KEB WEALTH ADVISORS

Item 1 – Cover Page 3200 Robbins Road, Suite 200A Springfield, IL 62704 (217) 789-0960 www.kebcpa.com January 28, 2026 This Brochure provides information about the qualifications and business practices of KEB Asset Management, LLC d/b/a KEB Wealth Advisors (“KEB”). If you have any questions about the contents of this Brochure, please contact us at (217) 789-0960. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. KEB is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about KEB also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for KEB is 117935. The SEC’s website also provides information about any persons affiliated with KEB who are registered, or are required to be registered, as investment adviser representatives of KEB. i  Item 2 – Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since the last annual update and provide clients with a summary of such changes. In this update, we: • Added language to disclose the use of AQR as an Independent Manger in Item 4 and Item 5; • Amended our fee schedules in Item 5. Additionally, we have updated the Assets Under Management information of Item 4 in accordance with the filing of our Annual Updating Amendment on January 28, 2026. We will further provide you a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Justin P. Mason, Chief Compliance Officer and Managing Member, at (217) 789-0960. (Brochure Date: 01/28/2026) (Date of Most Recent Annual Updating Amendment: 01/28/2026) ii  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................................. i Item 2 – Material Changes ................................................................................................................................................ ii Item 3 – Table of Contents ............................................................................................................................................... iii Item 4 – Advisory Business ............................................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................................... 3 Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................................... 6 Item 7 – Types of Clients ................................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 6 Item 9 – Disciplinary Information .................................................................................................................................... 9 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................... 9 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ..................................... 10 Item 12 – Brokerage Practices ....................................................................................................................................... 11 Item 13 – Review of Accounts ........................................................................................................................................ 12 Item 14 – Client Referrals and Other Compensation ............................................................................................... 14 Item 15 – Custody ............................................................................................................................................................. 15 Item 16 – Investment Discretion ................................................................................................................................... 15 Item 17 – Voting Client Securities ................................................................................................................................. 15 Item 18 – Financial Information ..................................................................................................................................... 16 iii  Item 4 – Advisory Business KEB Asset Management, LLC d/b/a KEB Wealth Advisors (“KEB”) is owned by 19 individual members and has been providing advisory services since 1999. As of December 31, 2025, KEB managed $1,199,872,013 on a discretionary basis and $74,616,744 on a non-discretionary basis for a total of $1,274,488,757 in assets under management. Additionally, KEB advised on $258,329,757 of self-directed retirement account assets. Investment Management Services: KEB manages investment portfolios for individuals, trusts, partnerships, corporations, not-for-profit organizations and retirement plans. KEB will work with a client to determine the client's investment objectives and investor risk tolerance and will design a written investment policy statement ("IPS”). KEB uses investment and portfolio allocation software to evaluate alternative portfolio designs. KEB evaluates the client's existing investments with respect to the client's IPS. KEB works with new clients to develop a plan to transition from the client's existing portfolio to the portfolio recommended by KEB. KEB will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold review meetings with the client regarding the account as necessary. KEB will typically create a portfolio of no-load mutual funds and exchange-traded funds (“ETFs”), and may use model portfolios if the models match the client's investment policy. KEB will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. KEB primarily recommends securities that follow an evidence-based investment philosophy with low holdings turnover. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s IPS. KEB manages equity portfolios on a discretionary and nondiscretionary basis according to the client’s advisory agreement. Clients may impose any reasonable restrictions on KEB’s discretionary authority, including restrictions on the types of securities in which KEB or any third-party money manager (“TPMM”) may invest client’s assets and on specific securities, which the client may believe to be appropriate. KEB may also recommend fixed income portfolios to investment management clients, which consist of managed accounts of individual bonds. KEB requires discretionary authority from investment management clients to manage fixed income portfolios, including the discretion to retain a TPMM. 1  In certain circumstances, as determined by KEB and the client, KEB engages AQR Capital Management, LLC (“AQR”) as an Independent Manager to manage portfolios of individual securities for clients. In these instances, AQR’s fees are separate, distinct, and in addition to KEB’s advisory fees. Pursuant to its discretionary authority, KEB may retain a TPMM for the ongoing management of all or some of a client’s portfolio. KEB utilizes Focus Partners Advisor Solutions, LLC (“Focus Partners | Advisor Solutions or FPAS”) as the primary TPMM for client portfolios. The TPMM will be provided with the discretionary authority to invest client assets in securities consistent with the client’s IPS. The TPMM will also monitor the account for changes in credit ratings, security call provisions, and tax loss harvesting opportunities (to the extent that the manager is provided with cost-basis information). On an ongoing basis, KEB will answer clients’ inquiries regarding their accounts and review periodically with clients the performance of their accounts. KEB will periodically, and at least annually, review clients’ IPS, risk profile and discuss the rebalancing of each client's accounts to the extent appropriate. KEB will provide to the TPMM any updated client financial information or account restrictions necessary for the investment manager to provide sub-advisory services. In addition to managing the client’s investment portfolio, KEB may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: KEB also provides advisory services to employee retirement benefit plans. KEB will generally recommend a third-party administrator for plan administration, which may provide online bundled services and an opportunity for plan sponsors to provide diversified portfolios to their participants along with daily account access, valuation and investment education. KEB will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. KEB will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. KEB will recommend changes in the plan's investment vehicles as may be appropriate from time to time. KEB generally will review the plan's investment vehicles and investment policy as necessary. For certain retirement plans, KEB also works in coordination and support with FPAS and other 3(38) fiduciary providers (“fiduciary provider”). Retirement plan clients will engage both KEB and the fiduciary provider. The fiduciary provider will administer to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made 2  available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. KEB will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. Financial Planning Services: KEB also provides financial planning advice. Clients purchasing this service may receive a written financial plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives or with a written plan addressing a specific financial planning topic. In general, the financial plan will address any or all of the following areas of concern: • Personal: Family records, budgeting, personal liability, estate information and financial goals. • Tax & Cash Flow: Income tax and spending analysis and planning for current and future years. KEB may illustrate the impact of various investments on a client’s current income tax and future tax liability. • Death & Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. • Retirement: Analysis of current strategies and investment plans to help the client achieve his or • her retirement goals. Investments: Analysis of investment alternatives and their effect on a client’s portfolio. KEB gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, and a written report is prepared. Should a client choose to implement the recommendations in the plan, KEB suggests the client work closely with his/her attorney, accountant and/or insurance agent. Implementation of financial plan recommendations is entirely at the client’s discretion. Item 5 – Fees and Compensation In certain circumstances, all fees, account minimums and their applications to family circumstances may be negotiable. Minimum account sizes may also be waived when a person demonstrates an ability to meet the minimum account size in a reasonable period of time through additional contributions. KEB has contracted with FPAS for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. The fee paid by KEB to 3  FPAS consists of a portion of the fee paid by clients to KEB and varies based on the total client assets participating in FPAS through KEB. These fees are not separately charged to advisory clients. The specific manner in which fees are charged by KEB is established in a client’s written agreement with KEB. Investment Management and Employee Benefit Plan clients will be invoiced in advance at the beginning of each calendar quarter based upon the value (market value based on independent third- party sources or fair market value in the absence of market value; client account balances on which KEB calculates fees may vary from account custodial statements based on independent valuations and other accounting variances, including mechanisms for including accrued interest in account statements) of the client’s account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted (date of first trade). For Investment Management and Employee Benefit Plan Services, KEB will request authority from the client to receive quarterly payments directly from the client's account held by an independent custodian. Clients may provide written limited authorization to KEB or its designated service provider, FPAS, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit KEB’s fee and remit such fee to KEB. A client agreement may be canceled at any time, by either party, for any reason, upon receipt of thirty (30) days’ written notice. Upon termination, any prepaid, unearned fees will be promptly refunded. KEB’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment and other third parties, such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and ETFs also charge internal management fees, which are disclosed in a fund’s prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to KEB for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. Such charges, fees and commissions are exclusive of and in addition to KEB’s fee, and KEB shall not receive any portion of these commissions, fees, and costs. KEB amended the fee schedules below in January 2026. Clients with relationships prior to these changes are subject to their contracted fee schedule until such time as KEB and the client respectively agree to a new schedule. 