Overview
- Headquarters
- Salem, OR
- Average Client Assets
- $3.3 million
- Minimum Account Size
- $500,000
- SEC CRD Number
- 292600
Fee Structure
Primary Fee Schedule (ADV PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,750 | 1.38% |
| $5 million | Negotiable | Negotiable |
| $10 million | Negotiable | Negotiable |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 64.43%
- Total Client Accounts
- 2,083
- Discretionary Accounts
- 2,083
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
Primary Brochure: ADV PART 2A BROCHURE (2026-03-23)
View Document Text
KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 1 – Cover Page
KEUDELL MORRISON WEALTH MANAGEMENT, LLC
235 Front Street SE, Suite 300
Salem, OR 97301
(971) 209-4500
March 23, 2026
http://www.kmwm.com/
This Brochure provides information about the qualifications and business practices of Keudell
Morrison Wealth Management, LLC. If you have any questions about the contents of this
Brochure, please contact us at (971) 209-4500 or mandy@kmwm.com. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Additional information about Keudell Morrison Wealth Management, LLC is available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Keudell
Morrison Wealth Management, LLC is #292600.
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 2 – Material Changes
The material changes since the last annual update on March 21, 2025, are described below.
• None
is also
included with our Brochure on
We will ensure that all current clients receive a Summary of Material Changes to this and
subsequent Brochures within 120 days of the close of our business’ fiscal year. A Summary of
the SEC’s website at
Material Changes
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Keudell Morrison Wealth
Management, LLC is #292600. We may further provide other ongoing disclosure information
about material changes as necessary and will further provide you with a new Brochure as necessary
based on changes or new information, at any time, without charge.
Currently, our Brochure may be requested by contacting Amanda Shine, Chief Compliance Officer
of Keudell Morrison Wealth Management, LLC at (971) 209-4500 or mandy@kmwm.com. Our
Brochure is provided free of charge.
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Form ADV Part 2A – Firm Brochure
Item 3 – Table of Contents
Page
Item 1 – Cover Page ........................................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ............................................................................................................................ 1
Item 5 – Fees and Compensation ................................................................................................................... 3
Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................... 5
Item 7 – Types of Clients ................................................................................................................................ 6
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 7
Item 9 – Disciplinary Information ............................................................................................................... 13
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 14
Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal Trading ..... 15
Item 12 – Brokerage Practices ..................................................................................................................... 17
Item 13 – Review of Accounts ..................................................................................................................... 19
Item 14 – Client Referrals and Other Compensation .............................................................................. 20
Item 15 – Custody........................................................................................................................................... 22
Item 16 – Investment Discretion ................................................................................................................. 23
Item 17 – Voting Client Securities .............................................................................................................. 24
Item 18 – Financial Information .................................................................................................................. 25
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 4 – Advisory Business
A
Keudell Morrison Wealth Management, LLC (“Keudell Morrison” “we” or “us”) is a
registered investment advisor located in Salem, Oregon and registered with the SEC since
April 2018. Keudell Morrison’s founders and owners are Michael Morrison, Larry
Keudell, Joel Blount, Stephanie Smith and Amanda Shine.
B
Keudell Morrison serves individuals and businesses in all areas of investment management
and financial planning, including asset management, investment consulting, education
funding, risk management, tax management, retirement planning, estate planning services,
and employee and executive benefits. While we do not provide tax or legal advice, we
provide a full range of services coupled in coordination with other advisors such as
attorneys and Certified Public Accountants.
C
All of our clients may impose restrictions on investing in certain securities, industries, or
sectors, but must advise us of any such restrictions in writing. Keudell Morrison provides
tailored advisory services to meet our clients’ particular needs. We work individually
and with other advisers to build and protect our separate account clients’ wealth over the
long term. We ask you to complete an investor questionnaire to assist us in developing
investment objectives that reflect your unique goals, needs, risk tolerance and time
horizon. You may have multiple accounts with us, and each may have different
investment objectives. We offer to review your questionnaire with you at least annually
to be sure the objectives continue to meet your particular needs and goals.
See Item 8 for a description of our investment strategy.
D
We offer a Wrap Fee program, as indicated in the Wrap Free Brochure (Appendix 1).
E
We manage $921,506,676 of Client assets on a discretionary basis. This amount was
calculated as of December 31, 2025.
In addition to the advisory services, the wrap fee program includes certain brokerage
services of Charles Schwab & Co., Inc. (Schwab) a broker-dealer registered with the
Securities and Exchange Commission and a member of FINRA and SIPC. We are
independently owned and operated and not affiliated with Schwab. Schwab will act solely
as a broker-dealer and not as an investment advisor to you. It will have no discretion over
your account and will act solely on instructions it receives from us. Schwab has no
responsibility for our services and undertakes no duty to you to monitor our management
of your account or other services we provide to you. Schwab will hold your assets in a
brokerage account and buy and sell securities ad execute other transactions when we
instruct them to. We do not open the account for you.
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Form ADV Part 2A – Firm Brochure
For Transaction Based Pricing
The advisor pays Schwab transaction costs for each executed trade in wrap fee accounts.
As a result, we have financial incentive to limit orders for wrap fee accounts because trades
increase our transaction costs. Thus, an incentive exists to trade less frequently in a wrap
fee program.
We do not charge our clients higher advisory fees based on their trading activity, but you
should be aware that we have an incentive to limit our trading in your account(s) because
we are charged for executed trades.
