J K R & COMPANY, INC.

Form ADV Part 2A (Firm Brochure) JKR & Company, Inc. 7145 Woodley Avenue Van Nuys, CA 91406 Phone: 818-781-7721 Fax: 818-787-2232 www.jkrco.com jamie@jkrco.com April 2026 This brochure provides information about the qualifications and business practices of JKR & Company. If you have any questions about the contents of this brochure, please contact us at 818-781-7721 or jamie@jkrco.com. The information in this brochure has not been approved or verified by the US Securities and Exchange Commission (“SEC”) or by any state securities authority. In addition, state registration does not imply a certain level of skill or training. Additional information about JKR & Company (CRD# 8040) is available on the SEC’s website at https://adviserinfo.sec.gov/IAPD/Default.aspx. 1  JKR & Company Brochure ITEM 2: MATERIAL CHANGES The material changes in the business practices of JKR & Company since the last filing of our Firm Brochure on September 2025, have been listed below. Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at 818-781-7721 or by email at jamie@jkrco.com. 2  JKR & Company Brochure TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ....................................................................................................................................................... 2 ITEM 4: ADVISORY BUSINESS ......................................................................................................................................................... 5 ITEM 5: FEES AND COMPENSATION ............................................................................................................................................ 8 ITEM 6: PERFORMANCE FEES AND SIDE-BY-SIDE MANAGEMENT .......................................................................................... 11 ITEM 7: TYPES OF CLIENTS ......................................................................................................................................................... 11 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................................................. 11 ITEM 9: DISCIPLINARY DISCLOSURES ........................................................................................................................................ 13 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................................................... 13 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .......... 14 ITEM 12: BROKERAGE PRACTICES .............................................................................................................................................. 15 ITEM 13: REVIEW OF ACCOUNTS .............................................................................................................................................. 17 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ................................................................................................... 18 ITEM 15: CUSTODY ..................................................................................................................................................................... 18 ITEM 16: INVESTMENT DISCRETION ......................................................................................................................................... 19 ITEM 17: VOTING CLIENT SECURITIES ....................................................................................................................................... 19 ITEM 18: FINANCIAL INFORMATION ........................................................................................................................................... 19 3  JKR & Company Brochure ITEM 4: ADVISORY BUSINESS JKR & Company (“JKR”) is a corporation organized in the State of California. JKR operates both as a registered investment adviser (“Adviser” or “We”) and a broker-dealer (“BD”) member FINRA, SIPC. The firm operated solely as a BD from 1979 through November 2001 when JKR began offering fee-based investment management as a registered investment adviser. JKR is also licensed to sell certain insurance products. JKR is owned by James Ellis and James Kemp Richardson. This brochure is intended primarily to provide information about JKR as a registered investment adviser. Unless otherwise stated, the information provided relates to the registered investment adviser. However, to provide full disclosure of JKR’s entire scope of business, there may also be references to the BD. TYPES OF SERVICES As a registered investment adviser JKR is held to a fiduciary standard. We have the duty always to put our clients’ interests before our own, by providing disinterested advice and disclosing any material conflicts of interest to our clients as disclosed herein. INVESTMENT / ASSET MANAGEMENT: Our investment adviser representatives (“IARs”) may provide advisory services in the form of investment management services. Investment management services involve providing clients with continuous and ongoing supervision over client accounts. This means that IARs continuously monitor a client’s account and make trades in client accounts when deemed necessary. JKR customizes clients’ portfolios according to their individual risk tolerance, time horizon, and specific goals. Our IAR’s will assist clients in determining their objective(s), investment strategy, and investment suitability, prior and subsequent to opening an asset management account. Clients must contact us to notify of any changes in their investment objective(s) and/or financial situation. JKR provides its clients with a range of investment management services including, but not limited to: Assessment of the client’s investment needs and objectives; development of an asset allocation strategy designed to meet the client’s objectives; recommendations on suitable style allocations; identification of appropriate