View Document Text
Kennedy Investment Group, Inc.
Form ADV Part 2A – Disclosure Brochure
Effective: February 6, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Kennedy Investment Group, Inc. (“KIG” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at 856-853-0400.
KIG is a registered investment advisor with the U.S. Securities and Exchange Commission. The information in this
Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or
by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Disclosure Brochure provides information about KIG to assist you in determining whether to retain the
Advisor.
information about KIG and
its Advisory Persons
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 322605.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of KIG. For convenience, the Advisor has combined these documents into a single disclosure document.
KIG believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. KIG encourages all current and
prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last annual amendment filing
on January 31st, 2025:
• The Advisor now offers estate planning services. Please see Items 4 and 5 for additional information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 322605. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at 856-853-0400.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 5
D. Wrap Fee Programs ........................................................................................................................................................ 5
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services.............................................................................................................................................. 6
B. Fee Billing........................................................................................................................................................................ 7
C. Other Fees and Expenses .............................................................................................................................................. 7
D. Advance Payment of Fees and Termination ................................................................................................................... 7
E. Compensation for Sales of Securities ............................................................................................................................. 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 8
A. Methods of Analysis ........................................................................................................................................................ 8
B. Risk of Loss ..................................................................................................................................................................... 9
Item 9 – Disciplinary Information ........................................................................................................................ 10
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10
A. Code of Ethics ............................................................................................................................................................... 10
B. Personal Trading with Material Interest ......................................................................................................................... 11
C. Personal Trading in Same Securities as Clients ........................................................................................................... 11
D. Personal Trading at Same Time as Client .................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................ 11
A. Recommendation of Custodian[s] ................................................................................................................................. 11
B. Aggregating and Allocating Trades ............................................................................................................................... 12
Item 13 – Review of Accounts ............................................................................................................................. 12
A. Frequency of Reviews ................................................................................................................................................... 12
B. Causes for Reviews ...................................................................................................................................................... 12
C. Review Reports ............................................................................................................................................................. 12
Item 14 – Client Referrals and Other Compensation ........................................................................................ 12
A. Compensation Received by KIG ................................................................................................................................... 12
B. Compensation for Client Referrals ................................................................................................................................ 14
Item 15 – Custody ................................................................................................................................................. 14
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ....................................................................................................................... 14
Item 18 – Financial Information ........................................................................................................................... 14
Wrap Fee Program Brochure .............................................................................................................................. 16
Form ADV Part 2B – Brochure Supplement ....................................................................................................... 24
Privacy Policy ....................................................................................................................................................... 37
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 4 – Advisory Services
A. Firm Information
Kennedy Investment Group, Inc. (“KIG” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Corporation under the laws of the State of New Jersey.
KIG was founded in October 2003 and is owned and operated by John W. Kennedy III (CEO). This Disclosure
Brochure provides information regarding the qualifications, business practices, and the advisory services provided
by KIG.
B. Advisory Services Offered
KIG offers investment advisory services to individuals, high net worth individuals, and corporations (each referred to
as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. KIG's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Wealth Management Services
KIG provides tailored investment advisory solutions to its Clients. This is achieved through personal Client contact
and interaction while providing a broad range of comprehensive financial planning and discretionary investment
management over Client portfolios. These services are described below.
Financial Planning Services – KIG provides a variety of financial planning services to Clients. Financial planning
services involve preparing a formal financial plan, which encompass one or more areas of need including but not
limited to investment planning, retirement planning, education planning, estate planning, tax planning, insurance
planning, and other areas of a Client’s financial situation. KIG will work closely with each Client to understand their
financial situation, investment goals, objectives, and overall risk tolerance. A financial plan developed for the Client
will include general recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their portfolio or asset allocation strategy, commence,
or alter retirement savings, and/or establish education savings. KIG may also refer Clients to an accountant, attorney,
or other specialists, as appropriate for their unique situation. Financial planning recommendations pose a conflict
between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to
recommend that Clients engage the Advisor for investment management services or to increase the level of
investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are
not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the
Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no
obligation to implement the transaction through the Advisor.
Investment Management Services - KIG provides customized discretionary investment management services to its
Clients. KIG works closely with each Client to create a portfolio strategy based on their investment goals, objectives,
and risk tolerance. KIG will construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or
exchange-traded funds (“ETFs”), individual stocks, bonds, options contracts, and alternative investments to meet the
needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit
with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the
Client.
KIG’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. KIG will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
KIG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. KIG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. KIG may
recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing
cash positions as a possible hedge against market movement. KIG may recommend selling positions for reasons
that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance
of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will KIG accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such
a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as
a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed
by the Advisor.
Use of Independent Managers - KIG may recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required to authorize
and enter into an investment management agreement with the Independent Manager[s] that defines the terms in
which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and
due diligence over each Independent Manager to ensure the strategy remains aligned with Client’s investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial portfolio
recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with
an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure
(or a brochure that makes the appropriate disclosures).