For Asset Based Pricing
The advisor pays Schwab a single asset-based fee in lieu of transaction-based commissions.
The fees we pay Schwab are assessed on certain assets in your account(s) at Schwab. We
have a conflict of interest because we have a financial incentive to maximize our
compensation by seeking to reduce or minimize the total costs incurred in your account(s)
subject to a wrap fee.
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 5 – Fees and Compensation
A
Keudell Morrison Wealth Management, LLC charges annual fees for managing Clients’
portfolios. The fees charged generally vary between 0.50% and 1.5% of assets under
management according to the amount of assets under management and the specific needs
of the client; however, fees may be negotiable. We may charge client a fixed fee each
billing period as agreed upon in the Agreement. Keudell Morrison has an asset minimum
of $500,000. We will make exceptions to this minimum under certain circumstances.
Keudell Morrison’s standard fee schedule is:
Market Value of Account(s) Annual Advisory Fee
Under $499,999
1.50%
$500,000 – $999,999
1.25%
$1,000,000 – $1,999,999
1.00%
$2,000,000 and over
Negotiable
B
We bill Client monthly fees in arrears and concurrently send the custodian a notice of the
amount of the fee to be deducted from the Client’s account. Fees are paid directly to us
from the account by the custodian upon our submission of an invoice to custodian.
Payment of fees may result in the liquidation of Client’s securities if there is insufficient
cash in the account. The fee is based on the average daily market value of the Client’s
account for the preceding month when based on the assets under management. We do not
charge differently for cash balances or separately managed accounts.
C
Clients pay brokerage transaction costs and other charges directly to the custodian. See
Item 12 – Brokerage Practices. Clients may be required to pay, in addition to Keudell
Morrison’s fee, a proportionate share of any exchange traded fund’s or mutual fund’s fees
and charges. For example, mutual fund operating expenses are paid out of the fund and
are an additional expense incurred by the Client.
D
Investment advisory fees are generally billed monthly, in arrears. Clients with separately
managed accounts are billed quarterly, in arrears. Retirement plan clients are also billed
quarterly, in arrears.
New accounts are pro-rated from the time we begin charging a fee to the Client. Fees for
partial months at the commencement or termination of this Agreement will be billed on a
pro-rated basis contingent on the number of days the account was open during the month.
Additionally, all service agreements may be terminated at any time by providing us with
15 days written notice. Any compensation paid for services beyond the time the agreement
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
was terminated in writing will be refunded to the Client.
If Keudell Morrison has provided the Client a copy of its Form ADV Part 2 less than forty-
eight hours prior to entering into any investment advisory contract or if Keudell Morrison
provided the Client a copy of its Form ADV Part 2 at the time of entering into the
investment advisory agreement, then the Client may terminate the investment advisory
agreement without penalty within five business days after entering into the contract.
Alternatively, the investment advisory agreement may be terminated at any time by either
party by providing 15 days written notice to the other party.
E
Certain investment advisor representatives of Keudell Morrison are also licensed to sell
insurance in one or more states, either through a licensed general insurance agency or as
direct agent representative of a specific insurance company. Insurance related business is
transacted with advisory Clients and individuals may receive commissions from
insurance products sold to Clients. Clients are advised that the fees paid to Keudell
Morrison for investment advisory services are separate and distinct from the commissions
earned by any individual for selling Clients other insurance products. If requested by a
Client, we will disclose the amount of commission expected to be paid.
The receipt of commissions by an individual associated with the firm presents a conflict
of interest. As fiduciaries we must act primarily for the benefit of investment advisory
Clients. As such, we will only transact insurance related business with Clients when fully
disclosed, suitable, and appropriate. Further, we must determine in good faith that any
commissions paid to our representatives are appropriate. Clients are informed that they
are under no obligation to use any individual associated with Keudell Morrison for
insurance products or services. Clients may use any insurance firm or agent they choose.
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Form ADV Part 2A – Firm Brochure
Item 6 – Performance-Based Fees and Side-By-Side Management
Keudell Morrison does not charge any performance-based fees for its services or perform side by
side management. Accordingly, this item is not applicable to our firm.
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Form ADV Part 2A – Firm Brochure
Item 7 – Types of Clients
We provide investment advice to individuals, high net worth individuals, businesses, not for profit
organizations and pension & profit sharing plans. Because each Client is unique, they must be
willing to be involved in the planning and ongoing processes. Such involvement does not have to
be time consuming, however we want our Clients to remain informed and have a sense of security
about their investments. Keudell Morrison has an asset minimum of $500,000. We will make
exceptions to this minimum under certain circumstances.
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A
Our Methods of Analysis and Investment Strategies
KMWM’s investment philosophy is based on Modern Portfolio Theory, which refers to
the process of attempting to reduce risk in a portfolio through systematic diversification
across asset classes, including but not limited to common stocks, corporate bonds,
government bonds, commodities, and real estate investment trusts. We consider
ourselves global investment managers and attempt to add additional diversification by
including non-U.S. investments to clients’ portfolios. We emphasize the analysis of
mutual funds, exchange-traded funds, and separately managed accounts (SMA’s) in our
selection of the investments that comprise our clients’ portfolios.
