosure Brochure
January 1, 2026
Customized Investment Portfolios
retirement strategies, or various other economic and
investment topics.
individualized
•
Based on your financial situation, Kenora will create and
manage a Customized Investment Portfolio of stocks.
Customized investment portfolios are sometimes referred
to as Separately Managed Accounts (SMAs). There are
several advantages of having a separately managed
investment account. These include:
Our seminars are educational in nature and do not involve
the sale of insurance or investment products. Information
presented will not be based on any one person's need nor
do we provide
investment advice to
General information
attendees during our general sessions.
•
•
Appropriate diversification with individual stocks
in different industries, and a strong belief in
efficient markets.
Risk is tailored to each client's specific needs, based
on information you provide to us.
Substantial tax benefits available, such as capital
losses in non-IRA type accounts, deferred capital
gains and forgiveness of tax upon death.
Kenora does not provide legal, accounting, or insurance
services. With your consent, we may work with your other
advisers (attorneys, accountant, etc.) to assist with
coordination and implementation of accepted strategies.
You should be aware that these other advisers may charge
you separately for their services and these fees may be in
addition to our advisory fees.
•
We rarely recommend mutual funds and annuities for the
following reasons:
Kenora will use its best judgment and good faith effort in
rendering its services.
•
Kenora cannot warrant or guarantee any particular level of
account performance or that your account will be profitable
over time. Past performance is not necessarily indicative of
future results.
•
•
Mutual Funds have a very poor history of
promoting their investors' interests; hence low
rates of return.
Mutual Fund and Annuity fees are unacceptably
high; especially costs they do not report.
Funds are not customized to meet client objectives.
Funds cannot pass through capital losses to
minimize taxes paid by Fundholders.
Kenora and its Supervised Persons are not responsible for
any loss, claim, cost, or liability incurred by reason of any
independent act or omission by any broker-dealer,
custodian, or other third parties, unless such loss, claim,
cost, or liability was due to our instructions to the third
party, or if we were involved in a violation of applicable
laws or breach of our fiduciary duty.
trading
support
for
Notwithstanding the preceding, nothing within our client
agreement is intended to diminish in any way our fiduciary
obligation to act in your best interest or in any way limit or
waive your rights under federal or state securities laws or
the rules promulgated pursuant to those laws.
Our fees are based on the value of our clients' investment
portfolios. Schwab Institutional, a division of Charles
Schwab & Co., Inc., is a leading provider of custodial,
operational and
independent
investment advisers. Since 1987, Schwab Institutional has
supported independent investment advisers by offering
support and services to help grow their businesses and help
their clients. Working with Schwab enables Kenora to help
investors reach their financial goals.
Wrap Fee Programs
Kenora does not participate in or sponsor wrap fee
investment management programs.
We also manage tax-deferred IRA, Roth, 401(k), 403 (b),
SEP and Keough accounts and pension plans, using a
diversified approach to meet client investment objectives
and risk levels. Fees for these accounts are even lower than
Financial Education
taxable investment portfolios.
Client Assets Under Management
As of December 31, 2024, our firm had approximately
$269,662,450 of reportable client assets directly under its
management on a discretionary basis.
Kenora is committed to educating people on personal
financial management and investing. We offer classes on
investing in stocks through the adult education program at
local schools. We are pleased we have been able to help so
many people.
We also provide free educational seminars on an “as
announced” basis for groups desiring general advice on
investments and personal finance. Topics may include
issues related to financial management, financial planning,
Select Investors Fund
In addition to customized client portfolios, we also manage
the Select Investors Fund, a private pooled investment
vehicle which invests in publicly traded equity securities.
The fund is currently closed to new investors. We receive a
portfolio management fee based on a percentage of fund
assets under management.
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Disclosure Brochure
January 1, 2026
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
Our advisory fee includes financial planning, investment
counseling, retirement planning, and tax planning services.
Kenora does not charge a fee for financial education
services.
Management fees shall be prorated for capital contributions
or withdrawals made during the applicable calendar
quarter (with the exception of de minimis contribution).
Accounts opened in mid-quarter will be assessed at a pro-
rated management fee. Fees are not negotiable. Any
investment advisory contract may be terminated by either
party at any time with five days' notice. In our discretion,
we may terminate services for nonpayment of fees upon
written notice to the client.
The specific manner in which fees are charged by Kenora is
established in a client's written investment advisory
agreement. The annual fee for our customized investment
portfolio management services will be charged as a
percentage of assets under management according to the
schedule below.
Brokerage
IRA
Assets Under
Management
$50,000 to $100,000
2.00%
1.00%
$ 100,000 to $ 500,000
1.50%
0.80%
$ 500,000 to $ 2,000,000
1.25%
0.60%
Other Types of Fees and Expenses
fees are exclusive of brokerage commissions,
Our
transaction fees, and other related costs and expenses. You
may incur certain charges imposed by custodians, brokers,
and other third parties such as custodial fees, deferred sales
charges, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and
securities transactions. Such charges, fees and commissions
are exclusive of and in addition to our fee, and we do not
receive any portion of these commissions, fees, and costs.
Over $ 2,000,000
1.00%
0.40%
Item 12 further describes the factors that we consider in
selecting or recommending broker-dealers and custodians
for your accounts and determining the reasonableness of
their compensation (e.g., commissions).
An Initial Set-Up Charge of $500.00 will be retroactively
charged to each brokerage account if closed during the first
twelve months following the effective date of the advisory
agreement.
de minimis
We do not accept 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
Fees are based on the market value of your assets under
pro rata
management as of the close of business on the last business
day of each calendar quarter, and adjusted on a
basis for capital contributions or withdrawals made during
contributions).
the calendar quarter (except for
We do not charge performance-based fees, which are fees
based on a share of capital gains in your account. In
addition, we do not perform side-by-side management,
which refers to the practice of simultaneously managing
accounts that pay performance-based fees (such as a hedge
fund) and those that do not.