Estate Planning Services- In certain circumstances, the Advisor may also provide Clients with estate planning
services. When such services are offered, the Advisor will leverage a third-party service. These services are provided
pursuant to a separate written agreement between the Client and the Advisor, and are offered for a fixed fee. The
Advisor does not provide legal services and does not hold itself out as providing legal advice.
C. Client Account Management
Prior to engaging KIG to provide investment advisory services, each Client is required to enter into an agreement
with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These
services may include:
• Establishing an Investment Strategy – KIG, in connection with the Client, will develop a portfolio strategy that
seeks to achieve the Client’s investment goals, time horizon, financial situation, and risk tolerance for each
Client.
•
Investment Management and Supervision – KIG will provide investment management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
KIG includes securities transaction fees together with its wealth management fees. Including these fees into a single
asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its wealth management services for
its Clients. The Advisor sponsors the KIG Financial Wrap Fee Program solely as a supplemental disclosure regarding
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the
Client may pay more or less in total fees than if the Client paid its own securities transaction fees. Please see
Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2025, KIG manages $633,231,923 in Client assets, all of which are managed on a discretionary
basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid quarterly in advance, pursuant to the terms of the wealth management agreement.
Fees are based on the market value of assets under management at the end of the prior quarter. Wealth management
fees are based on the following schedule:
Assets Under Management ($)
Annual Rate (%)
Up to $200,000
$200,001 to $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $7,500,000
$7,500,001 and over
1.75%
1.50%
1.00%
0.75%
0.50%
0.25%
The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
KIG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
KIG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to
terminate an account or the overall relationship. If assets of $100,000 or more are deposited into or withdrawn from
the Client’s account[s] during a billing cycle, the Advisor’s fee will be adjusted in the next billing cycle to reflect the
prorated fee difference.
Use of Independent Managers - As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment
portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn
any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described
above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will
reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms
of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s]
with the Independent Manager.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Estate Planning Services- The Advisor offers estate planning services for a fixed engagement fee. Fixed fees range up
to $1,500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall
relationship with the Advisor. An estimate for total costs will be provided to the Client prior to engaging for these services.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian.
The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual
rate divided by 4) to the total assets under management with KIG at the end of the prior quarter. Clients will be provided
with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are
urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian,
as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees
to be deducted by KIG to be paid directly from their account[s] held by the Custodian as part of the investment advisory
agreement and separate account forms provided by the Custodian.
Use of Independent Managers - For Client accounts implemented through an Independent Manager, the Client’s
overall fee will include KIG’s wealth management fee (as noted above) plus wealth management fees and/or platform
fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating
the Client’s fees and deducting all fees from the Client’s account[s].
Estate Planning Services- Fixed engagement fees for the Advisor’s estate planning services are invoiced and due
upon completion of the agreed upon deliverable[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of
the Client’s account[s]. The Advisor includes securities transactions costs as part of its overall wealth management
fee through the KIG Financial Wrap Fee Program. Securities transaction fees for Client-directed trades may be
charged back to the Client. Please see Item 4.D. as well as Appendix 1 – Wrap Fee Program Brochure
In addition, all fees paid to KIG for wealth management services are separate and distinct from the expenses charged
by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s
prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund
expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee.
A Client may be able to invest in these products directly, without the services of KIG, but would not receive the
services provided by KIG which are designed, among other things, to assist the Client in determining which products
or services are most appropriate for each Client’s financial situation and objectives. In certain instances, Clients will
be charged a fee for closing an account held at Raymond James & Associates, Inc. (collectively “Raymond James”),
a FINRA-registered broker-dealer and member New York Stock Exchange/SIPC. Accordingly, the Client should
review both the fees charged by the fund[s] and the fees charged by KIG to fully understand the total fees to be paid.
Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
KIG is compensated for its wealth management services in advance of the quarter in which services are rendered.
Either party may terminate the wealth management agreement, at any time, by providing advance written notice to the
other party. The Client may also terminate the wealth management agreement within five (5) business days of signing
the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination
to the end of the quarter. The Client’s wealth management agreement with the Advisor is non-transferable without the
Client’s prior consent.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Use of Independent Managers - KIG will have the discretion to terminate the relationship with Independent Managers
if determined that an Independent Manager is no longer in the Client’s best interest. The terms for termination are
set forth in the respective agreements between the Advisor and Independent Managers.
Estate Planning Services- Either party may terminate the estate planning agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the estate planning agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope
completed by the Advisor. The Client’s estate planning agreement with the Advisor is non-transferable without the
Client’s prior consent.
E. Compensation for Sales of Securities
KIG does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
KIG does not charge performance-based fees for its investment advisory services. The fees charged by KIG are as
described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any
Client.
KIG does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge
fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
KIG offers investment advisory services to individuals, high net worth individuals, and corporations. KIG generally
does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
KIG primarily employs a fundamental analysis method in developing investment strategies for its Clients. Research
and analysis from KIG are derived from numerous sources, including financial media companies, third-party research
materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases
and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
As noted above, KIG generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. KIG will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, KIG may also buy
and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. KIG will assist Clients in determining an appropriate strategy based on
their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their
investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Options Contracts
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call," pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Digital Assets Risks
Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are
loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients
with a high risk tolerance.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving KIG or its owner. KIG values the trust Clients
place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service
provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#
322605.