Representatives may use additional methods of analysis to manage the accounts of their
clients. Following are typical methods of analysis that representatives may use; however,
clients should inquire of their specific representative the particular method the
representative intends to use in managing the client's account:
Fundamental Analysis
Fundamental analysis uses publicly available data in the evaluation of a security's value.
Although most analysts use fundamental analysis to value common stocks, this method
of valuation can be used for just about any type of security. For example, an investor can
perform fundamental analysis on a bond's value by looking at economic factors such as
interest rates and the overall state of the economy. He can also look at information about
the bond issuer, such as potential changes in credit ratings.
For stocks and equity instruments, this method uses revenues, earnings, future growth,
return on equity, profit margins and other data to determine a company's underlying value
and potential for future growth. In terms of common stocks, fundamental analysis
focuses on the financial statements of the company being evaluated.
Fundamental analysts study anything that can affect a security’s value including
macroeconomic factors such as the overall economy and industry conditions, and
microeconomic factors such as financial conditions and company management. The end
goal of fundamental analysis is to produce a quantitative value that an investor can
compare with a security's current price, thus indicating whether the security is
undervalued or overvalued.
Technical Analysis
Technical analysis is used to attempt to forecast the price movement of virtually any
tradable instrument that is generally subject to forces of supply and demand, including
common stocks, bonds, futures and currency pairs. In fact, technical analysis can be
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Form ADV Part 2A – Firm Brochure
viewed as simply the study of supply and demand forces as reflected in the market price
movements of a security. It is most commonly applied to price changes, but some
analysts may additionally track numbers other than just price, such as trading volume or
open interest figures.
Over the years, numerous technical indicators have been developed by analysts in
attempts to accurately forecast future price movements. Some indicators are focused
primarily on identifying the current market trend, including support and resistance areas,
while others are focused on determining the strength of a trend and the likelihood of its
continuation. Commonly used technical indicators include trend-lines and multiple
moving averages, such as the 50-day moving average and the 200-day moving average.
Economic (Cyclical) Analysis
Economic analysis takes into consideration economic cycles in order to predict how
various sectors of the market and a market index will perform. Stocks in consumer
staples such as food and household products may be appropriate in one cycle while in a
period of recovery consumer discretionary stocks may become more attractive. The
expectation of rising or falling interest rates during economic cycles can also affect risk
premiums. This type of analysis is useful over longer periods of time for portfolio
planning and allocation, but does not generally provide a basis for day-to-day investment
management.
Mutual Fund and ETF Analysis
In analyzing mutual funds and ETFs, we heavily scrutinize the experience and track
record of the portfolio managers to determine if they have demonstrated the ability to
invest successfully in varying economic conditions. We continuously monitor the funds
in an attempt to determine if they are deviating from their stated investment strategies.
We also evaluate the fees of each fund to ensure they are reasonable for the asset class we
are investing in. A risk of our mutual fund and ETF analysis is that, as in all investments,
past performance does not guarantee future results. A manager who has been successful
in the past may not be able to replicate that success in the future. In addition, managers
of different mutual funds and ETF’s may purchase the same security in a client’s
portfolio, increasing the risk to the client if that security were to fall in value. There is
also a risk that a manager may deviate from the stated investment mandate or strategy of
the fund, which could make the fund less suitable for the client's portfolio. We
specifically rely on Morningstar for our mutual fund and ETF analytical data.
Sources of information
KMWM subscribes to numerous financial newspapers, investment magazines, trade
association publications, and research services including The Wall Street Journal, The
Economist, Ned Davis Research, Mauldin Economics, Cass Freight Index, Alpine Macro
and Hedgeye Risk Management. In addition, KMWM also uses free online resources
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
including but not limited to FRED (Federal Reserve Economic Database), The IMF
(International Monetary Fund), The World Factbook – Central Intelligence Agency, The
Atlanta Federal Reserve’s GDP Now, US Department of Labor, The Congressional
Budget Office, and the Bureau of Economic Analysis.
Risk of Errors in Investment Decisions
There is a risk that our judgment about the attractiveness, relative value, or potential
appreciation of a particular security or market sector, or about the timing of investment
purchases or sales, may prove to be incorrect, resulting in losses to a client's account.
The success of KMWM’s strategy for an account or portfolio is subject to KMWM's
ability to continually analyze and select appropriate mutual fund, ETF, and SMA
investments, and allocate and re-allocate the investments consistent with the intended
investment objectives and risk parameters of the client.
Investment Strategies & Risks
We reserve the right to employ a number of investment strategies in pursuit of the
investment objectives for client portfolios, including long-term investments (investments
expected to be held for more than a year) and short-term investments (investments
expected to be held for less than a year). In general, clients should expect that our
strategies will emphasize long-term investments in common stocks, bonds, mutual funds,
and ETF’s. Portfolio composition and allocation at any given time will vary based on our
assessment of current market conditions and the relative risk and reward of particular
investments.
Additional Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following
investment risks:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as
much as a dollar next year, because purchasing power is eroding at the rate of
inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
carry a higher risk of profitability than an electric company, which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
B
We use our best judgment and good faith efforts in rendering services to Client. We
cannot warrant or guarantee any particular level of account performance, or that an
account will be profitable over time. Not every investment recommendation we make
will be profitable. Investing in securities involves risk of loss that Clients should be
prepared to bear. Clients assume all market risk involved in the investment of account
assets. Investments are subject to various market, currency, economic, political, and
business risks.