investments and investment vehicles suitable given the client’s goals; evaluation of investments meeting style and allocation criteria; review of client accounts to ensure adherence to client guidelines and asset allocation; recommendations for account rebalancing, if necessary; and reporting of client account(s) performance and progress. IARs will provide the client with some, or all the above-referenced investment advisory services based on the type of account and the client’s individual needs. Client assets managed by JKR are held in accounts at a non-affiliated registered broker-dealer and qualified custodian, who will provide clearing, custody and other brokerage services for client accounts. While JKR may assist the client in completing the custodian’s paperwork, the client is ultimately responsible for providing all the necessary information to establish the account. Clients will retain all rights of ownership on the accounts, including the right to withdraw securities and cash, vote proxies, and receive transaction confirmations. 4  JKR & Company Brochure FINANCIAL PLANNING AND CONSULTING: JKR offers financial planning and consulting services to clients in several areas of an individual’s financial situation, depending on their goals, objectives, and financial situation. Generally, such financial planning services involve preparing a formal written financial plan or rendering a specific financial consultation based on the client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to: investment planning, retirement planning, income tax planning, cash flow, and debt planning, compensation and employee benefits planning, estate planning, insurance planning and other areas of a client’s financial situation. A financial plan developed for, or financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions for the client to undertake. For example, recommendations may be made that the client start or revise their investment programs, begin, or alter retirement savings, establish education savings and/or revise charitable giving programs. For certain financial planning engagements, JKR will provide a written summary of the client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, JKR may not provide a written summary. Plans or consultations are completed in less than six months of contract date, assuming the client provides all information and documents promptly. JKR may include financial planning related services without separate compensation as part of our overall wealth management services or in limited circumstances, we may provide financial planning as a stand-alone service. We describe fees charged for financial planning services below under Item 5: Fees and Compensation. Conflict of Interest Statement (California Code of Regulations, 10 CCR Section 260.235.2) When multiple services are offered, there is a conflict of interest since there is an incentive for the party offering financial planning services to recommend products or services for which JKR, or a related party, may receive compensation. Clients are under no obligation to act upon JKR’s recommendations, and, if the client elects to act on any of the recommendations, clients are under no obligation to affect the transaction through JKR. RETIREMENT PLAN SERVICES: JKR provides retirement plan services that are intended to assist clients in understanding the scope of their fiduciary duties and responsibilities, guide them in the development of prudent practices and procedures to enable them to discharge their duties and responsibilities, and document their actions and decisions. JKR offers the following services that assist plan sponsors in the: • Development of an investment policy statement (IPS) that establishes the investment policies and objectives for the plan. • Development of recommended asset allocations and portfolio modeling, consistent with the IPS. • Selection of specific investment holdings to fulfill the recommended asset allocation. • Periodic rebalancing of assets to maintain the recommended asset allocation. • Monitoring and measuring investment performance on a periodic basis to maintain adherence to the IPS, including possibly recommending changes to the selected investments. • Monitoring, selecting and supervising service vendors, including coordination of any transition between such vendors; and • Understanding the fiduciary responsibilities as a plan sponsor. 5  JKR & Company Brochure JKR also provides plan fiduciaries with a periodic report that scores the investment options in each asset class and conducts meetings to discuss investment reports and recommendations. JKR provides advice and recommendations; however, the plan sponsor will retain final decision-making authority. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS JKR customizes investment advice and financial plans according to each client’s risk tolerance, time horizon, and specific goals. Clients may impose restrictions on investing in certain securities or types of securities (note that this may not be possible in all situations, such as when the client invests in mutual funds and ETFs). WRITTEN AGREEMENTS Prior to engaging JKR to provide advisory services, clients are required to enter into a written agreement (“Agreement”) with JKR setting forth the terms and conditions under which JKR renders its services. Termination of Agreement For a period of five (5) business days from the date of signing an Agreement, clients may unconditionally terminate the Agreement and receive a full refund of all fees paid. Thereafter, an Agreement may be terminated by either party. If the client made an advance payment, JKR will refund any unearned portion of the advance payment (pro rata). If the client made a payment in arrears, clients will be charged pro rata for services provided through to the date of termination. Assignment of Agreements Agreements may not be assigned without client consent. WRAP FEE PROGRAMS JKR does not participate in any wrap fee programs. IRA ROLLOVER RECOMMENDATIONS When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice). • Never put our financial interests ahead of yours when making recommendations (give loyal advice). 