Item 10 – Other Financial Industry Activities and Affiliations
Kennedy Insurance Services, Inc
KIG is affiliated with Kennedy Insurance Services, Inc (“KIS”) which is owned by John Kennedy. Advisory Persons
are also licensed as independent insurance professionals through KIS. KIS and Advisory Persons may receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Commissions generated by insurance sales do not offset wealth management fees. This practice presents a conflict
of interest in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by KIS, Advisory Persons or the Advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
KIG has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client.
This Code applies to all persons associated with KIG (“Supervised Persons”). The Code was developed to provide
general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. KIG and its
Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of KIG’s
Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that
guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request
a copy of the Code, please contact the Advisor at 856-853-0400.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
B. Personal Trading with Material Interest
KIG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased
on behalf of Clients. KIG does not act as principal in any transactions. In addition, the Advisor does not act as the
general partner of a fund, or advise an investment company. KIG does not have a material interest in any securities
traded in Client accounts.
C. Personal Trading in Same Securities as Clients
KIG allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased
on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a
conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures.
As noted above, the Advisor has adopted the Code to address insider trading (material non-public information
controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for
personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty
to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms
than Client trades, or by trading based on material non-public information. This risk is mitigated by KIG requiring
reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”).
The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While KIG allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will KIG, or any Supervised Person of KIG, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
KIG does not have discretionary authority to select the broker-dealer/custodian for custody and execution services.
The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize
KIG to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, KIG does not
have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
Where KIG does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not
incur any extra fee or cost from the Advisor associated with using a custodian not recommended by KIG. However,
the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. KIG may
recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to
the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices.
The Advisor will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.
Raymond James will serve as the Client’s “qualified custodian”. The Advisor maintains an institutional relationship
with Raymond James, whereby the Advisor receives economic benefits from Raymond James. The Advisor may also
recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered
broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. KIG maintains an
institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab. Please see
Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. KIG does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
2. Brokerage Referrals - KIG does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where KIG will place trades within
the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within
their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from
or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one
Client account from another Client’s account[s]). KIG will not be obligated to select competitive bids on securities
transactions and does not have an obligation to seek the lowest available transaction costs. These costs are
determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. KIG will execute its transactions through the Custodian as
authorized by the Client. KIG may aggregate orders in a block trade or trades when securities are purchased or sold
through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business day
must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be
done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons and periodically
reviewed by Eugene Donato, Chief Compliance Officer of KIG. Formal reviews are generally conducted at least
annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify KIG if changes occur in the Client’s personal
financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by
material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
website so that the Client may view these reports and their account activity. Client brokerage statements will include
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by KIG
KIG is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. KIG
does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third
party. KIG may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, KIG may receive
non-compensated referrals of new Clients from various third-parties. Services and fees covered by KIG’s wrap fee
program differ by Custodian and will be outlined in the account opening paperwork for each new account.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Participation in Institutional Advisor Platform – Raymond James
The Advisor has established an institutional relationship with Raymond James to assist the Advisor in managing
Client account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor
receives access to software and related support without cost because the Advisor renders investment management
services to Clients that maintain assets at Raymond James. The software and related systems support may benefit
the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian
creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over
one that does not furnish similar software, systems support, or services. Additionally, the Advisor has the following
benefits from Raymond James: financing services, receipt of duplicate Client confirmations and bundled duplicate
statements; access to a trading desk that exclusively services its institutional participants; access to block trading
which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client
accounts; and access to an electronic communication network for Client order entry and account information.
Participation in Institutional Advisor Platform – Schwab
KIG has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like KIG. As a registered investment advisor
participating on the Schwab Advisor Services platform, KIG receives access to software and related support without
cost because the Advisor renders investment management services to Clients that maintain assets at Schwab.
Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab
will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its
Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a
potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over
one that does not furnish similar software, systems support, or services.
Fees and Costs Not Included – Our wrap fee covers our advisory services and the brokerage services provided by
Schwab [including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities]. As a
result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all
fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund,
or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup)
for trades executed away from [Schwab/Custodian] at another broker-dealer, wire transfer fees and other fees and
taxes on brokerage accounts and securities transactions.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to KIG that may not benefit the Client,
including: educational conferences and events, consulting services and discounts for various service providers.
Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a
potential conflict of interest. KIG believes, however, that the selection of Schwab as Custodian is in the best interests
of its Clients.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
B. Compensation for Client Referrals
KIG does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client
referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16 – Investment Discretion
KIG generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by KIG.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be
evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such
authority. All discretionary trades made by KIG will be in accordance with each Client's investment objectives and
goals.
Item 17 – Voting Client Securities
KIG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole
responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither KIG, nor its management, have any adverse financial situations that would reasonably impair the ability of
KIG to meet all obligations to its Clients. Neither KIG, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. KIG is not required to deliver a balance sheet along with this Disclosure Brochure
as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in
the future.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Kennedy Investment Group, Inc.