It is the responsibility of the Client to give us complete information and to notify us of
any changes in financial circumstances or goals.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you
withdraw the assets from your employer's retirement plan and roll the assets over to an
individual retirement account ("IRA") that we will manage on your behalf. If you elect to
roll the assets to an IRA that is subject to our management, we will charge you an asset
based fee as set forth in the agreement you executed with our firm. This practice presents
a conflict of interest because persons providing investment advice on our behalf have an
incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
company plan. Also, current employees can sometimes move assets out of their company
plan before they retire or change jobs. In determining whether to complete the rollover to
an IRA, and to the extent the following options are available, you should consider the
costs and benefits of:
An employee will typically have four options:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we
encourage you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here
are a few points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address
your needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu
than IRAs.
b. Employer retirement plans may have unique investment options not available
to the public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand
the cost structure of the share classes available in your employer's retirement
plan and how the costs of those share classes compare with those available in
an IRA.
b. You should understand the various products and services you might take
advantage of at an IRA provider and the potential costs of those products and
services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially
delay your required minimum distribution beyond age 72.
6. Your 401k may offer more liability protection than a rollover IRA; each state may
vary. Generally, federal law protects assets in qualified plans from creditors. Since
2005, IRA assets have been generally protected from creditors in bankruptcies.
However, there can be some exceptions to the general rules so you should consult with an
attorney if you are concerned about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
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8. IRA assets can be accessed any time; however, distributions are subject to ordinary
income tax and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses, or the
purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at
a lower capital gains tax rate.
It is important that you understand the differences between these types of accounts and to
decide whether a rollover is best for you. Prior to proceeding, if you have questions
contact your investment adviser representative, or call our main number as listed on the
cover page of this brochure.
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Item 9 – Disciplinary Information
Keudell Morrison is required to disclose all material facts regarding any legal or disciplinary event
that would be material to your evaluation of our firm, or the integrity of our management.
In order to avoid the time and expense associated with arbitration, on September 26, 2008,
without admitting or denying any allegations, Larry Keudell reached a settlement over a disputed
claim with a client. Mr. Keudell made no payment towards the settlement and the matter did not
result in any fine, or regulatory action against him. Keudell Morrison remains committed to
observing the highest standards of integrity and regulatory compliance in all aspects of our
operations. We welcome any inquiries regarding this matter.
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Item 10 – Other Financial Industry Activities and Affiliations
As disclosed in Section 5 above, certain investment advisor representatives of Keudell Morrison
are also licensed as insurance agents in one or more states, either through a licensed general
insurance agency or as direct agent representative of a specific insurance company. The conflicts
of interest associated with the above arrangements and how these conflicts are addressed are
described in Section 5E, above.
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Item 11 – Code of Ethics, Participation or Interest in Client Transaction & Personal
Trading
A
Keudell Morrison has a Code of Ethics which all employees are required to follow.
The Code of Ethics outlines our high standard of business conduct, and fiduciary duty
to Clients. The Code of Ethics includes provisions relating to the confidentiality of
Client information, a prohibition on insider trading, a prohibition of rumor mongering,
restrictions on the acceptance of significant gifts, the reporting of certain gifts and
business entertainment items, and personal securities trading procedures, among other
things.
A copy of the code of ethics is available to any Client or prospective Client upon
request by contacting Amanda Shine at (971) 209-4500 or mandy@kmwm.com.
B, C, D We do not own or manage any companies or investments that we advise our Clients to
buy.
Keudell Morrison or individuals associated with our firm may buy and sell some of the
same securities for their own account that Keudell Morrison buys and sells for its
Clients. When appropriate, we will purchase or sell securities for Clients before
purchasing the same for our account or allowing representatives to purchase or sell the
same for their own account. In some cases, Keudell Morrison or representatives may
buy or sell securities for their own account for reasons not related to the strategies
adopted for our Clients. Our employees are required to follow the Code of Ethics when
making trades for their own accounts in securities which are recommended to and/or
purchased for Clients. The Code of Ethics is designed to assure that the personal
securities transactions will not interfere with decisions made in the best interest of
advisory Clients while at the same time, allowing employees to invest their own
accounts.
Keudell Morrison will disclose to advisory Clients any material conflict of interest
relating to us, our representatives, or any of our employees which could reasonably be
expected to impair the rendering of unbiased and objective advice.
As any advisory situation could present a conflict of interest, we have established the
following restrictions to ensure our fiduciary responsibilities:
1. A director, officer, associated person, or employee of Keudell Morrison shall not
buy or sell securities for his personal portfolio where his decision is substantially
derived, in whole or in part, by reason of his employment unless the information is also
available to the investing public on reasonable inquiry. No person of Keudell Morrison
shall prefer his or her own interest to that of the advisory Client.
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2. Keudell Morrison maintains a list of all securities holdings for itself and for anyone
associated with its advisory practice that has access to advisory recommendations. An
appropriate officer of Keudell Morrison reviews these holdings on a regular basis.
3. Any individual not in observance of the above may be subject to termination.
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Item 12 – Brokerage Practices
A
Our Clients’ assets are held by independent third-party custodian, Charles Schwab & Co.,
Inc. (“Schwab”). Schwab is an independent and unaffiliated SEC-registered broker-dealer.