6  JKR & Company Brochure • Avoid misleading statements about conflicts of interest, fees, and investments. • Follow policies and procedures designed to ensure that we give advice that is in your best interest. • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. ASSETS UNDER MANAGEMENT As of March 31, 2026, JKR had $136,316,266 in client assets under management representing (1) $113,298,848 in discretionary assets under management and (2) $0 in non-discretionary assets under management. JKR also had approximately $179,023,142 in retirement plan assets under advisement. ITEM 5: FEES AND COMPENSATION Investment Management Fee: The Adviser’s Annual Fee shall be payable quarterly, in four (4) equal installments in arrears on the first business day after the ending quarter. This will be based upon the total gross value of the assets in the Client’s Account(s) as of the last business day of the prior calendar quarter. The total balance of the clients account will be multiplied by the annual rate and divided by 4. This Annual Fee will also be adjusted in the event of net contributions, or withdrawals during any calendar quarter more than $25,000, with an adjustment or refund to be made as of the beginning of the next calendar quarter or upon termination of this Agreement, as appropriate. Fees payable for a portion of any calendar quarter shall be prorated accordingly. Each IAR sets his own fee schedule; however, in no instance will the annual investment management fee exceed 1.5% (0.375% quarterly) of a client’s assets under management. The exact services you will receive and the fees you will be charged are dependent upon the complexity of your financial situation, the investment services to be provided, the experience and standard fees charged by your IAR, and the nature and total dollar value of assets maintained in your account. Options Trading Fees: Any managed account held at the Broker Dealer trading options will be charged a $25 ticket charge as well as $1.00 per option contract for closing transactions and $2.50 per option contract for opening transactions. Managed accounts trading options will not be charged an AUM fee for options held in the account. Financial Planning Fee: We charge a fixed fee for written financial plans, which range from $2500 to $10,000 depending on the nature and complexity of a client’s financial situation. The hourly fee is up to $250 and is generally paid after the consultations. If the Agreement is terminated within five (5) business days from the date of inception, all fees paid in advance will be refunded. If the agreement is terminated at any other time, any prepaid fees will be refunded on a pro-rated basis. If the client engages JKR for additional investment management services, JKR may offset all or a portion of the financial planning or consulting fee. All fees are negotiable at the sole discretion of JKR and are agreed upon prior to entering into a written agreement with any client. Advisory clients should note that fees for comparable services vary and lower fees for comparable services may be available from other sources. Retirement Plan Services Fee: A client will pay a fee based on the market value of the retirement plan assets in accordance with a schedule of fees agreed to by both parties. The fee range for JKR’s services is 7  JKR & Company Brochure negotiable and may vary according to the facts and circumstances including the scope of services to be provided, the duration of services and the size of the client (number of employees, plan or individual assets, and other demographic factors). Based upon the services selected by the client, JKR generally will charge an annual advisory fee ranging from .50% to 1.00% of the plan assets under management. BILLING PRACTICES Investment Management Fee: Clients may choose to either have account debited directly from Custodian (preferable) or to have JKR send a bill directly to the client to pay by check made payable to JKR within thirty (30) days of receipt. If the client chooses to be billed directly by the Custodian, JKR would have custody over that account and must have written authorization from the client to do so. All fees are billed in arrears. Financial Planning or Consulting Fee: One-time financial planning fees are typically collected as follows: 50% of the agreed upon fee is payable in advance of services, with the remaining 50% due upon delivery of the plan. In certain situations, your IAR may allow you to pay 100% of the agreed upon fee upon delivery of the plan. You also may elect to pay up to 100% of the fee prior to delivery of the plan. Retirement Plan Services Fee: Retirement plan services fees are assessed quarterly in arrears and calculated by the Custodian based on the fair market value of the account as of the last business day of the current billing period. Such fees will be automatically deducted from the client’s account by the Custodian upon the client’s written authorization. OTHER FEES There are several other fees that can be associated with holding and investing in securities. In addition to the advisory fees paid to JKR, clients may also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions (collectively “Financial Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees, fees charged by the third-party investment manager, margin costs, charges imposed directly by a mutual fund or ETF held in a client’s account (as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Clients are responsible for paying those fees separately from JKR fees. JKR does not receive any portion of these additional