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: February 6, 2026
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and
business practices for Kennedy Investment Group, Inc. (“KIG” or the “Advisor”) services when offering services
pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the KIG Disclosure
Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the
complete KIG Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure
or the KIG Disclosure Brochure, please contact the Advisor at 856-853-0400.
KIG is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information
in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority.
Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program
Brochure provides information about KIG to assist you in determining whether to retain the Advisor.
information about KIG and
its advisory persons are available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD#322605.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices
and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by
the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on January
31st, 2025.
Future Changes
From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee
Program Brochure (along with the complete KIG Disclosure Brochure) or a Summary of Material Changes shall be
provided to you annually and if a material change occurs in the business practices of KIG.
At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name
or CRD# 322605. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at
856-853-0400.
Item 3 – Table of Contents
Item 2 – Material Changes ................................................................................................................................... 16
Item 3 – Table of Contents ................................................................................................................................... 16
Item 4 – Services Fees and Compensation ........................................................................................................ 17
Item 5 – Account Requirements and Types of Clients ..................................................................................... 18
Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 18
Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 20
Item 8 – Client Contact with Portfolio Managers ............................................................................................... 20
Item 9 – Additional Information ........................................................................................................................... 20
Privacy Policy ....................................................................................................................................................... 37
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 4 – Services Fees and Compensation
A. Services
KIG provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided
as a supplement to the KIG Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along
with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting KIG
as your investment advisor.
As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, KIG includes securities transaction
fees for certain mutual funds fees, custody fees, and administrative fees (herein “Covered Costs”) as part of the
overall investment advisory fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee
Program”. The Advisor’s recommended Custodian does not charge securities transaction fees for exchange-traded
fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of
investments. The Advisor sponsors the KIG Wrap Fee Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of
Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back
to the KIG Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item
4 – Advisory Services of the Disclosure Brochure for details on KIG’s investment philosophy and related
services.
B. Program Costs
Advisory services provided by KIG are offered in a wrap fee structure whereby Covered Costs are included in the
overall investment advisory fee paid to KIG. As the level of activity in a Client’s account[s] may vary from year to year,
the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are
borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to
each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap
Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the
Client’s account[s] or to utilize securities that do not have transaction fees. As noted above, the Advisor’s
recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client accounts,
but typically charges for mutual funds and other types of investments. As such, the Advisor is incentivized to utilize
ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into
a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and
Compensation of the Disclosure Brochure for complete details on fees.
C. Fees
Wealth Management Services
Wealth management fees are paid quarterly in advance, pursuant to the terms of the wealth management agreement.
Fees are based on the market value of assets under management at the end of the prior quarter. Wealth management
fees are based on the following schedule:
Assets Under Management ($)
Annual Rate (%)
Up to $200,000
$200,001 to $500,000
$500,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $7,500,000
$7,500,001 and over
1.75%
1.50%
1.00%
0.75%
0.50%
0.25%
The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
KIG will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Wealth management fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian.
The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s
account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate
(annual rate divided by 4) to the total assets under management with KIG at the end of the prior quarter. Clients will
be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory
fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement
from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization
permitting advisory fees to be deducted by KIG to be paid directly from their account[s] held by the Custodian as part
of the investment advisory agreement and separate account forms provided by the Custodian.
In addition, all fees paid to KIG for investment advisory services or part of the Wrap Fee Program are separate and
distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable.
These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used
to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and
account reporting), and a possible distribution fee. Securities transaction fees for Client-directed trades will be
charged back to the Client. In connection with the discretionary investment management services provided by KIG,
the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered Costs noted
above, such as administrative fees and fees for trades executed away from the Custodian. The Advisor does not
control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged
by KIG to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure
Brochure (included with this Wrap Fee Program Brochure).
D. Compensation
KIG is the sponsor and portfolio manager of this Wrap Fee Program. KIG receives investment advisory fees paid by
Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of
the Client’s account[s].
Item 5 – Account Requirements and Types of Clients
KIG offers investment advisory services to individuals, high net worth individuals, and retirement plans. KIG generally
does not impose a minimum account size for establishing a relationship. Please see Item 7 – Types of Clients in the
Disclosure Brochure for additional information.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
KIG serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
KIG personnel serve as portfolio managers for this Wrap Fee Program. KIG does not serve as a portfolio manager
for any third-party Wrap Fee Programs.
Performance-Based Fees
KIG does not charge performance-based fees for its investment advisory services. The fees charged by KIG are as
described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any
Client.
Supervised Persons
KIG Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee
Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure.
Methods of Analysis
Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the
research and analysis methods employed by the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. KIG will assist Clients in determining an appropriate strategy based on
their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their
investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Options Contracts
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call," pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Digital Assets Risks
Digital assets are highly speculative and volatile investments that may become illiquid at any time. Digital assets are
loosely regulated. Clients could lose the entire value of their investment in digital assets and is only suitable for Clients
with a high risk tolerance.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on
investment risks.
Proxy Voting
KIG does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole
responsibility for proxy decisions and voting.