Except to the extent that the Client directs otherwise, Keudell Morrison may use its
discretion in selecting or recommending the broker-dealer. The Client is not obligated to
effect transactions through any broker-dealer recommended by Keudell Morrison. In
recommending broker-dealers, Keudell Morrison will comply with its fiduciary duty to seek
best execution and with the Securities Exchange Act of 1934 and will take into account
such relevant factors as:
➢ Price;
➢ The custodian’s facilities, reliability and financial responsibility;
➢ The ability of the custodian to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order; and
➢ Any other factors that we consider to be relevant.
Advisory Board (the “TOS Advisory Board”). As described under Item 9 of this Form
ADV, advisor may recommend that clients establish brokerage accounts with Schwab to
maintain custody of the clients’ assets and effect trades for their accounts. The TOS
Advisory Board consists of representatives of independent investment advisory firms who
have been invited by Schwab management to participate in meetings and discussions of
Schwab Advisor Services’ services for independent investment advisory firms and their
clients. TOS Advisory Board members enter nondisclosure agreements with Schwab
under which they agree not to disclose confidential information shared with them. This
information generally does not include material nonpublic information about Schwab. The
TOS Advisory Board meets in person or virtually approximately twice per year and has
periodic conference calls scheduled as needed. TOS Advisory Board members are not
compensated by Schwab for their service, but Schwab does pay for or reimburse TOS
Advisory Board members’ travel, lodging, meals and other incidental expenses incurred
in attending Board meetings.
Receiving Economic Benefits can be a conflict of interest, which is why there should be a
disclosure regarding it.
B
Keudell Morrison may aggregate trades for Clients. The allocations of a particular security
will be determined by Keudell Morrison before the trade is placed with the broker. When
practical, Client trades in the same security will be bunched in a single order (“block”) in
an effort to obtain best execution at the best security price available. When employing a
block trade:
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Form ADV Part 2A – Firm Brochure
• Keudell Morrison will make reasonable efforts to attempt to fill Client orders by
•
•
day-end.
If the block order is not filled by day-end, Keudell Morrison will allocate shares
executed to underlying accounts on a pro rata basis, adjusted as necessary to keep
Client transaction costs to a minimum.
If a block order is filled (full or partial fill) at several prices through multiple trades,
an average price and commission will be used for all trades executed.
• All participants receiving securities from the block trade will receive the average
price.
• Only trades executed within the block on the single day may be combined for
purposes of calculating the average price.
It is expected that this trade aggregation and allocation policy will be applied consistently.
However, if application of this policy results in unfair or inequitable treatment to some or
all of our Clients, we may deviate from this policy.
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Item 13 – Review of Accounts
A
Accounts are reviewed by Amanda Shine who is responsible for overseeing all investment
advisory activities for the firm. The frequency of reviews is determined based on the
Client’s investment objectives. Accounts are generally reviewed quarterly, but in any
event, no less than annually.
B
More frequent reviews may be triggered by a change in Client’s investment objectives; tax
considerations; large deposits or withdrawals; large sales or purchases; loss of confidence
in corporate management; or, changes in the economic climate.
C
Investment advisory Clients receive standard account statements from the custodian of
their accounts on a monthly basis. Keudell Morrison also provides Clients with a written
report summarizing the account activity generally quarterly, but in any event, no less than
annually.
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
Item 14 – Client Referrals and Other Compensation
Charles Schwab & Co., Inc. Advisor Services provides Keudell Morrison with access to Charles
Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are
typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors.
These services generally are available to independent investment advisers on an unsolicited
basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’
assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles
Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the
execution of securities transactions, custody, research, including that in the form of advice,
analyses and reports, and access to mutual funds and other investments that are otherwise
generally available only to institutional investors or would require a significantly higher
minimum initial investment. For Keudell Morrison client accounts maintained in its
custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately
for custody services but is compensated by account holders through commissions or other
transaction-related or asset-based fees for securities trades that are executed through
Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co.,
Inc. Advisor Services accounts.
information
technology, business succession,
Charles Schwab & Co., Inc. Advisor Services also makes available to Keudell Morrison other
products and services that benefit Keudell Morrison but may not benefit its clients’
accounts. These benefits may include national, regional or Keudell Morrison specific
educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor
Services. Other potential benefits may include occasional business entertainment of
personnel of Keudell Morrison by Charles Schwab & Co., Inc. Advisor Services personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms
of entertainment, some of which may accompany educational opportunities. Other of these
products and services assist Keudell Morrison in managing and administering clients’
accounts. These include software and other technology (and related technological training)
that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts, if applicable), provide research, pricing information and other
market data, facilitate payment of Keudell Morrison’s fees from its clients’ accounts (if
applicable), and assist with back-office training and support functions, recordkeeping and
client reporting. Many of these services generally may be used to service all or some
substantial number of Keudell Morrison’s accounts. Charles Schwab & Co., Inc. Advisor
Services also makes available to Keudell Morrison other services intended to help Keudell
Morrison manage and further develop its business enterprise. These services may include
professional compliance, legal and business consulting, publications and conferences on
regulatory
practice management,
compliance, employee benefits providers, and human capital consultants, insurance and
marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available,
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Firm Brochure
arrange and/or pay vendors for these types of services rendered to Keudell Morrison by
independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or
waive fees it would otherwise charge for some of these services or pay all or a part of the
fees of a third-party providing these services to Keudell Morrison. Keudell Morrison is
independently owned and operated and not affiliated with Charles Schwab & Co., Inc.