Item 7: Types of Clients
We may provide our services to a variety of client types:
•
•
•
Our fees are payable quarterly, in arrears, usually within
thirty (30) days following the end of the quarter for which
said fees will be incurred. Our clients authorize the account
custodian to debit their client account for the amount of our
investment advisory fee. At the inception of the relationship
and each quarter thereafter, we will notify your custodian
of the amount of the fee due and payable to us through our
fee schedule and contract. The custodian does not validate
or check our fee, its calculation or the assets on which the
fee is based. They will deduct the fee from your account(s)
or, if you have more than one account, from the account you
have designated to pay our advisory fees. In limited
situations we may provide an alternate payment method.
•
•
Individual, families;
Trusts and estates;
Endowments, foundations, and other charitable
organizations;
Corporations and other business entities; and
Pension and profit-sharing plans.
initial
investment
is $150,000
for
The minimum
management of accounts.
Each month, you will receive a statement directly from your
custodian showing all transactions, positions and credits
into or debits from your account; the statements after the
quarter-end will reflect these transactions, including the
advisory fee paid by you to us. We encourage you to
promptly review all account statements to confirm the
accuracy of the fee deductions, and immediately notify us of
any questions or concerns.
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Disclosure Brochure
January 1, 2026
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
income
those who are very risk tolerant, who have a
significant guaranteed
(pensions or
annuities), or with a long time horizon before their
• Moderately Aggressive:
portfolio must be tapped.
Generally suitable
Methods of Analysis and Investment Strategies
When we provide investment advice, we will first gather
and consider several factors, including
for
the possibility of
risk
• Moderately Conservative:
for
investors between the ages of 50-60, who are still
in the accumulation phase but moving closer to
retirement age; or for those who are willing to take
some
capital
improvement.
•
•
•
•
•
•
current financial situation;
current and long-term needs;
investment goals and objectives,
level of investment knowledge;
tolerance and appetite for risk; and
restrictions, if any, on the management of your
portfolio.
Generally suitable for
investors between the ages of 60-70, who are
concerned with capital preservation but want or
need to see some capital appreciation in their
• Conservative:
portfolio.
Investors over 70 or those with a
lower risk tolerance who must preserve assets
while still managing inflation.
believe
our
strategies
and
Kenora employs an investment philosophy emphasizing
portfolio management that is custom tailored to the needs
of each client. We begin the investment process by carefully
listening to the client and gaining a thorough understanding
of the client's unique goals, risk tolerance, time horizon, and
other circumstances. We then determine an appropriate
risk level with the client based on those understandings.
With limited exceptions, Kenora rarely uses mutual funds
thereby avoiding inefficiencies and additional layers of fees.
Investment Strategy Risks
We
investment
recommendations are designed to produce the appropriate
potential return for the given level of risk; however, we
cannot guarantee that an investment objective or planning
goal will be achieved. As an investor you must be able to
bear the risk of loss that is associated with your account,
Investing in securities involves risk of loss that clients
which may include the loss of some or all of your principal.
should be prepared to bear.
Because our services are based on information you provide
us regarding your financial circumstances, it is important
that you provide accurate information, and notify us of any
significant changes to your financial circumstances, so that
we can adjust your investment strategy if necessary.
Risk is a measure of variation of returns around the mean
average return. Low risk means little variation; higher
variation is more risk.
into
the 23
largest
Risk is mathematically defined. Zero risk is that available on
30-day treasury bills (no variation), while one beta of risk
is the average deviation of all the stock prices on the New
York Exchange on a weighted basis. Since this is a
logarithmic scale, make sure you understand that two betas
of risk is ten times that of one beta risk, not twice. You will
probably go broke with a two-beta portfolio in the next
market crash.
There are three types of portfolio risk: individual company
risk; industry risk; and market risk. Remember, new public
information is the only thing that changes stock prices.
Kenora client portfolios are managed
to provide
diversification for safety plus tax advantages. We have a
strong belief in efficient markets. Our client portfolios are
mostly comprised of U.S. large- and medium cap publicly-
traded companies. We do not use foreign stocks due to
higher risk of political factors and currency fluctuations. We
industries excluding
diversify
conglomerates and real estate. We may use some corporate
bonds to lower client risk levels. We use a risk profile
questionnaire as one of the tools to determine what a
client's portfolio risk level should be. We then build a
portfolio with stocks that achieve that desired risk level.
Individual stock beta values (risk levels) are researched
using Value Line. A total of all client accounts (IRAs, Roths,
Brokerage) is viewed as one portfolio.
Although we may make use of margin in brokerage
accounts, we do not risk client assets in option or
commodity trading.
Information pertaining to only one company (CFO indicted
for instance) will affect the stock price of only that company.
Over 98% of individual company risk can be avoided by
investing in 20 unrelated companies.
• Aggressive
We do not engage in market timing, technical analysis or
charting. We have four categories of risk tolerance:
- Generally suitable
for
investing
in 23 different
investors
younger than 50 years old who are in the
accumulation phase of managing their assets; or for
Information pertaining to only one industry (digitizing
books really hurt the printing industry) will reflect the price
of all stocks in that industry. Over 98% of industry risk can
be avoided by
industries.
According to Standard and Poors there are 26 major
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Disclosure Brochure
January 1, 2026
larger companies. Small and medium cap companies may
face a greater risk of business failure, which could increase
Inflation Risk:
the volatility of your portfolio.
industries. We ignore conglomerates because they, by
definition, operate in several industries. Nor do we use real
estate, since most of our clients own enough. Then, we drop
out the smallest industries and invest in the 23 that are left.