Item 7 – Client Information Provided to Portfolio Managers
KIG is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with
other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the
KIG Privacy Policy (included after this Wrap Fee Program Brochure).
Item 8 – Client Contact with Portfolio Managers
KIG is a full-service investment management advisory firm. Clients always have direct access to the Portfolio
Managers at KIG.
Item 9 – Additional Information
A. Disciplinary Information and Other Financial Industry Activities and Affiliations
There are no legal, regulatory or disciplinary events involving KIG or its owner. KIG values the trust Clients
place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service
provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD#
322605.
Please see Item 9 of the KIG Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement
(included with this Wrap Fee Program Brochure) for additional information on how to research the background of the
Advisor and its Advisory Persons.
Other Financial Activities and Affiliations
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation
of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure).
B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
KIG has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of
Ethics applies to all persons subject to KIG’s compliance program (our “Supervised Persons”). Complete details on
the KIG Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal
Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure).
Investments in
Review of Accounts
Client accounts are monitored on a regular and continuous basis by Advisory Persons of KIG under the supervision
of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the
Form ADV Part 2A – Disclosure Brochure.
Services and fees covered by KIG’s wrap fee program differ by Custodian and will be outlined in the account opening
paperwork for each new account.
Participation in Institutional Advisor Platform - Raymond James
The Advisor has established an institutional relationship with Raymond James to assist the Advisor in managing
Client account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Advisor
receives access to software and related support without cost because the Advisor renders investment management
services to Clients that maintain assets at Raymond James. The software and related systems support may benefit
the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the
interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian
creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over
one that does not furnish similar software, systems support, or services. Additionally, the Advisor has the following
benefits from Raymond James: financing services, receipt of duplicate Client confirmations and bundled duplicate
statements; access to a trading desk that exclusively services its institutional participants; access to block trading
which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client
accounts; and access to an electronic communication network for Client order entry and account information.
Participation in Institutional Advisor Platform - Schwab
KIG has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like KIG. As a registered investment advisor
participating on the Schwab Advisor Services platform, KIG receives access to software and related support without
cost because the Advisor renders investment management services to Clients that maintain assets at Schwab.
Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab
will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its
Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a
potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over
one that does not furnish similar software, systems support, or services.
Fees and Costs Not Included – Our wrap fee covers our advisory services and the brokerage services provided by
Schwab including custody of assets, equity trades, ETFs, and agency transactions in fixed income securities. As a
result, we have an incentive to execute transactions for your account at Schwab. Our wrap fee does not cover all
fees and costs. The fees not included in the wrap fee include charges imposed directly by a mutual fund, index fund,
or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other
fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees (such as a commission or markup)
for trades executed away from Schwab at another broker-dealer, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating Advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to KIG that may not benefit the Client,
including: educational conferences and events, consulting services and discounts for various service providers.
Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a
potential conflict of interest. KIG believes, however, that the selection of Schwab as Custodian is in the best interests
of its Clients.
Wrap Fee Program Disclosures – The benefits under a wrap fee program depend, in part, upon the size of the
account, the costs associated with managing the account, and the frequency or type of securities transactions
executed in the account. For example, a wrap fee program may not be suitable for all accounts, including but not
limited to accounts holding primarily, and for any substantial period of time, cash or cash equivalent investments,
fixed income securities or no-transaction-fee mutual funds, or any other type of security that can be traded without
commissions or other transaction fees. In order to evaluate whether a wrap fee arrangement is appropriate, the Client
should compare the agreed-upon Wrap Program Fee and any other costs associated with participating in the
Advisor’s Wrap Fee Program with the amounts that would be charged by other advisers, broker-dealers, and
custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided
under the Wrap Fee Program.
Conflict of Interest – When managing a Client's account on a wrap fee basis, the Advisor receives as compensation
for investment advisory services, the balance of the total wrap fee that is paid by the Client after custodial, trading
and other management costs (including execution and transaction fees) have been deducted. Accordingly, the
Advisor has a conflict of interest because there is a financial incentive to maximize the Advisor’s compensation by
seeking to reduce or minimize the total costs incurred in the Client’s account[s] that are subject to a wrap fee.
Schwab and other custodians have eliminated transaction fees for online trades of U.S. equities, ETFs and options
(subject to $0.65 per contract fee). This means that, in most cases, when the Advisor buys and sells these types of
securities, the Advisor will not have to pay any commissions to Schwab. The Client is encouraged to review Schwab’s
pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If the
Client chooses to enter into a wrap fee arrangement, the total cost to invest could exceed the cost of paying for
brokerage and advisory services separately. To see what the Client would pay for transactions in a non-wrap account
please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide.
Please see
Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program
Brochure) for details on additional compensation that may be received by KIG or its Advisory Persons. Each Advisory
Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside
business activities and the associated compensation.
Client Referrals from Solicitors
KIG does not engage paid solicitors for Client referrals.