Advisor Services. Receiving Economic Benefits can be a conflict of interest.
Client Experience Panel disclosure
Amanda Shine serves on the Schwab Advisor Services Technology, Operations and
Service Advisory Board (the“TOS Advisory Board”). Keudell Morrison Wealth
Management may recommend that clients establish brokerage accounts with Schwab to
maintain custody of the clients’ assets and effect trades for their accounts. The TOS
Advisory Board consists of representatives of independent investment advisory firms who
have been invited by Schwab management to participate in meetings and discussions of
Schwab Advisor Services’ services for independent investment advisory firms and their
clients. TOS Advisory Board members enter nondisclosure agreements with Schwab under
which they agree not to disclose confidential information shared with them. This
information generally does not include material nonpublic information about the Charles
Schwab Corporation, whose common stock is listed for public trading on the New York
Stock Exchange (symbol SCHW). The TOS Advisory Board meets in person or virtually
approximately twice per year and has periodic conference calls scheduled as needed. TOS
Advisory Board members are not compensated by Schwab for their service, but Schwab
does pay for or reimburse TOS Advisory Board members’ travel, lodging, meals and other
incidental expenses incurred in attending Board meetings.
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Item 15 – Custody
When it deducts fees directly from client accounts at a selected custodian, Keudell Morrison will
be deemed to have limited custody of client’s assets and must have written authorization from the
client to do so. Clients provide written authority to have fees debited from their accounts when
they review and sign Keudell Morrison’s Investment Advisory Agreement. They also provide the
Custodian the authority to release fee payments from their accounts when they sign the custodial
account application. Clients shall receive account statements no less than quarterly from the
Custodian. Clients also receive quarterly statements from Keudell Morrison that include
notification of advisory fee calculations and the debiting from of these fees from client accounts.
We urge clients to review the Keudell Morrison statements carefully and compare these accounts
statements with the account statements from the Custodian.
Custody is also disclosed in Form ADV because Keudell Morrison has authority to transfer money
from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly,
Keudell Morrison will follow the safeguards specified by the SEC rather than undergo an annual
audit.
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Item 16 – Investment Discretion
Clients may grant Keudell Morrison ongoing and continuous discretionary authority to execute its
investment recommendations in accordance with Keudell Morrison’s Statement of Investment
Policy (or similar document used to establish each Client’s objectives and suitability), without the
Client’s prior approval of each specific transaction. Under this discretionary authority, Client
allows Keudell Morrison to purchase and sell securities and instruments in their account(s),
arrange for delivery and payment in connection with the foregoing, select and retain sub-advisors,
and act on behalf of the Client in matters necessary or incidental to the handling of the account,
including monitoring certain assets.
Clients may also grant Keudell Morrison non-discretionary authority to execute its investment
recommendations. Non-discretionary authority requires Keudell Morrison to obtain a Client’s
prior approval of each specific transaction prior to executing the investment recommendations.
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Form ADV Part 2A – Firm Brochure
Item 17 – Voting Client Securities
A
Keudell Morrison will not vote proxies on behalf of Clients and will not provide advice to
Clients on how the Client should vote.
B
Keudell Morrison does not have authority to vote Client securities unless authorized by the
Client. Most Clients will receive proxies and other solicitations directly from the custodian
or transfer agent. If any proxy materials are received on behalf of a Client, they will be
sent directly to the Client or a designated representative of the Client, who is responsible
to vote the proxy.
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Item 18 – Financial Information
A
Keudell Morrison does not require or solicit prepayment of more than $1,200 in fees per
client, six months or more in advance.
B
Keudell Morrison does have discretionary authority over some Client funds and securities,
but we have no financial commitments that would impair our ability to meet contractual
and fiduciary commitments to Clients.
C
Neither Keudell Morrison, nor any of the principals, have been the subject of a bankruptcy
petition at any time in the past.
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Additional Brochure: WRAP FEE PROGRAM BROCHURE (2026-03-23)
View Document Text
KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 1 – Cover Page
KEUDELL MORRISON WEALTH MANAGEMENT, LLC
235 Front Street SE, Suite 300
Salem, OR 97301
(971) 209-4511
March 23, 2026
http://www.kmwm.com/
This Wrap Fee Brochure provides information about the qualifications and business practices of
Keudell Morrison Wealth Management, LLC. If you have any questions about the contents of this
Wrap Fee Brochure, please contact us at (971) 209-4500 or mandy@kmwm.com. The information
in this Wrap Fee Brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Keudell Morrison Wealth Management, LLC is available on the
SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Keudell
Morrison Wealth Management, LLC is #292600.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 2 – Material Changes
The material changes since the last annual update on March 21, 2025, are described below.
• None
We will ensure that all current Clients receive a Summary of Material Changes to this and
subsequent Wrap Fee Brochures within 120 days of the close of our business’s fiscal year. A
Summary of Material Changes is also included with our Wrap Fee Brochure on the SEC’s website
at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Keudell Morrison Wealth
Management, LLC is #292600. We may further provide other ongoing disclosure information
about material changes as necessary and will further provide you with a new Wrap Fee Brochure
as necessary based on changes or new information, at any time, without charge.