Market risk cannot be reduced or eliminated, since market
timing does not work.
Inflation may erode the buying-power of your
investment portfolio, even if the dollar value of your
Interest Rate Risk:
investments remains the same.
consists of
industry
About 30% of portfolio risk is individual stock risk and
another 30%
risk. Proper
diversification will eliminate over 98% of these risks, which
leaves you with about 58% less risk in your portfolio.
Bond prices generally fall when interest
rates rise, and the value may fall below par value or the
principal investment. The opposite is also generally true,
bond prices generally rise when interest rates fall. In
general, fixed income securities with longer maturities are
more sensitive to these price changes. Most other
investments are also sensitive to the level and direction of
Legal or Legislative Risk:
interest rates.
You want stocks with higher risks because they have higher
expected rates of return, but you want your portfolio risk to
be much lower. With proper diversification you can have
higher risk/higher rate of return stocks while actually
lowering your portfolio risk.
Legislative changes or Court
rulings may impact the value of investments, or the
Geopolitical Risk:
securities’ claim on the issuer’s assets and finances.
The risk of financial and market loss
because of political decisions or disruptions in a particular
Catastrophic Events:
country or region.
Determining your risk level is where financial/retirement
planning comes in. If you have 20 years or more before you
will need the money, you can afford a relatively high risk
(perhaps 1.1 beta). Even if you're already retired, you can
afford higher risks if you have more money than you will
need.
If you have, or plan to have, less than the amount you'd like
for a pleasant retirement, you can't afford as much risk. If
you're 75 years old with only $300,000 in financial assets
and social security, you can't afford risky investments. You
many want a portfolio of investment grade bonds, even
though the income may not keep up with inflation.
In addition to general market risks,
investments may be subject to the risk of loss arising from
direct or indirect exposure to a number of types of
catastrophic events, such as global pandemics, natural
disasters, acts of terrorism, cyber-attacks, or network
outages. The extent and impact of any such event on
investment strategies will depend on many factors,
including the duration and scope of the event, the extent of
any governmental restrictions, the effect on the supply
chain, overall consumer confidence, and the extent of the
disruption to global and domestic markets.
Item 9: Disciplinary Information
Then, there is “psychological” risk tolerance. If you are the
type of investor who would become afraid and reduce your
portfolio risk in market downturns, you should have a much
lower portfolio risk than indicated above. You don't lose
money when the market falls; you lose if you are out of the
market when it rises. We administer a “Psychological Risk
Assessment” to each prospective client to reduce or
eliminate these situations.
General Risks
In addition to the investment strategy risks described
above, following are some general risks that apply to
Market Risk:
investments more broadly.
Neither the firm nor any member of its management has
been involved in a material criminal or civil action in a
domestic, foreign or military jurisdiction, an administrative
enforcement action, or self- regulatory organization
proceeding in the past 20+ years that would reflect poorly
upon our firm's advisory business or the integrity of our
firm, or that would be material to a client's evaluation of the
company or its personnel.
Item 10: Other Financial Industry Activities
and Affiliations
Market risk involves the possibility that an
investment’s current market value will fall because of a
general market decline, reducing the value of the
investment regardless of the operational success of the
Strategy Risk:
issuer’s operations or its financial condition.
Our investment strategies and/or investment
Small and Medium Cap Company Risk:
techniques may not work as intended.
Broker-Dealer or Representative Registration
Neither Kenora nor a member of firm management is
registered, or has an application pending to register, as a
broker/dealer or a registered representative of a Financial
Securities of
companies with small and medium market capitalizations
are often more volatile and less liquid than investments in
7
Disclosure Brochure
January 1, 2026
Industry Regulatory Authority (FINRA) or National Futures
Association (NFA) broker/dealer.
Recommendation or Selection of Other Investment
Advisers and Conflicts of Interest
We do not provide recommendations to or make selection
of other investment advisers or third-party registered
investment adviser firms for your account.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
Futures or Commodity Registration
Neither Kenora nor a member of firm management is
registered, or has 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.
interest between the firm,
Material Relationships Maintained by this Advisory
Business and Conflicts of Interest
Our policies require our firm and its associates to conduct
business activities in a manner that avoids actual or
potential conflicts of
its
employees and clients, or that may be contrary to law. We
will provide disclosure to each client prior to and
throughout the term of an engagement regarding any
conflicts of interest which might reasonably compromise
our impartiality or independence.
•
Neither Kenora nor a member of our firm's management is
or has a material relationship with any of the following
types of entities:
•
•
Code of Ethics
Kenora has adopted a Code of Ethics that defines our
fiduciary commitment to each client. This Code of Ethics
applies to all persons associated with Kenora. The Code of
Ethics was developed to provide general ethical guidelines
and specific instructions regarding our duties to you, our
client. Kenora and its personnel owe a duty of loyalty,
fairness and good faith towards each Client. It is the
obligation of Kenora associates to adhere not only to the
specific provisions of the Code but to the general principles
that guide the Code. The Code of Ethics covers a range of
include: general ethical principles,
topics that may
to
reporting personal securities trading, exceptions
reporting securities trading, reportable securities, initial
public offerings and private placements, reporting ethical
violations, distribution of the Code of Ethics, review and
enforcement processes, amendments to Form ADV and
supervisory procedures.
1
;
1
We periodically review and amend our Code of Ethics to
ensure that it remains current.
;
•
•
•
•
•
•
Our firm will provide a copy of its Code of Ethics to any
client or prospective client upon request.