Financial Information
Neither KIG, nor its management, have any adverse financial situations that would reasonably impair the ability of
KIG to meet all obligations to its Clients. Neither KIG, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. KIG is not required to deliver a balance sheet along with this Disclosure Brochure
as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in
the future.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Form ADV Part 2B – Brochure Supplement
for
John W. Kennedy, AAMS®, CFP®
CEO
Effective: February 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John
W. Kennedy, AAMS®, CFP® (CRD# 2453669), in addition to the information contained in the Kennedy Investment
Group, Inc. (“KIG” or the “Advisor”, CRD# 322605) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the KIG Disclosure Brochure or this Brochure
Supplement, please contact us at 856-853-0400.
Additional information about Mr. Kennedy is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2453669.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Educational Background and Business Experience
John W. Kennedy, AAMS®, CFP®, born in 1971, is dedicated to advising Clients of KIG as the CEO. Mr. Kennedy
earned a Bachelor's degree in Arts and Sciences from Rutgers University in 1993. Additional information regarding
Mr. Kennedy’s employment history is included below.
Employment History:
CEO, Kennedy Investment Group, Inc.
Financial Planner, Kennedy Investment Group
Registered Representative, Raymond James Financial Services, Inc.
Registered Representative, Edward Jones
Registered Representative, Fiserv Investor Services, Inc.
Registered Representative, MDS Securities Incorporated
Registered Representative, Edward D. Jones & Co., L.P.
Owner, Kennedy Insurance Services, Inc.
10/2022 to Present
05/2004 to 10/2022
05/2004 to 10/2022
04/1998 to 05/2004
09/1997 to 04/1998
10/1995 to 09/1997
06/1994 to 10/1995
08/2009 to Present
Accredited Asset Management Specialist™ (“AAMS®”)
Individuals who hold the AAMS® designation have completed a course of study encompassing investments,
insurance, tax, retirement, and estate planning issues. Additionally, individuals must pass an end-of-course
examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life
situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a disciplinary
process. Designees renew their designation every two-years by completing 16 hours of continuing education,
reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure requirements.
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED
FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard
of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP®
certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas
include insurance planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and
apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in order to
maintain the right to continue to use the CFP® marks:
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP®.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Kennedy. Mr. Kennedy has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Kennedy.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Kennedy.
However, we do encourage you to independently view the background of Mr. Kennedy on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2453669.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Kennedy is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Kennedy’s role with KIG. As an insurance professional, Mr. Kennedy will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Kennedy is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Kennedy or the Advisor. Mr. Kennedy spends approximately 10% of his time per month in this capacity.
Mr. Kennedy is 100% owner of Kennedy Insurance Services. All fixed insurance sales will be run through Kennedy
Insurance Sales. Mr. Kennedy spends less than 5% of his time on this activity.
Mr. Kennedy is the 100% owner of Kennedy Cellars, an instructional winemaking facility and retail winery. Mr.
Kennedy spends less than 5% of his time on this activity.
Item 5 – Additional Compensation
Mr. Kennedy has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Kennedy serves as the CEO of KIG and is supervised by Eugene Donato, the Chief Compliance Officer. Mr.
Donato can be reached at 856-853-0400.
KIG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of KIG. Further, KIG is subject to regulatory oversight by various
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
agencies. These agencies require registration by KIG and its Supervised Persons. As a registered entity, KIG is
subject to examinations by regulators, which may be announced or unannounced. KIG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Form ADV Part 2B – Brochure Supplement
for
Keith R. Hering, AAMS®, CIMA®, CRPS®
Managing Director
Effective: February 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Keith
R. Hering, AAMS®, CIMA®, CRPS® (CRD# 1496018), in addition to the information contained in the Kennedy
Investment Group, Inc. (“KIG” or the “Advisor”, CRD# 322605) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the KIG Disclosure Brochure or
this Brochure Supplement, please contact us at 856-853-0400.
Additional information about Mr. Hering is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1496018.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Educational Background and Business Experience
Keith R. Hering, AAMS®, CIMA®, CRPS®, born in 1962, is dedicated to advising Clients of KIG as a Managing
Director. Mr. Hering earned a Bachelors of Science degree in Finance from The Pennsylvania State University in
1986. Additional information regarding Mr. Hering’s employment history is included below.
Employment History:
10/2022 to Present
Managing Director, Kennedy Investment Group, Inc., d/b/a Hering Financial
Services, Inc.
Financial Advisor, Raymond James Financial Services Advisors, Inc
Registered Representative, Raymond James Financial Services, Inc.
Registered Representative, Edward Jones
Registered Representative, Ernst & Company
05/2005 to 10/2022
05/2004 to 10/2022
07/1990 to 05/2004
01/1990 to 07/1990
Accredited Asset Management Specialist™ (“AAMS®”)
Individuals who hold the AAMS® designation have completed a course of study encompassing investments,
insurance, tax, retirement, and estate planning issues. Additionally, individuals must pass an end-of-course
examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life
situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a
disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing
education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure
requirements.