4  Advisory Fees Investment Management Services: The annual fee for investment management services will be charged as a percentage of assets under management, according to the schedule below: Assets Under Management On the first $2,000,000* On the next $3,000,000 On the next $5,000,000 On the next $10,000,000 On all amounts thereafter Annual Fee 0.90% 0.50% 0.40% 0.30% 0.20% *All relationships are subject to a minimum annual fee of $4,500, which is billed in advance on a monthly basis. For relationships under $500,000, this equates to a monthly fee of $375. In certain circumstances, portfolio values for members of the same family are combined (often referred to as “householded”) for the purposes of determining the fees assessed. Accounts for business entities and accounts related thereto, including those of the business owner, are assessed fees based on the total account balances of all such related accounts. The fee is calculated on the entire portfolio value. For example, a $500,000 portfolio is charged 0.90% or $4,500. Independent Manager Fees As stated above in Item 4, KEB (in coordination with the client) may decide to implement AQR as an Independent Manager for the management of portfolios of individual securities. In these instances, AQR will charge its own separate and distinct fee from KEB’s advisory fees, which are noted above. Clients grant AQR authority at the client’s custodian for AQR to directly debit client accounts for AQR’s fee. Additionally, clients are required to sign an advisory agreement addendum with KEB which outlines these additional fees. Employee Benefit Retirement Plan Services: The annual fee for plan services will be charged as a percentage of assets within the plan. Certain pre- existing employee benefit plan services clients may be on a different fee schedule. Assets Under Advisement On the first $2,000,000 On the next $3,000,000 On the next $5,000,000 On the next $10,000,000 Annual Fee 0.70% 0.40% 0.30% 0.20% 5  On all amounts thereafter 0.10% The 3(38) fiduciaries will charge a separate and distinct fee for their services, as laid out and agreed to in the client agreement. Financial Planning Services: Financial planning fees will be charged on an hourly basis ranging from $250 to $400 per hour, depending on the nature and complexity of each client’s circumstances and upon mutual agreement with the client. If appropriate, a fixed fee may be estimated at the beginning of the financial planning engagement. All fees are agreed upon prior to entering into an agreement with any client. The length of time it will take to provide a financial plan will depend on each client’s personal situation. A 50% payment of the estimated fee may be due upon signing the agreement, with the balance (based on actual hours) due upon presentation of the plan to the client. KEB will never hold client funds greater than $1,200 for more than six (6) months in advance of completion of the financial plan. Item 6 – Performance-Based Fees and Side-By-Side Management KEB does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). All fees are calculated as described above and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. Item 7 – Types of Clients KEB provides services to individuals, trusts, partnerships, corporations, not-for-profit organizations and retirement plans. As mentioned in Item 5, all relationships are subject to a minimum annual fee of $3,000, which is billed in advance on a monthly basis. For relationships under $250,000, this equates to a monthly fee of $250. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy KEB's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. KEB's investment approach is firmly rooted in the belief that markets are efficient over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. KEB selects or recommends portfolios of 6  securities, principally broadly-traded open-end mutual funds, ETFs, and conservative fixed income securities to implement this investment strategy. Although all investments involve risk, KEB's investment advice seeks to limit risk through broad diversification among asset classes and, as appropriate for particular clients, the investment directly in conservative fixed income securities to represent the fixed income class. KEB's investment philosophy is designed for investors who desire a buy and hold strategy. KEB's strategy seeks to minimize frequent trading of securities which increases brokerage and other transaction costs. Clients may hold or retain other types of assets as well, and KEB may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services, but may help to more generally assist the client. KEB’s strategies do not utilize securities that we believe would be classified as having any unusual risks, and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. KEB receives supporting research from FPAS and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). KEB utilizes DFA securities in client portfolios. DFA securities follow an evidence-based investment philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to KEB. Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, KEB relies on an analysis of the client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, KEB may use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other methods used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • The risk that expected future cash flows will not match those used in the analysis • The risk that future rates of return will fall short of the estimates used in the simulation • The risk that inflation will exceed the estimates used in the simulation • For taxable clients, the risk that tax rates will be higher than was assumed in the analysis KEB does not recommend the purchase of public partnership programs due to their illiquidity and the fee structure of such programs. Occasionally, KEB will recommend public real estate investment trusts (“REITs”) for certain clients who desire to include real estate in their asset allocation strategy. KEB will also evaluate insurance products such as annuities and various types of life insurance products which may have been recommended to clients by other professionals. Risk of Loss 7  Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by KEB include funds invested in domestic and international equities, including REITs, corporate and government fixed income securities and commodities. Equity securities may include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds used in KEB’s investment strategies funds are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Conservative fixed income securities have lower risk of loss of principal, but most bonds (with the exception of Treasury Inflation Protected Securities, or “TIPS”) present the risk of loss of purchasing power through lower expected return. This risk is greatest for longer-term bonds. Certain funds utilized by KEB may contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. Interval Fund Risk An interval fund is a type of closed-end fund containing shares that do not trade on the secondary market. Instead, the fund periodically offers to buy back a percentage of outstanding shares at net asset value. The rules for interval funds, along with the types of assets held, make this investment largely illiquid compared with other funds. The primary reasons for investors to consider investing in interval funds KEB may utilize include, but are not limited to, gaining exposure to certain risk categories that provide diversified sources of expected returns, part of which may be in the form of illiquidity premiums. Access to the intended risk and expected return characteristics may not otherwise be available in more liquid, traditional investment vehicles. Where appropriate, KEB may utilize certain interval funds structured as non-diversified, closed-end management investment companies, registered under the Investment Company Act of 1940. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will 8  be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired, and the fund may suspend or postpone purchases. Clients should carefully review the fund’s prospectus to more fully understand the interval fund structure and the corresponding liquidity risks. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some or all of the investment. More information about the risks of any particular market sector can be reviewed in representative mutual fund prospectuses managing assets within each applicable sector. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of KEB or the integrity of KEB’s management. KEB has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Affiliated Accounting Firm The Members of KEB are also Partners of Kerber, Eck & Braeckel LLP, an accounting firm that is affiliated through both ownership and control to KEB. Kerber, Eck & Braeckel LLP may recommend KEB to accounting clients in need of advisory services. KEB may recommend Kerber, Eck & Braeckel LLP to advisory clients in need of accounting services. Accounting services provided by Kerber, Eck & Braeckel LLP are separate and distinct from the advisory services of KEB and are provided for separate and typical compensation. No KEB client is obligated to use Kerber, Eck & Braeckel LLP for any accounting services as no Kerber, Eck & Braeckel LLP client is obligated to use KEB for advisory services. Focus Partners | Advisor Services As described above in Item 4, KEB may exercise discretionary authority provided by a client to select an independent third-party money manager (“TPMM”) for the management of portfolios. KEB selects Focus Partners Advisor Solutions, LLC (“Focus Partners | Advisor Solutions or FPAS”) for such management. KEB also contracts with FPAS for back-office services and assistance with portfolio modeling. KEB has a fiduciary duty to select qualified and appropriate managers in the client’s best interest, and believes that FPAS effectively provides both the back-office services that assist with its overall investment advisory practice and portfolio management services. The management of KEB continuously makes this 9  assessment. While KEB has a contract with FPAS governing a time period for back-office services, KEB has no such fixed commitment to the selection of FPAS for portfolio management services and may select another investment manager for clients upon reasonable notice to FPAS. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading KEB has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. KEB’s Code of Ethics describes the firm's fiduciary duties and responsibilities to clients and sets forth KEB's practice of supervising the personal securities transactions of employees with access to client information. Individuals associated with KEB may buy or sell securities for their personal accounts identical or different than those recommended to clients. It is the expressed policy of KEB that no person employed by the firm shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on investment decisions of advisory clients. To supervise compliance with its Code of Ethics, KEB requires that anyone associated with this advisory practice with access to advisory recommendations provide annual securities holding reports and quarterly transaction reports to the firm's Chief Compliance Officer or his or her designee. KEB also requires such access persons to receive approval from the Chief Compliance Officer prior to investing in any IPO's or private placements. KEB's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information and protecting the confidentiality of client information. KEB requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to discipline. KEB will provide a complete copy of its Code of Ethics to any client or prospective client upon request. It is KEB’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. KEB will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer. 10  Item 12 – Brokerage Practices KEB arranges for the execution of securities transactions with the assistance of FPAS. Through FPAS, KEB participates in the Schwab Advisor Services (“SAS”) program offered to independent investment advisers by Charles Schwab & Company, Inc (“Schwab”), member FINRA/SIPC, and the Fidelity Institutional Wealth Services (“FIWS”) program offered to independent investment advisors, sponsored by Fidelity Brokerage Services, LLC (“Fidelity”), member FINRA/SIPC. Schwab and FIWS are unaffiliated SEC-registered broker-dealers and FINRA member broker-dealers. The Schwab and FIWS brokerage programs will generally be recommended to advisory clients for custody services and the execution of mutual fund and equity securities transactions. KEB regularly reviews these programs to ensure that its recommendation is consistent with its fiduciary duty. These trading platforms are essential to KEB's service arrangements and capabilities, and KEB may not accept clients who direct the use of other brokers. As part of these programs, KEB receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). Additionally, KEB offers a cash management aggregator system named Flourish Cash. Flourish Cash is a service offered by an unaffiliated third-party, Flourish Financial LLC, a registered broker-dealer and FINRA member. A Flourish Cash account is a brokerage account whereby the cash balance is swept from the brokerage account to deposit accounts at one or more third-party banks that have agreed to accept deposits from clients of Stone Ridge Securities, LLC. Stone Ridge Securities LLC is an indirect, wholly- owned subsidiary of Massachusetts Mutual Life Insurance Company. Please refer to the applicable disclosures provided separately by Stone Ridge Securities upon account opening. As KEB will not request the discretionary authority to determine the broker-dealer to be used or the commission rates to be paid for mutual fund and equity securities transactions, clients must direct KEB as to the broker-dealer to be used. In directing the use of a particular broker or dealer, it should be understood that KEB will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. KEB will not exercise authority to arrange client transactions in fixed income securities. Clients will provide this authority to FPAS by designating FPAS with trading authority over client's brokerage account. Clients will be provided with the Disclosure Brochure (Form ADV Part 2) of FPAS. SAS and FIWS do not generally charge clients a custody fee and are compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through the broker or that settle into the clients' accounts at the brokers. Trading client accounts through other brokers may result in fees (including mark-ups and mark-downs) being charged by the custodial broker and an additional broker. While KEB will not arrange transactions through other brokers, the authority of 11  the fixed income portfolio manager includes the ability to trade client fixed income assets through other brokers. KEB also does not have any arrangements to compensate any broker-dealer for client referrals. KEB does not maintain any client trade error gains. KEB makes client whole with respect to any trade error losses incurred by client caused by KEB. KEB generally does not aggregate any client transactions in mutual fund or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which KEB arranges transactions. FPAS will aggregate certain transactions among client accounts that it manages, in which case a KEB client’s orders may be aggregated with an order for another client of FPAS who is not a KEB client. See FPAS’s Form ADV Part 2. Employee Benefit Retirement Plan Services: KEB does not arrange for the execution of securities transactions for plans as a part of this service. Transactions are executed directly through employee plan participation. Financial Planning Services: KEB's financial planning practice, due to the nature of its business and client needs, does not include blocking trades, negotiating commissions with broker-dealers or obtaining volume discounts, nor necessarily obtaining the best price. Clients will be required to select their own broker-dealers and insurance companies for the implementation of financial planning recommendations. KEB may recommend any one of several brokers. KEB clients must independently evaluate these brokers before opening an account. The factors considered by KEB when making this recommendation are the broker's ability to provide professional services, KEB's experience with the broker, the broker's reputation, and the broker's financial strength, among other factors. KEB's financial planning clients may use any broker or dealer of their choice. Item 13 – Review of Accounts Reviews: Investment Management Services: Account assets are supervised continuously and reviewed at least quarterly. An investment advisor representative (“IAR”) is assigned to each