Accountant or Accounting Firm:
Broker-dealer, municipal securities dealer or
government securities dealer or broker;
Other investment adviser or financial planner;
Futures commission merchant, commodity pool
operator, or commodity trading advisor;
Banking or thrift institution;
Lawyer or law firm
Insurance company or agency
Pension consultant;
Real estate broker or dealer; or
Sponsor or syndicator of limited partnerships.
Ryan McNeilly & Associates,
CPAs is a related firm which shares office space and clients
with Kenora. Ryan McNeilly & Associates, CPAs bills clients
Investment Company or Other Pooled Investment Vehicle:
for tax preparation, IRS audits, and estate planning only.
Personal Trading and Conflicts of Interest
At times, Kenora or employees may buy or sell securities for
their own account which are also recommended to clients.
Kenora may recommend securities or investment products
in which Kenora or a related person has some financial
interest. To avoid any potential conflicts of interest
involving personal trades, Kenora has adopted a Code of
Ethics. The Code of Ethics is predicated on the principle that
Kenora owes a fiduciary duty to its clients.
We
manage the Select Investors Fund, a private pooled
investment vehicle which invests in publicly traded equity
securities. The fund is currently closed to new investors. We
receive a portfolio management fee based on a percentage
of fund assets under management.
Accordingly, employees must attempt to avoid activities,
interests and relationships that run contrary (or appear to
run contrary) to the best interests of clients, including:
1
Upon your request, we may provide referrals to various
professionals, such as an attorney or insurance agent. We
do not have an agreement with or receive fees from these
professionals for these informal referrals. Any fees charged
by these other entities for their services are completely
separate from fees charged by our firm.
8
Disclosure Brochure
January 1, 2026
•
•
•
•
Schwab provides Kenora with access to its institutional
trading and custody services, which are typically not
investors. These services
available to Schwab retail
generally are available to independent investment advisers
on an unsolicited basis, at no charge to them so long as a
total of at least $10 million of the adviser's clients' assets are
maintained in accounts at Schwab institutional.
•
•
Act within an ethical manner with the public,
investors, prospective clients and investors;
Place the interests of clients above their own
personal interests;
Not take inappropriate advantage of their position;
Avoid actual or potential material conflicts of
interest, or, in the event conflicts cannot be
avoided, to proactively disclose such conflicts to all
investors;
Conduct all personal securities transactions in a
manner consistent with this policy; and
Use reasonable care and exercise independent
professional judgment.
These services are not contingent upon Kenora committing
to Schwab any specific amount of business (assets in
custody or trading commissions). Schwab's brokerage
services include the execution of securities transactions,
custody research, and access to mutual funds and other
investments that are otherwise generally available only to
institutional investors or would require a significantly
higher minimum initial investment.
The majority of INVESCO LLC's investing is in widely traded
stocks. Given the volume of these stocks, it is unlikely that
the trading of Kenora employees would have any material
impact on the stock being traded.
At no time will Kenora or any associated person of Kenora
transact in any security to the detriment of any client.
For Kenora client accounts maintained in its custody,
Schwab generally does not charge separately for custody
services but is compensated by account holders through
commissions and other transaction-related or asset-based
fees for securities trades that are executed through Schwab
or that settle into Schwab accounts.
interest,
including, but not
limited
Kenora does not engage in any transactions where it has a
financial
to
commissionable securities transactions, buying securities
from or selling securities to its Clients.
Schwab institutional also makes available to Kenora other
products and services that benefit Kenora but may not
directly benefit its clients' accounts. Many of these products
and services may be used to service all or some substantial
number of Kenora accounts,
including accounts not
maintained by Schwab.
As a Fee-Only registered investment adviser, Kenora does
not have a broker-dealer relationship and has no incentive
to sell products of any kind to its Clients.
Item 12: Brokerage Practices
see
Item 15 - Custody
Schwab's products and services that assist Kenora in
managing and administering clients' accounts include
software and other technology to (i) provide access to client
account data (such as trade confirmations and account
statements); (ii) facilitate trade execution and allocate
aggregated trade orders for multiple client accounts;
(iii) provide research, pricing and other market data;
(iv) facilitate payment of Kenora fees from its clients'
accounts; and (v) assist with back-office functions, record
keeping and client reporting.
Factors used to Select Broker-Dealers for Client
Transactions
Kenora does not typically maintain custody of any of your
assets (
). Your assets must be
maintained in an account at a qualified custodian that is
frequently assessed for its capabilities to serve as a
custodian by their respective industry regulatory authority.
Our firm does not have an affiliate that is a custodian.
Kenora does not receive any compensation for commissions
when stocks are bought or sold. Charles Schwab & Co., Inc.
has been selected as broker for reasonable commissions,
efficient on-line trading and security of client securities.
Kenora may require that clients establish brokerage
accounts with the Schwab Institutional division of Charles
Schwab & Co., Inc. (Schwab), a FINRA-registered broker-
dealer, member SIPC, to maintain custody of clients' assets
and to effect trades for their accounts. Although Kenora may
require that clients establish accounts at Schwab, it is the
client's decision to custody assets with Schwab. Kenora is
independently owned and operated and not affiliated with
Schwab.
Schwab institutional also offers other services intended to
help Kenora manage and further develop its business
enterprise. These services may include: (i) compliance,
legal and business consulting; (ii) publications and
conferences on practice management and business
succession; and (iii) access to employee benefits providers,
human capital consultants and
insurance providers.
Schwab may make available, arrange and/or pay third-
party vendors for the types of services rendered to Kenora.
Schwab institutional may discount or waive fees it would
otherwise charge for some of these services or pay all or a
part of the fees of a third party providing these services to
Kenora. Schwab institutional may also provide other
benefits such as educational events or occasional business
entertainment of Kenora personnel.