Certified Investment Management Analyst™ (“CIMA®”)
The CIMA® certification signifies that an individual has met initial and ongoing experience, ethical, education, and
examination requirements for investment management consulting, including advanced investment management
theory and application. To earn CIMA® certification, candidates must: submit an application, pass a background
check and have an acceptable regulatory history; pass an online Qualification Examination; complete an in-person
or online executive education program at an AACSB® accredited university business school; pass an online
Certification Examination; and have an acceptable regulatory history as evidenced by FINRA Form U-4 or other
regulatory requirements and have three years of financial services experience at the time of certification.
CIMA® certificates must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules
and Guidelines for Use of the Marks. CIMA® designees must report 40 hours of continuing education credits,
including two ethics hours every two years to maintain the certification. The designation is administered through the
Investment Management Consultants Association™ (IMCA®).
Chartered Retirement Plans Specialist (“CRPS®”)
Individuals who hold the CRPS® designation have completed a course of study encompassing design, installation,
maintenance and administration of retirement plans. Additionally, individuals must pass an end-of-course
examination that tests their ability to synthesize complex concepts and apply theoretical concepts to real-life
situations. All designees have agreed to adhere to Standards of Professional Conduct and are subject to a
disciplinary process. Designees renew their designation every two-years by completing 16 hours of continuing
education, reaffirming adherence to the Standards of Professional Conduct and complying with self-disclosure
requirements.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Hering. Mr. Hering has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Hering.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Hering.
However, we do encourage you to independently view the background of Mr. Hering on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1496018.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Hering is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Hering’s role with KIG. As an insurance professional, Mr. Hering will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Hering is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Hering or the Advisor. Mr. Hering spends approximately 1% of his time per month in this capacity.
All fixed insurance sales will be run through Kennedy Insurance Services, Inc.
Item 5 – Additional Compensation
Mr. Hering has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Hering serves as a Managing Director of KIG and is supervised by Eugene Donato, the Chief Compliance
Officer. Mr. Donato can be reached at 856-853-0400.
KIG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of KIG. Further, KIG is subject to regulatory oversight by various
agencies. These agencies require registration by KIG and its Supervised Persons. As a registered entity, KIG is
subject to examinations by regulators, which may be announced or unannounced. KIG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Form ADV Part 2B – Brochure Supplement
for
Henry J. Schroeder, CFP®
President
Effective: February 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Henry
J. Schroeder, CFP ® (CRD# 4980239), in addition to the information contained in the Kennedy Investment Group,
Inc. (“KIG” or the “Advisor”, CRD# 322605) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the KIG Disclosure Brochure or this Brochure
Supplement, please contact us at 856-853-0400.
Additional information about Mr. Schroeder is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4980239.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Educational Background and Business Experience
Henry J. Schroeder, CFP®, born in 1982, is dedicated to advising Clients of KIG as the President. Mr. Schroeder
earned a Bachelor of Arts degree in Political Science and History from the University Of Pittsburgh in 2005. Additional
information regarding Mr. Schroeder’s employment history is included below.
Employment History:
President, Kennedy Investment Group, Inc.
Financial Advisor, Raymond James Financial Services Advisors, Inc
Registered Representative, Raymond James Financial Services, Inc.
Financial Advisor, Advice and Planning Services
10/2022 to Present
03/2018 to10/2022
03/2018 to 10/2022
04/2012 to 03/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Schroeder. Mr. Schroeder has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Schroeder.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Schroeder.
However, we do encourage you to independently view the background of Mr. Schroeder on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4980239.
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by CERTIFIED
FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to
hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard
of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that
govern professional engagements with clients. Currently, more than 87,000 individuals have obtained CFP®
certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
• Education – Complete an advanced college-level course of study addressing the financial planning subject
areas that CFP Board’s studies have determined as necessary for the competent and professional delivery
of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States
college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas
include insurance planning and risk management, employee benefits planning, investment planning, income
tax planning, retirement planning, and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case
studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and
apply one’s knowledge of financial planning to real-world circumstances;
• Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining
the ethical and practice standards for CFP® professionals.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Individuals who become certified must complete the following ongoing education and ethics requirements in order to
maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary standard of
care. This means CFP® professionals must provide financial planning services in the best interests of their
clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s
enforcement process, which could result in suspension or permanent revocation of their CFP®.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Schroeder is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Schroeder’s role with KIG. As an insurance professional, Mr. Schroeder will receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Mr. Schroeder is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Schroeder or the Advisor. Mr. Schroeder spends approximately 10% of his time per month in this
capacity. All fixed insurance sales will be run through Kennedy Insurance Services, Inc.
Item 5 – Additional Compensation
Mr. Schroeder has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Schroeder serves as the President of KIG and is supervised by Eugene Donato, the Chief Compliance Officer.
Mr. Donato can be reached at 856-853-0400.
KIG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of KIG. Further, KIG is subject to regulatory oversight by various
agencies. These agencies require registration by KIG and its Supervised Persons. As a registered entity, KIG is
subject to examinations by regulators, which may be announced or unannounced. KIG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Form ADV Part 2B – Brochure Supplement
for
Alexa L. Comey
Financial Advisor and Senior Planner
Effective: February 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Alexa
L. Comey (CRD# 7196987) in addition to the information contained in the Kennedy Investment Group, Inc. (“KIG” or
the “Advisor”, CRD# 322605) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if
you have any questions about the contents of the KIG Disclosure Brochure or this Brochure Supplement, please
contact us at 856-853-0400.