account and that IAR will review each account at least quarterly. The review process contains each of the following elements: 12  a. assessing client goals and objectives; b. evaluating the employed strategy(ies); c. monitoring the portfolio(s); and d. addressing the need to rebalance. Additional account reviews may be triggered by any of the following events: a. a specific client request; b. a change in client goals and objectives; c. an imbalance in a portfolio asset allocation; d. market/economic conditions; and e. realizing tax losses in an account. For portfolios managed by FPAS, certain account review responsibilities are delegated to FPAS as described in Item 14. Employee Benefit Retirement Plan Services: Plan assets are reviewed on a quarterly basis or as otherwise agreed between the parties, and according to the standards and situations described above for investment management accounts. Financial Planning Services: Financial planning accounts will be reviewed as contracted for at the inception of the advisory relationship. Reports: Investment Management Services: All clients other than those utilizing employee benefit retirement plan services will receive quarterly performance reports from KEB that summarize the client's account and asset allocation. Quarterly reports include portfolio performance review, current positions and current market value. Clients will also receive statements from account custodians. Employee Benefit Retirement Plan Services: Plan sponsors are provided with quarterly information and annual performance reviews from KEB. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan. 13  Financial Planning Services: Financial Planning clients will receive reports as contracted for at the inception of the advisory relationship. Item 14 – Client Referrals and Other Compensation Other Compensation: As indicated under the disclosure for Item 12, SAS and FIWS each respectively provide KEB with access to services, which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. These services benefit KEB but may not benefit its clients' accounts. Many of the products and services assist KEB in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of KEB's fees from its clients' accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of KEB's accounts. SAS and FIWS also make available to KEB other services intended to help KEB manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. KEB does not, however, enter into any commitments with SAS or FIWS for transaction levels in exchange for any services or products from brokers. While as a fiduciary, KEB endeavors to act in its clients' best interests, KEB's requirement that clients maintain their assets in accounts at Schwab or FIWS may be based in part on the benefit to KEB of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the broker, which may create a potential conflict of interest. KEB also receives software from DFA, which KEB utilizes in forming assets allocation strategies and producing performance reports. DFA also provides continuing education for KEB personnel. These services are designed to assist KEB to plan and design its services for business growth. Client Referrals: KEB may from time to time compensate, either directly or indirectly, any person (defined as a natural person or a company) for client referrals. KEB may compensate affiliated persons. KEB is aware of the special considerations promulgated under Section 206(4)-1 of the Investment Advisers Act of 1940, as 14  amended. As such, appropriate disclosure shall be made, all written instruments will be maintained by KEB and all applicable federal and/or state laws will be observed. Members and other employees of the accounting firm of Kerber, Eck & Braeckel LLP may refer clients to KEB for advisory services. KEB is under common ownership and control with Kerber, Eck & Braeckel LLP, and, therefore, any Kerber, Eck & Braeckel LLP employee referring clients to KEB has a potential conflict of interest because of an economic incentive to recommend the advisory services of KEB. Members and other employees of Kerber, Eck & Braeckel LLP may receive compensation if a client chooses to use KEB's advisory services. This compensation will generally be a fixed fee or equal to a percentage of the total fee received by KEB for the client's advisory account. Item 15 – Custody Investment Management and Employee Benefit Plan Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains client’s investment assets. KEB urges its clients to carefully review such statements and compare such official custodial records to the account statements that KEB may provide to its clients. KEB’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion KEB requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. In certain circumstances, this authority will include the discretion to retain a third-party money manager for fixed income accounts. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, KEB observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to KEB in writing. Item 17 – Voting Client Securities Proxy Voting: As a matter of firm policy and practice, KEB does not accept the authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Clients will receive applicable proxies directly 15  from the issuer of securities held in clients’ investment portfolios. KEB, however, may provide advice to clients regarding the clients' voting of proxies. Class Actions, Bankruptcies and Other Legal Proceedings: Clients should note that KEB will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held or previously were held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct KEB to transmit copies of class action notices to the client or a third party. Upon such direction, KEB will make reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about KEB’s financial condition. KEB 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. 16