9
Disclosure Brochure
January 1, 2026
Brokerage for Client Referrals.
We do not receive client referrals from any broker-dealer or
custodian.
Item 13: Review of Accounts
Kenora may take into account the availability of some of the
foregoing products and services and other arrangements as
part of the total mix of factors it considers and not solely the
nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict
of interest.
Unlike some investment advisers, Kenora does not engage
in any “soft dollar” practices involving the receipt of
research or other brokerage service in relation to client
commission money, nor do we receive any research or
other products in connection with client transactions.
Kenora also does not use client commission money to
compensate or otherwise reward any brokers for client
referrals.
Customized Investment Portfolios
Portfolios must be periodically rebalanced back to their
original targets to maintain the intended risk level and
industry allocations. Kenora reviews each Client's Account
when it is opened, and monitors and periodically rebalances
each Client's portfolio to seek to maintain a Client's desired
risk level. Client accounts are reviewed at least monthly.
Kenora also conducts reviews when material changes may
have occurred to a Client's portfolio or investment
objectives. We consider tax implications when deciding
when and how to rebalance taxable accounts.
items, and
We periodically conduct an assessment of any service
provider we recommend, including Charles Schwab & Co.,
which typically includes a review of their range of services,
reasonableness of fees, among other
in
comparison, to their industry peers.
Triggering factors in rebalancing portfolios occur in
the stock price drops
brokerage accounts when
substantially below the cost basis, or in all accounts to
adjust back to desired target risk level, or when an industry
becomes over-weighted.
On a quarterly basis, Kenora provides clients written
reports on their portfolio's balances and projected cash
flow. In addition, we report what fees will be billed to the
account for the previous quarter.
Best Execution
Best execution means the most favorable terms for a
transaction based on all relevant factors, including those
listed in the previous section. We recognize our obligation
in seeking best execution for our clients; however, it is our
belief that the determinative factor is not always the lowest
possible cost but whether the selected service provider's
transactions represent the best qualitative execution while
taking into consideration the full range of services
provided. Therefore, we will seek services involving
competitive rates but it may not necessarily result in the
lowest possible rate for each transaction. We have
determined that having Charles Schwab & Co. execute our
trades is consistent with our duty to seek “best execution.”
The Client will receive brokerage statements monthly from
the Custodian. These brokerage statements are sent directly
from the Custodian to the Client. The Client may also
establish electronic access to the Custodian's website so
that the Client may view these reports and their account
activity. Client brokerage statements will include all
positions, transactions and fees relating to the Client's
account(s).
periodically
review
policies
regarding
We
our
recommending service providers to our clients in light of
our duty to seek best execution.
Other Services
Except for accounts that are managed on a discretionary
basis with our customized investment portfolios services as
described above, we generally do not provide ongoing
formal reviews or reports with respect to our financial
planning, investment counseling, retirement planning,
estate planning, tax planning, and financial education
services, unless you request us to provide a review.
Item 14: Client Referrals and Other
Compensation
Aggregating Securities Transactions for Client
Accounts
Transactions for each of our clients will generally be
effected independently unless we decide to purchase or sell
the same securities for several clients at approximately the
same time, often termed “aggregated” or “batched” orders.
We do not receive any additional compensation or
remuneration as a result of aggregated transactions.
We may, but are not obligated to, aggregate orders in an
attempt to obtain better execution, negotiate favorable
transaction rates, or to allocate equitably among our client
accounts should there be differences in prices and
commissions or other transaction costs that might have
been obtained had such orders been separately placed.
Economic Benefits Provided to the Advisory Firm
From External Sources and Conflicts of Interest
Kenora is a Fee-Only adviser, who, in all circumstances, is
compensated solely by the client. Kenora does not receive
10
Disclosure Brochure
January 1, 2026
from product
commissions or other compensation
sponsors, broker dealers or any unrelated third party.
implement
Similar to a limited power of attorney, discretionary
authority allows our firm to
investment
decisions, such as the purchase or sale of a security on
behalf of your account, without requiring your prior
authorization for each transaction to meet your stated
account objectives.
Advisory Firm Payments for Client Referrals
We do not, directly or indirectly, compensate any person
who is not advisory personnel for client referrals.
Item 15: Custody
financial planning,
Client funds and securities will be maintained by an
unaffiliated, qualified custodian. Client assets are not held
by our firm or any of our associates.
account
statements directly
from
Clients will be provided with transaction confirmations and
summary
the
custodian/broker. Typically, statements are provided on a
monthly basis or as transactions occur within your account.
We will not create a statement for you nor be the sole
recipient of account statements.
Other Services
Except for accounts that are managed on a discretionary
basis with our Customized Investment Portfolio services as
described above, our
investment
counseling, retirement planning, estate planning, tax
planning, and financial education services are generally
provided on a non-discretionary basis. This means that you
have the sole authority to take action on the advice
provided. We have no authority to act on your behalf with
respect to these services. You may
implement any
investment recommendations on your own. You are free to
select any appropriately
licensed brokerage firm or
insurance agency to do so. We do not have any control over
the timing or accuracy of any transactions executed by you.
You are not obligated to implement any financial planning
recommendations made by us or to maintain an ongoing
relationship with us.
Item 17: Voting Client Securities
Clients will receive periodic reports from our firm that
include investment performance information; you are
urged to carefully review and compare your account
statements that you have received directly from your
broker/custodian with any report from our firm. Only the
broker's trading confirmations and statements represent
the official records of a client's account.
We do not accept voting authority for securities held in your
investment accounts, and we do not provide advice to
clients on how to vote proxies. In addition, we do not take
any action on behalf of clients or provide advice to clients
with regard to any class action lawsuit or bankruptcy
related to securities held in your investment accounts.