fees or expenses incurred by advisory clients. MUTUAL FUNDS: As with any business, running a mutual fund involves costs. For example, there are costs incurred in connection with particular investor transactions, such as investor purchases, exchanges, and redemptions. There are also regular fund operating costs that are not necessarily associated with any particular investor transaction, such as investment advisory fees, marketing and distribution expenses, brokerage fees, and custodial, transfer agency, legal, and accountants’ fees. Some funds cover the costs associated with an individual investor’s transactions and account by imposing fees and charges directly on the investor at the time of the transactions (or periodically with respect to account fees). These fees and charges are identified in a fee table, located near the front of a fund’s prospectus, under the heading "Shareholder Fees." Funds typically pay their regular and recurring, fund-wide operating expenses out of fund assets, rather than by imposing separate fees and charges on investors. (Keep in mind, however, that because these expenses are paid out of fund assets, investors are paying them indirectly.) These expenses are identified in the fee table in the fund’s prospectus under the heading "Annual Fund Operating Expenses." 8  JKR & Company Brochure MUTUAL FUND SHARE CLASSES: Mutual funds may be offered in multiple classes of the same fund portfolio where each class has different eligibility criteria and provides different marketing and/or shareholder services subject to different levels of fees and expenses including an ongoing marketing (12b-1) fee. Each class invests in the same pool (or investment portfolio) of securities and has the same investment objectives and policies; however, the performance of each class varies because of the different fees and expenses. In addition to the more commonly offered retail share classes (typically, Class A, B, and C shares), mutual funds may also offer institutional share classes and other share classes (i.e., I, R, N, X, and Y shares) that are specifically designed for purchase in an account enrolled in fee-based investment advisory programs. Institutional share classes or classes of shares designed for purchase in an investment advisory program usually have a lower expense ratio than other share classes. When selecting mutual funds that have multiple share classes for recommendation to clients, the Adviser will consider the internal fees and expenses associated with each share class, and it is JKR’s policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise (i.e., expense ratio savings does not justify the payment of any transaction fee. For a complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund. COMMISSIONABLE SECURITIES SALES: IARs of JKR do not receive commissions for trades occurring in client advisory accounts. Any fees associated with transactions are either retained by the custodian or by BD (please see Item 12). In the event a security is purchased that causes a client to pay a sales charge, the security will be excluded from billing while held in the client account. Management personnel and other IARs of our firm are licensed as registered representatives of BD and/or licensed as insurance agents (see Item 10). In their separate capacity (ies), these individuals can implement investment recommendations for advisory clients for separate and typical compensation (i.e., commissions, 12b-1 fees, or other sales-related forms of compensation). Clients should be aware that the receipt of additional compensation by advisory personnel creates a conflict of interest that may impair the objectivity of these individuals when making advisory recommendations. JKR endeavors always to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser. We take the following steps to address this conflict: • We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees. • We disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies. • We collect, maintain and document accurate, complete, and relevant client background information, including the client’s financial goals, objectives, and risk tolerance. • Our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances. • We require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed. • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm. • We educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. 9  JKR & Company Brochure At all times clients have the option to purchase investment products recommended by our advisory personnel through unaffiliated broker-dealers or insurance agents. LIMITED PREPAYMENT OF FEES: Under no circumstances do we require or solicit payment of fees more than $1,200 more than six months in advance of services rendered. ADVISORY FEES IN GENERAL Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. A client should review both the fees charged by the service/product providers and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. ITEM 6: PERFORMANCE FEES AND SIDE-BY-SIDE MANAGEMENT JKR does not charge fees that are based on a share of the capital gains or capital appreciation of managed securities. ITEM 7: TYPES OF CLIENTS JKR generally provides investment management and financial planning or consulting services to individuals and high net worth individuals. JKR also offers retirement plan services to plan sponsors. JKR generally has a $50,000 minimum account requirement, but JKR reserves the right to waive requirements or not accept certain accounts based on the size of the account and the nature of the services being provided. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS JKR will use any methods of analysis and investment strategies it deems appropriate to achieve each client’s objectives. The selection of a particular method or strategy will be guided by the IAR’s education and experience and based on the client’s objectives and circumstances. RISKS Investing involves risks that clients should understand and be prepared to accept. The risks can range from failing to keep pace with inflation to losing some or all the money you invest. Common risks that investors face include: Systematic or Market Risk: Relates to factors that affect the overall economy or securities markets. Market risk affects all companies, regardless of the company's financial condition, management, or capital structure, and, depending on the investment, can involve international as well as domestic factors. Interest-rate Risk: The risk that the value of a security will go down because of changes in interest 10  JKR & Company Brochure rates. For instance, when interest rates rise, the yields on existing bonds decrease and become less attractive to potential investors, causing their market values to decline. Inflation Risk: The risk that increases in the prices of goods and services, and therefore the cost of living, reduce your purchasing power. Currency Risk: This risk occurs because many world currencies float against each other. If money needs to be converted to a different currency to make an investment, any change in the exchange rate between that currency and yours can increase or reduce your investment return. Liquidity Risk: The risk of having difficulty in liquidating an investment position without taking a significant discount from current market value. Liquidity risk can be a significant problem with certain lightly traded securities such as unlisted options and municipal bonds that were part of small issues. Global Health Risks: The impact of global health events such as epidemics and pandemics could greatly affect the economies of many nations including the United States, individual companies, and the market(s). Pandemics may cause extreme volatility and disruption in both the U.S. and global markets causing uncertainty and risks to economic growth. Health emergencies caused by the recent coronavirus outbreak may exaggerate other preexisting political, social, and economic risks in certain countries and globally. Global health events may result, as this outbreak of coronavirus has resulted, in enhanced health screenings, healthcare service preparation and delivery, quarantines, closing borders, cancellation of travel, disruptions to supply chains and customer activity, mandatory business closures, public gathering limitations, as well as general concern and uncertainty. The impact may be short-term or may last for extended periods. Non-systematic Risk: The risk associated with investing in a particular product, company, or industry sector. Management Risk: Refers to the impact that adverse management decisions, other internal missteps, or even external situations can have on a company's performance and, therefore, on the value of investments in that company. Credit Risk: The risk that an issuer of debt securities (e.g., bond) or a borrower default on its obligations and will be unable to make payment of interest or principal in a timely manner. Financial Risk: The risk that a company will be unable to meet its financial obligations. This risk is primarily a function of the relative amount of debt that the company uses to finance its assets. A higher proportion of debt increases the likelihood that at some point the company will be unable to make the required interest and principal payments. Other Risks: All investing involves risks, including the permanent loss of capital. JKR does not guarantee the future performance of a client’s account, the success of any investment decision or strategy, the success of the overall management of an account, or the effects, if any, of future legal and regulatory changes on JKR’s business or the services JKR provides. In addition to the risks described above that primarily relate to the value of investments, there are various operational, and systems risks involved in investing, including but not limited to “cybersecurity” risk. As the use of technology and frequency of cyber-attacks on financial services targets has become more prevalent, JKR and the client accounts JKR manages have become potentially more susceptible to operational risks through breaches in cybersecurity. A breach in cybersecurity refers to both intentional and unintentional events that may cause JKR to lose proprietary information, suffer data corruption, or lose operational capacity. This, in turn, could cause JKR and/or a client account to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. A 11  cybersecurity breach may also result in a third party obtaining unauthorized access to JKR clients’ information, including social security numbers, home addresses, account numbers, account balances, and account holdings. Cybersecurity breaches may involve unauthorized access to digital information systems (e.g., through “hacking” or malicious software coding) and may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, cybersecurity breaches of third-party service providers (e.g., a client’s custodian) can subject an account to many of the same risks associated with direct cybersecurity breaches. Although JKR has established risk management systems designed to reduce the risks associated with cybersecurity threats, there is no guarantee that such efforts will succeed, especially since JKR does not directly control the cybersecurity systems third-party service providers. ITEM 9: DISCIPLINARY DISCLOSURES On July 27, 2020, JKR (broker-dealer), without admitting or denying the findings, executed an Acceptance, Waiver and Consent in which FINRA found that, from November 2012 to December 2016, the firm violated FINRA Rules 3310(A) and 2010 in connection with its AML Program by failing to detect red flags of suspicious activity in four related accounts, investigate them, and report the activities in a timely manner. JKR (broker-dealer) was censured, fined $50,000, and required to submit a written certification that JKR has established systems and procedures reasonably designed to achieve compliance with its AML obligations. On August 3, 2001, FINRA (formerly NASD) accepted a Letter of Acceptance, Waiver, and Consent (“AWC” - Case Number #C02010037). The allegations are as follows: NASD Rules 2110 and 2510(B) – Respondent (James Ellis) exercised discretionary power in public customers’ accounts without receiving prior written authorization from the customers. Mr. Ellis consented, without admitting or denying the findings, to the issuance of an AWC, a censure and a fine in the amount of $5,000. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS BROKER-DEALER OR REPRESENTATIVE REGISTRATION JKR and Company is also registered as an introducing securities broker-dealer that clears its trades through Pershing (www.Pershing.com). Through its broker-dealer operations/registered representatives, JKR (“BD”) performs trading services for the Adviser and its clients. The Adviser charges advisory clients a $30 transaction fee for each security transaction transacted through Pershing. Part of this transaction fee covers Pershing’s ticket charge; however, the balance of the fee is paid to BD’s firm account at Pershing. In addition, the BD may collect 12b-1 fees for mutual funds that have been recommended and sold by JKR in the capacity of a “broker-dealer” and that reside outside of our advisory program and services. This is a conflict of interest in that JKR’s affiliated broker-dealer receives compensation on brokerage transactions and mutual fund transactions through the BD in addition to compensation received as an investment adviser. However, clients of the Adviser are not required to use the brokerage services offered by the BD registered representatives. The Adviser does not make any representation that the brokerage services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from other brokerages. Certain advisory personnel of JKR are separately licensed as registered representatives of JKR, the broker- dealer. These individuals, in their separate capacity as registered representatives, can affect securities transactions for which they will receive separate, yet customary compensation. 12  FUTURES OR COMMODITY REGISTRATION Neither JKR nor its employees are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. MATERIAL RELATIONSHIPS MAINTAINED BY THIS ADVISORY BUSINESS JKR & Company is also licensed with the California Department of Insurance (license #0797302) to sell insurance products including life and variable products. JKR is authorized to sell insurance products on behalf of several unaffiliated insurance companies. James Ellis (CRD # 2395774) (CA license #0B03259), in his individual capacity, is an agent for various insurance companies. As such, he can receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. John is not licensed with NYS DFS to offer insurance products to NY Residents. John Pieracci (CRD #1875268), in his individual capacity, is an agent for various insurance companies. As such, he can receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. John is not licensed with NYS DFS to offer insurance products to NY Residents. Frederick Pieracci (CRD #725725), in his individual capacity, is an agent for various insurance companies. As such, he can receive separate, yet customary commission compensation resulting from implementing product transactions on behalf of advisory clients. Frederick is not licensed with NYS DFS to offer insurance products to NY Residents. RECOMMENDATIONS OR SELECTIONS OF OTHER INVESTMENT ADVISORS JKR does not recommend or select other managers currently. CONFLICTS OF INTEREST While JKR and its IARs endeavor always to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. Clients, however, are not under any obligation to engage these individuals when considering the implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING JKR has adopted a Code of Ethics for the purpose of instructing its personnel in their ethical obligations and to provide rules for their personal securities transactions. JKR and its personnel owe a duty of loyalty, fairness and good faith towards their clients, and the obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code covers a range of topics that may include general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings, and private placements, reporting ethical violations, distribution of the Code, review and enforcement processes, and insider trading. JKR will provide a copy of the Code to any client or prospective client upon request. 13  INVESTMENT RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST AND CONFLICTS OF INTEREST JKR does not recommend that clients buy or sell any security in which JKR or a related person to JKR has a material financial interest. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Under the JKR’s Code of Ethics, the Adviser and its officers and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If a security is purchased or sold for clients and any of the Adviser, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members officers or employees shall receive or pay the same price, or the clients shall receive a more favorable price. The Adviser and its managers, members, officers, and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. TRADING SECURITIES AT/AROUND THE SAME TIME AS CLIENTS’ SECURITIES IARs may buy or sell securities that are also recommended to clients. However, at no time will JKR’s representatives receive preferential treatment over clients. Furthermore, the securities purchased and sold are widely held and publicly traded. The Chief Compliance Officer of JKR is James Ellis. He reviews all employee trades no less than quarterly. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment. ITEM 12: BROKERAGE PRACTICES JKR generally recommends that clients select either Pershing Advisor Solutions (“PAS”) - Pershing LLC (“Pershing”) or the Institutional division of Charles Schwab & Co., Inc. ("Schwab") as their custodian. Both Pershing and Schwab are members of FINRA and the Securities Investor Protection Corporation (SIPC) and registered broker-dealers. JKR is independently owned and operated and not affiliated with either Pershing or Schwab. Clients may choose to hold their account assets at other brokerage firms with which we do not maintain relationships. In the event you choose to do so, our advisory services will include advice only. We will not implement our recommendations by instructing these firms to execute securities transactions for you. JKR examined this potential conflict of interest when choosing to enter a relationship with Pershing or Schwab determining that either relationship in the best interests of clients and that they satisfy JKR’s fiduciary obligations, including the duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to affect the same transaction where JKR determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution. JKR considers several factors when 14  recommending a brokerage firm including commission rates, the financial stability and reputation, the quality of the investment research, investment strategies, special execution capabilities, clearance, settlement, custody, record keeping and other services the financial stability and reputation of brokerage firms and the brokerage and research services provided by such brokers. INSTITUTIONAL TRADING AND CUSTODY SERVICES We do not receive formal soft dollar benefits other than execution support services from broker-dealers in connection with client securities transactions. Pershing and Schwab provide JKR with access to its institutional trading and custody services, which are typically not available to Pershing’s and Schwab’s retail investors. These services are not contingent upon JKR committing to Pershing or Schwab any specific amount of business (assets in custody or trading commissions). Pershing’s and Schwab’s brokerage services include the receipt of duplicate client confirmations, access to a trading desk serving advisor participants; 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; and access to mutual funds with no transaction fees and to certain institutional money managers. In evaluating whether to recommend that client’s custody their assets at Pershing or Schwab, JKR may consider 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 Pershing, which creates a potential conflict of interest. As part of its fiduciary duties to clients, JKR endeavors to always put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by JKR or its related persons in and of itself creates a potential conflict of interest and may indirectly influence JKR’s recommendation of broker-dealers such as Pershing for custody and brokerage services. BROKERAGE FOR CLIENT REFERRALS JKR receives no referrals from a broker-dealer or third party in exchange for recommending that broker- dealer or third party. CLIENTS DIRECTING WHICH BROKER-DEALER / CUSTODIAN TO USE Clients may instruct JKR to execute any or all securities transactions for their accounts with or through one or more broker-dealers designated by the client. In these cases, clients are responsible for negotiating the terms and conditions (including, but not limited to, commission rates) relating to all services to be provided by the broker-dealers. JKR has no responsibility for obtaining the best prices or any commission rates for transactions with or through the broker-dealer in these situations. Clients should recognize that they may not obtain rates as low as they might otherwise obtain if JKR had discretion to select broker- dealers. Clients are responsible for providing JKR written notification when they want JKR to cease executing transactions with or through the designated broker-dealer. AGGREGATING (BLOCK) TRADING FOR MULTIPLE CLIENT ACCOUNTS JKR may but is not required to, engage in block trading (the bunching or aggregation of transactions) in cases where two (2) or more client accounts are transacting in the same security on the same day. We have adopted trade aggregation policies and procedures to ensure that all accounts are treated fairly when orders 15  are aggregated for execution. Trades, where necessary, are allocated to advisory clients in a manner that fulfills our fiduciary obligations to each client and otherwise allocates securities on a good faith basis that is objective, fair, equitable, consistently applied, and does not unfairly discriminate against any advisory client based upon account performance or other factors. For instance, clients in aggregated transactions each receive the same price per security. If more than one price is paid for securities in an aggregated transaction, each client in the aggregated transaction will receive the average price paid for the block of securities in the same aggregated transaction for the day. If we are unable to fill an aggregated transaction completely but receive a partial fill of the aggregated transaction, we will allocate the filled portion of the transaction to clients on a pro rata basis. JKR may choose not to aggregate trades for several reasons, including, but not limited to: (1) an account reaches an investment guideline limit due to unforeseen changes in account assets after an order is placed; (2) a client account is low in cash; (3) a sale transaction is entered to raise cash in an account; or (4) operational considerations. AFFILIATED BROKER-DEALER JKR (“BD”) is dually registered as an introducing broker-dealer clearing through Pershing. Advisory clients who custody at Pershing can use BD to execute portfolio transactions. These transactions will be conducted subject to proper, and customary, disclosure including but not limited to compensation received by BD (a portion of the $30 Pershing ticket charge as previously disclosed in Item 10). Clients of the Adviser should note that they are not required to use the brokerage services offered by the BD registered representatives. In addition, JKR does not make any representation that the brokerage serves are at the lowest cost available and clients may be able to obtain those services and/or products at a more favorable rate from other brokers. ITEM 13: REVIEW OF ACCOUNTS INVESTMENT MANAGEMENT SERVICES REVIEWS: While the underlying securities within Investment Management Services accounts are continually monitored by the IAR, these accounts are reviewed at least quarterly James Ellis, President and CCO, and/or Kemp Richardson, Vice President. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. REPORTS: In addition to the monthly or quarterly statements and confirmations of transactions that clients receive from their custodian, IARs may provide quarterly reports summarizing account performance, balances, and holdings. FINANCIAL PLANNING SERVICES REVIEWS: Although reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. REPORTS: For financial planning engagements, the IAR will provide a written report. For financial planning 16  consulting or ad-hoc engagements, the IAR may not provide a written report. The IAR will generally not provide additional reports unless agreed upon as part of the engagement. RETIREMENT PLAN SERVICES REVIEWS: The IAR will review the client's Investment Policy Statement (IPS) whenever the client advises JKR of a change in circumstances regarding the needs of the plan. The IAR will also review the investment options of the plan according to the agreed upon time intervals. Such reviews will generally occur no less than annually. REPORTS: Clients will receive monthly or quarterly statements from their Custodian and/or third-party administrators. Plan sponsors and plan participants are urged to carefully review and compare account statements with any performance report they may receive from any source. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION REFERRALS: PROMOTERS/SOLICITORS We may compensate promoters for client referrals. Promoter’s agreements are drafted in compliance with applicable federal and state laws and the Investment Advisers Act of 1940. All clients referred to us by a promoter will be given a written disclosure (“Promoter’s Disclosure Letter”) describing the terms and fee arrangements between JKR & Co., Inc. and the promoter. Form ADV and the Promoter’s Disclosure Letter must be delivered to you at the time of, or prior to, our entering into the Investment Advisory Agreement. Promoters are not IA Reps, supervised persons, or agents of JKR & Co., Inc. Promoters do not provide investment advice on our behalf. They are paid solely for the referral in exchange for a percentage of the management fee. Promoters are not paid cash compensation beyond the referral fee for any activity involving your JKR & Co., Inc. account. Any referrals made by someone in the State of New York will be expressly required to adhere to all New York State regulations regarding solicitors/promoters. JKR & Co., Inc. will ensure compliance with all New York State regulation if anyone is solicited/promoted within the State. OTHER ECONOMIC BENEFITS: JKR receives an economic benefit from Pershing in the form of the support products and services it makes available to us and other independent investment advisers that have their clients maintain accounts at Pershing. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). ITEM 15: CUSTODY JKR is deemed to have custody of client assets solely because a client authorizes us to instruct the qualified custodian to deduct our advisory fees directly from your account. Pershing or Schwab maintains actual custody of your assets. As such, we have adopted the following safeguarding procedures: • Clients must provide JKR with written authorization permitting direct payment of advisory fees from their account(s) maintained by a custodian who is independent of our firm. • The account custodian sends a statement to the client, at least quarterly, showing all account disbursements, including advisory fees. 17  We urge you to carefully review such statements and compare the official custodial statement to the account statements or reports that we provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients should contact us directly if they believe that there may be an error in their statement. ITEM 16: INVESTMENT DISCRETION JKR manages client accounts on a discretionary or non-discretionary basis, pursuant to an executed advisory client agreement. By granting limited discretionary authority, the client authorizes JKR to execute securities transactions, which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be affected without obtaining specific client consent. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with JKR’s written acknowledgment. ITEM 17: VOTING CLIENT SECURITIES As a matter of firm policy and practice, JKR does not have any authority to and does not take any action with respect to corporate actions, tenders, the voting of proxies, or class action lawsuits solicited by or with respect to the issuers of securities maintained in client portfolios; clients retain the responsibility for receiving and taking action for any such corporate action. Notwithstanding this, JKR will provide recommendations to the client upon request for assistance. If a conflict of interest exists, it will be disclosed to the Client. ITEM 18: FINANCIAL INFORMATION JKR does not require prepayment of more than $1,200 in fees per client, six months or more in advance. For additional information regarding payment of fees, see Item 5 above. JKR has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 18