Currently, our Wrap Fee Brochure may be requested by contacting Amanda Shine, Chief
Compliance Officer of Keudell Morrison Wealth Management, LLC at (971) 209-4500 or
mandy@kmwm.com. Our Wrap Fee Brochure is provided free of charge.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
Item 3 – Table of Contents
Page
Item 1 – Cover Page .......................................................................................................................................... i
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents ............................................................................................................................ iii
Item 4 – Services, Fees and Compensation ................................................................................................. 1
Item 5 – Account Requirements and Types of Clients ............................................................................. 4
Item 6 – Portfolio Manager Selection and Evaluation .............................................................................. 4
Item 7 – Client Information Provided to Portfolio Managers ............................................................... 10
Item 8 – Client Contact with Portfolio Managers .................................................................................... 10
Item 9 – Additional Information .................................................................................................................. 10
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Item 4 – Services, Fees and Compensation
A
Keudell Morrison Wealth Management, LLC (“Keudell Morrison” “we” or “us”) is a
registered investment advisor located in Salem, Oregon and registered with the SEC since
April 2018. Keudell Morrison’s founders and owners are Michael Morrison, Larry
Keudell, Joel Blount, Stephanie Smith and Amanda Shine.
Under this Wrap Fee Program, Keudell Morrison serves individuals and businesses in all
areas of investment management and financial planning, including asset management,
investment consulting, education funding, risk management, tax management, retirement
planning, estate planning services, and employee and executive benefits. While we do not
provide tax or legal advice, we provide a full range of services coupled in coordination
with other advisors such as attorneys and Certified Public Accountants.
Under this Wrap Fee Program, Keudell Morrison charges Clients annual fees for
investment advisory services generally ranging from 0.50% to 1.5% of assets under
management according to the amount of assets under management and the specific needs
of the Client for managing Clients’ portfolios. Fees are generally not negotiable. Keudell
Morrison’s standard fee schedule is:
Market Value of Account(s) Annual Advisory Fee
Under $499,999
1.50%
$500,000 – $999,999
1.25%
$1,000,000 – $1,999,999
1.00%
$2,000,000 and over
Negotiable
B
In determining whether to establish an account under our Wrap Fee Program, you should
be aware that the overall cost to you of the program may be higher or lower than you might
incur by purchasing separately, or unbundled, the types of securities available in the
program. In order to compare the cost of the program with unbundled services, you should
consider the turnover rate in our investment strategies, trading activity in the account and
standard advisory fees and brokerage commissions that would be charged at our custodian,
or at other broker-dealers and investment advisors.
Depending upon the percentage wrap fee charged by our firm (as described more fully
above), the amount of portfolio activity in your account, and the value of custodial and
other services provided, the wrap fee may or may not exceed the aggregate cost of such
services if they were to be provided separately and/or if we were to negotiate transaction
fees and seek best price and execution of transactions for your individual account. In as
much as the execution costs for transactions effected in your account will be paid by our
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
firm, a conflict of interest arises in that we may have a disincentive to trade securities in
your account.
C
Clients that are enrolled in the Wrap Fee Program will still be required to pay certain fees
including:
• The Client’s proportionate share of any internal mutual fund’s fees and charges.
• The Client’s proportionate share of internal fees and expenses of exchange-traded funds
such as fees and expenses for investment advisory services, administration, and other
fund-level expenses
• Client charges imposed by the Client’s current custodian (e.g., a transfer or termination
fee) before the assets are transferred to Keudell Morrison.
• Client charges imposed by Keudell Morrison’s custodian (e.g., a transfer or termination
fee) before the assets are transferred from Keudell Morrison.
• Client charges necessary to liquidate incoming positions into our recommended
portfolio.
Our wrap fee covers our advisory services and the brokerage services provided by Schwab
(including custody of assets, equity trades, ETFs, and agency transaction 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 funds’ 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.
D
Keudell Morrison and its investment advisor representatives receive compensation as a
result of your participation in the Wrap Fee Program. This compensation may be more than
the amount Keudell Morrison and its investment advisor representatives would receive if
you paid separately for investment advice, brokerage, and other services. Accordingly, a
conflict of interest exists because Keudell Morrison and its investment advisor
representatives have a financial incentive to recommend the program.
Schwab Brokerage Services In addition to the advisory services, the wrap fee program
includes certain brokerage services of Charles Schwab & Co., Inc. (Schwab) a broker-
dealer registered with the Securities and Exchange Commission and a member of FINRA
and SIPC. We are independently owned and operated and not affiliated with Schwab.
Schwab will act solely as a broker-dealer and not as an investment advisor to you. It will
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
have no discretion over your account and will act solely on instructions it receives from us.
Schwab has no responsibility for our services and undertakes no duty to you to monitor our
management of your account or other services we provide to you. Schwab will hold your
assets in a brokerage account and buy and sell securities ad execute other transactions when
we instruct them to. We do not open the account for you.
For Transaction Based Pricing
The advisor pays Schwab transaction costs for each executed trade in wrap fee accounts.
As a result, we have financial incentive to limit orders for wrap fee accounts because trades
increase our transaction costs. Thus, an incentive exists to trade less frequently in a wrap
fee program.
We do not charge our clients higher advisory fees based on their trading activity, but you
should be aware that we have an incentive to limit our trading in your account(s) because
we are charged for executed trades.
For Asset Based Pricing
The advisor pays Schwab a single asset-based fee in lieu of transaction-based commissions.
The fees we pay Schwab are assessed on certain assets in your account(s) at Schwab. We
have a conflict of interest because we have a financial incentive to maximize our
compensation by seeking to reduce or minimize the total costs incurred in your account(s)
subject to a wrap fee.