Item 18: Financial Information
Because we manage the Select Investors Fund, we are
deemed to have constructive custody of the assets in the
private fund. Therefore, the fund is subject to an annual
audit by an independent certified public accounting firm. In
addition, we are deemed to have constructive custody of
assets in two client accounts due to our control or authority
over the assets. These client accounts are subject to an
annual surprise audit conducted by an independent
certified public accounting
firm. These audits are
performed by DeMarco, Sciaccotta, Wilkens & Dunleavy,
LLP, 9645 Lincolnway Lane, #214a, Frankfort, IL 60423,
(708) 489-1680.
Item 16: Investment Discretion
We do not require or solicit prepayment of $1,200 or more
in fees per client, six months or more in advance. Therefore,
we are not required to include our balance sheet in this
section. Kenora does not have any financial commitment
that impairs its ability to meet contractual and fiduciary
commitments to clients, and has not been the subject of a
bankruptcy proceeding. In addition, we do not require or
solicit pre-payment of advisory fees.
Customized Investment Portfolios
We receive discretionary authority from the client at the
outset of an advisory relationship to select the identity and
amount of securities to be bought or sold. Such authority is
provided in our contract with each client. In all cases,
however, such discretion is to be exercised in a manner
consistent with the stated investment objectives for the
particular client account. You may revoke this discretionary
authority at any time. However, upon revocation, Kenora
will be unable to manage your accounts, and our services
will terminate as of the date of receipt of such revocation.
11
Kenora Financial, LLC
CRD No. 123524
This Brochure Supplement provides information about our
advisory personnel that supplements the Disclosure
Brochure of Kenora Financial, LLC (formerly known as
INVESCO, LLC), CRD No. 123524 (“Kenora”). You should
have received a copy of that Disclosure Brochure. Please
contact us by phone at (847) 257-7200 or by email at
invest@KenoraFinancial.com if you did not receive the
Disclosure Brochure or if you have any questions about the
contents of this Brochure Supplement.
1295 Rand Road, Suite 100
(
Des Plaines, IL 60016
847) 257-7200
Additional information about our advisory personnel is
available on the SEC’s website at www.adviserinfo.sec.gov
which can be found by conducting an Individual search
using the CRD number shown for each individual.
Keith B. Nyborg (CRD No. 4602314)
www.KenoraFinancial.com
invest@KenoraFinancial.com
Brochure Supplement
Investment Adviser Representative
Form ADV Part 2A
January 1, 2026
Born 1959
Educational Background
Educational Background and Business Experience
•
Business Experience
Bachelor of Science, University of Illinois (1981)
•
Licenses and Exams
January 1990 to Present: Kenora Financial, LLC
(formerly known as INVESCO, LLC), Principal
•
Uniform Investment Adviser Law Examination
(NASAA Series 65)
Disciplinary Information
Keith does not have any legal or disciplinary events that
would be material to a client's evaluation of Keith or
Kenora.
Other Business Activities
Keith volunteers to teach the Investing in Stocks classes
through District 211’s adult continuing education program.
Keith is not involved in any other business activities.
Additional Compensation
As a principal of Kenora, Keith receives economic benefit
from the overall profitability of the firm, but does not
receive any additional compensation from non-clients for
providing advisory services.
12
Brochure Supplement
January 1, 2026
While some supervised persons of Kenora are CPAs, this
Personal Financial Specialist (PFSTM).
firm is not a CPA firm.
Supervision
Keith as Managing Member and Chief Compliance Officer of
Kenora, is responsible for supervision. Supervision is
administered through the application of and adherence to
written policies and procedures. He may be contacted at the
phone number on this Brochure Supplement.
Ryan McNeilly (CRD No. 4507434)
Investment Adviser Representative
Born 1979
Educational Background
Educational Background and Business Experience
•
Business Experience
A Personal
Financial Specialist (PFS™) is a certification for certified
public accountants (CPAs) that allows them to expand their
expertise and offerings to include financial planning and
wealth management. The requirements for the Personal
Financial Specialist (PFS™) credential are established by the
Personal Financial Planning (PFP) Division staff at the
AICPA, the National Accreditation Commission, along with
the PFS Credential Committee, and accurately reflect the
depth and breadth of experience and technical expertise
required to obtain this credential. A PFS candidate must
hold a valid and unrevoked CPA permit, license or
certificate issued by a legally constituted state authority.
You must also be a current Regular member of the AICPA.
Bachelor of Arts, University of Illinois (2001)
•
•
Disciplinary Information
Ryan does not have any legal or disciplinary events that
would be material to a client's evaluation of Ryan or Kenora.
Licenses and Exams
August 2008 to Present: Kenora Financial, LLC
(formerly known as INVESCO, LLC), Principal
August 2008 to Present: Ryan McNeilly &
Associates, CPAs, Partner
Other Business Activities
Ryan is not involved in any other business activities.
•
Professional Designations, Licensing and Exams
Uniform Investment Adviser Law Examination
(NASAA Series 65)
Certified Public Accountant (CPA).
Additional Compensation
As a principal of Kenora, Ryan receives economic benefit
from the overall profitability of the firm, but does not
receive any additional compensation from non-clients for
providing advisory services.
Supervision
Keith B. Nyborg, Chief Compliance Officer of Kenora, is
responsible for supervision. Supervision is administered
through the application of and adherence to written policies
and procedures. He may be contacted at the phone number
on this Brochure Supplement.