Additional information about Ms. Comey is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7196987.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Educational Background and Business Experience
Alexa L. Comey, born in 1996, is dedicated to advising Clients of KIG as a Financial Advisor and Senior Planner. Ms.
Comey earned a Bachelor of Science degree in Finance from Westchester University in 2016. Additional information
regarding Ms. Comey’s employment history is included below.
Employment History:
Financial Advisor and Senior Planner, Kennedy Investment Group, Inc.
Investment Advisor, Raymond James Financial Services Advisors, Inc
Registered Representative, Raymond James Financial Services, Inc.
Registered Representative, Ameriprise Financial Services, LLC
Financial Intern, Securian Financial Services, Inc.
Unemployed, Unemployed
Registered Representative, Pruco Securities LLC
Marketing Coordinator, Injury Care Center
Server, PJ Whelihan Restaurant Group
10/2022 to Present
12/2021 to 08/2022
12/2021 to 08/2022
09/2020 to 11/2021
06/2020 to 10/2020
03/2020 to 06/2020
09/2019 to 03/2020
08/2018 to 09/2019
08/2017 to 09/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Comey. Ms. Comey has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Comey.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Ms. Comey.
However, we do encourage you to independently view the background of Ms. Comey on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
7196987.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Ms. Comey is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Ms. Comey’s role with KIG. As an insurance professional, Ms. Comey will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Ms. Comey
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Ms. Comey
or the Advisor. Ms. Comey spends approximately 10% of her time per month in this capacity. All fixed insurance sales
will be run through Kennedy Insurance Services, Inc.
Item 5 – Additional Compensation
Ms. Comey has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Ms. Comey serves as a Financial Advisor and Senior Planner of KIG and is supervised by Eugene Donato, the
Chief Compliance Officer. Mr. Donato can be reached at 856-853-0400.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
KIG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of KIG. Further, KIG is subject to regulatory oversight by various
agencies. These agencies require registration by KIG and its Supervised Persons. As a registered entity, KIG is
subject to examinations by regulators, which may be announced or unannounced. KIG is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Form ADV Part 2B – Brochure Supplement
for
James F. Messner, CFA®
Senior Portfolio Strategist
Effective: February 6, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of James
F. Messner, CFA® (CRD# 7941236) in addition to the information contained in the Kennedy Investment Group, Inc.
(“KIG” or the “Advisor”, CRD# 322605) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the KIG Disclosure Brochure or this Brochure
Supplement, please contact us at 856-853-0400.
Additional information about Mr. Messner is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7941236.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Item 2 – Educational Background and Business Experience
James F. Messner, CFA®, born in 1986, is dedicated to advising Clients of KIG as s Senior Portfolio Strategist. Mr.
Messner earned a Bachelor of Science in Finance from Rutgers University in 2009. Additional information regarding
Mr. Messner’s employment history is included below.
Employment History:
Senior Portfolio Strategist, Kennedy Investment Group, Inc.
Research Analyst, Glenmede Investment Management, LP
05/2024 to Present
11/2013 to 04/2024
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded
by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over
two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical
and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio
management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable
professional experience in the investment decision-making process and must commit to abide by, and annually
reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a
trademark owned by CFA® Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Messner. Mr. Messner has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Messner.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Messner.
However, we do encourage you to independently view the background of Mr. Messner on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
7941236.
Item 4 – Other Business Activities
Mr. Messner is dedicated to the investment advisory activities of KIG’s Clients. Mr. Messner does not have any other
business activities.
Item 5 – Additional Compensation
Mr. Messner is dedicated to the investment advisory activities of KIG’s Clients. Mr. Messner does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Messner serves as a Senior Portfolio Strategist of KIG and is supervised by Eugene Donato, the Chief
Compliance Officer. Mr. Donato can be reached at 856-853-0400.
KIG has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of KIG. Further, KIG is subject to regulatory oversight by various
agencies. These agencies require registration by KIG and its Supervised Persons. As a registered entity, KIG is
subject to examinations by regulators, which may be announced or unannounced. KIG is required to periodically
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Advisor.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
Privacy Policy
Effective: February 6, 2026
Our Commitment to You
Kennedy Investment Group, Inc. (“KIG” or the “Advisor”) is committed to safeguarding the use of personal information
of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in
our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. KIG (also referred to as "we", "our" and "us”)
protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
KIG does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how
we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s
personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
to: processing
No
Not Shared
Yes
Yes
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
KIG does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with financial
institutions where you are a customer and where KIG or the client has a
formal agreement with the financial institution. We will only share
information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and persons
that we believe to be your authorized agent[s] or representative[s].
No
Not Shared
Information About Former Clients
KIG does not disclose and does not intend to disclose, non-public personal
information to non-affiliated third parties with respect to persons who are
no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 856-853-0400.
Kennedy Investment Group, Inc.
196 Delaware St., West Deptford, NJ 08086
Phone: 856-853-0400