Paul N. Linzer (CRD No. 4602316)
Investment Adviser Representative
CPAs are licensed and
regulated by their state boards of accountancy. While state
laws and regulations vary, the education, experience and
testing requirements for licensure as a CPA generally
include minimum college education (typically 150 credit
hours with at
least a baccalaureate degree and a
concentration in accounting), minimum experience levels
(most states require at least one year of experience
providing services that involve the use of accounting, attest,
compilation, management advisory, financial advisory, tax
or consulting skills, all of which must be achieved under the
supervision of or verification by a CPA), and successful
passage of the Uniform CPA Examination.
Born 1942
Educational Background
Educational Background and Business Experience
•
•
Business Experience
Master of Arts, Northeastern Illinois University
(1971)
Bachelor of Arts, DePaul University (1966)
•
January 1990 to Present: Kenora Financial, LLC
(formerly known as INVESCO, LLC), Principal
Additionally, all American Institute of Certified Public
Accountants (AICPA) members are required to follow a
rigorous Code of Professional Conduct which requires that
they act with integrity, objectivity, due care, competence,
fully disclose any conflicts of interest (and obtain client
consent if a conflict exists), maintain client confidentiality,
disclose to the client any commission or referral fees, and
serve the public interest when providing financial services.
The vast majority of state boards of accountancy have
adopted the AICPA's Code of Professional Conduct within
their state accountancy laws or have created their own.
13
Brochure Supplement
January 1, 2026
Licenses and Exams
•
Uniform Investment Adviser Law Examination
(NASAA Series 65)
concentration in accounting), minimum experience levels
(most states require at least one year of experience
providing services that involve the use of accounting, attest,
compilation, management advisory, financial advisory, tax
or consulting skills, all of which must be achieved under the
supervision of or verification by a CPA), and successful
passage of the Uniform CPA Examination.
Disciplinary Information
Paul does not have any legal or disciplinary events that
would be material to a client's evaluation of Paul or Kenora.
Other Business Activities
Paul is not involved in any other business activities.
Additional Compensation
As a principal of Kenora, Paul receives economic benefit
from the overall profitability of the firm, but does not
receive any additional compensation from non-clients for
providing advisory services.
Additionally, all American Institute of Certified Public
Accountants (AICPA) members are required to follow a
rigorous Code of Professional Conduct which requires that
they act with integrity, objectivity, due care, competence,
fully disclose any conflicts of interest (and obtain client
consent if a conflict exists), maintain client confidentiality,
disclose to the client any commission or referral fees, and
serve the public interest when providing financial services.
The vast majority of state boards of accountancy have
adopted the AICPA's Code of Professional Conduct within
their state accountancy laws or have created their own.
While some supervised persons of Kenora are CPAs, this
firm is not a CPA firm.
Supervision
Keith B. Nyborg, Chief Compliance Officer of Kenora, is
responsible for supervision. Supervision is administered
through the application of and adherence to written policies
and procedures. He may be contacted at the phone number
on this Brochure Supplement.
Nilu Judge (CRD No. 7196985)
Disciplinary Information
Nilu does not have any legal or disciplinary events that
would be material to a client's evaluation of Nilu or Kenora.
Investment Adviser Representative
Other Business Activities
Nilu is not involved in any other business activities.
Born 1971
Educational Background
Educational Background and Business Experience
•
Additional Compensation
As a principal of Kenora, Nilu receives economic benefit
from the overall profitability of the firm, but does not
receive any additional compensation from non-clients for
providing advisory services.
Business Experience
Bachelor of Commerce, University of Toronto
(1995)
•
•
•
Supervision
Keith B. Nyborg, Chief Compliance Officer of Kenora, is
responsible for supervision. Supervision is administered
through the application of and adherence to written policies
and procedures. He may be contacted at the phone number
on this Brochure Supplement.
Licenses and Exams
July 2020 to Present: Kenora Financial (formerly
known as INVESCO, LLC), Principal
January 2019 to Present: Ryan McNeilly &
Associates, CPAs, Partner
May 2006 to June 2020: Enesco LLC, Director FP&A
•
Professional Designations, Licensing and Exams
Uniform Investment Adviser Law Examination
(NASAA Series 65)
Certified Public Accountant (CPA).
CPAs are licensed and
regulated by their state boards of accountancy. While state
laws and regulations vary, the education, experience and
testing requirements for licensure as a CPA generally
include minimum college education (typically 150 credit
least a baccalaureate degree and a
hours with at
14
Kenora Financial, LLC
CRD No. 123524
This Privacy Notice describes how Kenora Financial, LLC
(“Kenora,”) collects, uses, and protects nonpublic personal
information about you in connection with the advisory
services we provide as a registered investment adviser. It
applies to current and former individual clients who obtain
financial products or services from us for personal, family,
or household purposes.
1295 Rand Road, Suite 100
(
Des Plaines, IL 60016
847) 257-7200
Information We Collect
We collect nonpublic personal information about you in
order to open and service your accounts, to comply with
legal and regulatory obligations, and to provide investment
advisory and related services you request. This information
•
may include:
www.KenoraFinancial.com
invest@KenoraFinancial.com
Privacy Policy
•
January 1, 2026
•
•
Identifiers, such as your name, Social Security number,
taxpayer identification number, date of birth, driver’s
license number, or passport number.
Contact information, such as your physical and mailing
addresses, email addresses, and telephone numbers.
Financial and account information, such as account
numbers, custodial account details, transaction history,
holdings, and other information related to your assets
and liabilities.
Other information you provide to us on account opening
documents or in the course of our relationship,
including information needed to verify your identity and
suitability for our services.
We generally collect this information directly from you, for
example through account applications and other forms you
complete, as well as in the ordinary course of our advisory
relationship and from your designated account custodian.
How We Use and Share Information
•
We use your nonpublic personal information to:
•
•
Establish and maintain your accounts and provide
investment advisory and related services.
Communicate with you about your accounts and our
services.
Satisfy our legal, regulatory, and contractual obligations,
including required reporting and recordkeeping.
We do not sell your personal information and do not share
it with third parties for their own marketing or sales
purposes.
We may disclose nonpublic personal information about you,
as permitted by law, to:
15
Privacy Policy
January 1, 2026
•
procedures are in place to address cyber security. A copy of
this policy is available upon request.
•
•
•
applicable
legal
and
Former Clients
If you end your relationship with us, we will continue to
protect your nonpublic personal information as described
in this Privacy Notice and in accordance with our record
retention and information security policies. We will retain
and, when appropriate, dispose of your information
consistent with
regulatory
requirements.
Your account custodian, for purposes of opening,
servicing, and maintaining your accounts and
processing transactions.
Our professional service providers that support our
advisory services, such as our in office tax firm and other
vendors that may provide administrative, operational,
audit, or technology services to us.
Our affiliates, if you engage the services of our affiliates,
so that we can provide coordinated services between
our affiliated entities.
Government agencies, regulators, self regulatory
organizations, auditors, or other parties when we
believe disclosure is required or appropriate to comply
with applicable law, regulation, legal process, or to
protect our rights or the rights of others.
Your Choices and Inquiries
Because we do not share your nonpublic personal
information with nonaffiliated third parties for their own
marketing purposes, there is no separate opt out right for
such sharing. If in the future we seek to share your
information in a way that gives rise to an opt out right under
applicable law, we will provide you with a revised notice
and instructions explaining your rights.
When we share information with service providers, we limit
their use of your information to the purposes for which it
was disclosed and expect them to safeguard it in accordance
with applicable law and our contractual arrangements.
Our Security Policy:
How We Safeguard Your Information
You may contact us if you have questions about this Privacy
Notice, wish to review or correct certain information we
maintain about you, or want more detail about how we
handle your nonpublic personal information, subject to
applicable legal and regulatory limitations.
We restrict access to nonpublic personal
information about you to those individuals who need to
know that information to provide products or services to
you and perform their respective duties. We maintain
physical, electronic, and procedural security measures to
Cyber Security:
safeguard confidential client information.
Changes to This Notice and Contact Information
If we make any substantial changes in the way we use or
disseminate confidential information, we will notify you. If
you have any questions concerning this Privacy Policy,
please contact us at:
We maintain physical, electronic, and
procedural safeguards designed to protect your nonpublic
personal information from unauthorized access, use, or
•
disclosure. These safeguards include, as appropriate:
•
Kenora Financial, LLC
1295 Rand Road, Suite 100
Des Plaines, IL 60016
(847) 257-7200
invest@KenoraFinancial.com
•
with
applicable
Access controls designed to limit nonpublic personal
information to personnel who need it to perform their
job responsibilities.
Reasonable administrative, technical, and physical
safeguards intended to protect against anticipated
threats or hazards and unauthorized access or use.
Processes for secure handling, storage, and disposal of
records containing nonpublic personal information, in
recordkeeping
accordance
requirements.
We periodically review and update our information
security program to address changes in technology,
sensitivity of data, and regulatory expectations.
If an incident occurs that involves unauthorized access to or
use of your nonpublic personal information, we will
conduct an investigation and take appropriate steps in
accordance with our incident response procedures. Where
required by law, we will notify you and any applicable
regulators of a qualifying data breach,
including a
description of the incident and information about steps you
can take to protect yourself. Internal policies and
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Kenora Financial, LLC
CRD No. 123524
We have developed a Business Continuity Plan that outlines
how we will respond to events that significantly disrupt our
business. Because the timing and impact of disasters and
disruptions is unpredictable, we will have to be flexible in
responding to actual events as they occur. With that in
Contacting Us:
mind, we are providing you with this summary of our plan.
1295 Rand Road, Suite 100
(
Des Plaines, IL 60016
847) 257-7200
If after a significant business disruption, you
cannot contact us as you usually do, you may attempt to
contact us using one of our alternative contact methods to
receive further instructions. If you cannot access us through
these alternate means, you may contact the custodian who
holds your account for assistance with your account.
Contact information for your custodian may be found on
Our Plan:
your account statement.
www.KenoraFinancial.com
invest@KenoraFinancial.com
Business Continuity Plan
January 1, 2026
We plan to quickly recover and resume business
operations after a significant business disruption and
respond by safeguarding our employees and property,
protecting the firm’s books and records, and allowing our
clients to transact business. In short, our Plan is designed to
permit our firm to resume operations as quickly as possible,
given the scope and severity of the significant business
disruption.
Our Plan addresses: data backup and recovery; mission
critical systems; alternative communications with clients,
employees, regulators, and critical business constituents;
alternate physical location of employees; and assuring our
clients prompt access to their funds and securities if we are
Varying Disruptions:
unable to continue our business.
Significant business disruptions can
vary in their scope, such as only our firm, the city where we
are located, or the whole geographic region. The severity of
the disruption can also vary from minimal to severe. Our
Plan is flexible enough to address a variety of disruptions.
We are able to work virtually from any location with
Internet access, and we anticipate being able to resume
business operations promptly in most scenarios. We will
provide you with further instructions through the phone
number or website listed below. If the significant business
disruption is so severe that it prevents us from remaining in
business, you still have access to your funds and securities
For More Information:
directly through your account custodian.
If you have questions about our
business continuity plan, please contact us at:
Kenora Financial, LLC
1295 Rand Road, Suite 100
Des Plaines, IL 60016
(847) 257-7200
invest@KenoraFinancial.com
17