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 [or bundled] fee arrangement is appropriate for you, you
should compare the agreed-upon Wrap Program Fee and any other costs associated with
participating in our 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, we receive as
compensation for our investment advisory services, the balance of the total wrap [or
program] fee you pay after custodial, trading and other management costs (including
execution and transaction fees) have been deducted. Accordingly, we have a conflict of
interest because we have a financial incentive to maximize our compensation by seeking to
reduce or minimize the total costs incurred in your account(s) subject to a wrap fee.
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Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
• For example, our wrap fee arrangement creates incentives for our [advisers/firm] to trade
less frequently or select investments that that reduce our costs, and in some cases increase
expenses that are borne by the client.
Additionally, Schwab generally does not charge commissions [or transaction fees] for
online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-
transaction-fee (“NTF”) mutual funds. This means that, in most cases, when we buy these
types of securities, we can do so without paying commissions to Schwab. [Alternative
Language]: We are available to discuss Schwab’s execution related pricing with you so that
you can compare the total costs of entering into a wrap fee arrangement versus a non-wrap
fee arrangement.] If you choose to enter into a wrap fee arrangement, your total cost to
invest could exceed the cost of paying for brokerage and advisory services separately.
Item 5 – Account Requirements and Types of Clients
Keudell Morrison provides investment advice to individuals, high net worth individuals,
businesses, and not for profit organizations. Because each Client is unique, they must be willing
to be involved in the planning and ongoing processes. Such involvement does not have to be time
consuming, however we want our Clients to remain informed and have a sense of security about
their investments. Keudell Morrison has an asset minimum of $500,000 for opening or
maintaining a Wrap Fee Program Account. We will make exceptions to this minimum under
certain circumstances.
Item 6 – Portfolio Manager Selection and Evaluation
A
Investment advisor representatives of Keudell Morrison may act as the portfolio manager
under a Wrap Fee Program account. In circumstances where Keudell Morrison
recommends separate account managers, we consider several factors including account
size, risk tolerance, the opinion of each Client and the investment philosophy of the
selected registered investment advisor. The recommendation of the initial portfolio
manager and or the replacement of the portfolio manager will be based on a number of
factors including Client service, portfolio performance, customer satisfaction and other
similar factors. The Chief Compliance Officer or other firm manager may conduct periodic
portfolio performance evaluations where the performance of the portfolio being evaluated
may be compared to other similarly managed accounts. Each portfolio evaluated may be
evaluated based on its particular circumstances. Therefore, the portfolio performance
evaluations of accounts may not be conducted on a uniform or consistent basis.
B
Investment advisor representatives of Keudell Morrison may act as the portfolio manager
under a Wrap Fee Program account. Keudell Morrison and its investment advisor
representatives receive compensation as a result of your participation in the program. This
compensation may be more than the amount Keudell Morrison and its investment advisor
representatives would receive if you paid separately for investment advice, brokerage, and
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
other services. Accordingly, a conflict of interest exists because Keudell Morrison and its
investment advisor representatives have a financial incentive to recommend the program.
Related persons are subject to the same selection criteria as outside portfolio managers.
C
Advisory Business.
Information regarding types of advisory services offered, how advisory services are
tailored to individual needs of Clients, and differences between the wrap fee program and
separately managed accounts can be found in Item 4 above.
Performance-Based Fees and Side-By-Side Management.
Keudell Morrison does not charge any performance-based fees for its services and does
not provide side-by-side management.
Methods of Analysis, Investment Strategies and Risk of Loss.
Keudell Morrison’s investment philosophy is based on Modern Portfolio Theory, which
refers to the process of attempting to reduce risk in a portfolio through systematic
diversification across asset classes, including but not limited to common stocks, corporate
bonds, government bonds, commodities, and real estate investment trusts. We consider
ourselves global investment managers and attempt to add additional diversification by
including non-U.S. investments to clients’ portfolios. We emphasize the analysis of mutual
funds, exchange-traded funds, and separately managed accounts (SMA’s) in our selection
of the investments that comprise our clients’ portfolios.
Representatives may use additional methods of analysis to manage the accounts of their
clients. Following are typical methods of analysis that representatives may use; however,
clients should inquire of their specific representative the particular method the
representative intends to use in managing the client's account:
Fundamental Analysis
Fundamental analysis uses publicly available data in the evaluation of a security's value.
Although most analysts use fundamental analysis to value common stocks, this method
of valuation can be used for just about any type of security. For example, an investor can
perform fundamental analysis on a bond's value by looking at economic factors such as
interest rates and the overall state of the economy. He can also look at information about
the bond issuer, such as potential changes in credit ratings.
For stocks and equity instruments, this method uses revenues, earnings, future growth,
return on equity, profit margins and other data to determine a company's underlying value
and potential for future growth. In terms of common stocks, fundamental analysis
focuses on the financial statements of the company being evaluated.
Fundamental analysts study anything that can affect a security’s value including
macroeconomic factors such as the overall economy and industry conditions, and
microeconomic factors such as financial conditions and company management. The end
goal of fundamental analysis is to produce a quantitative value that an investor can
compare with a security's current price, thus indicating whether the security is
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
Form ADV Part 2A – Appendix 1, Wrap Fee Program Brochure
undervalued or overvalued.
Technical Analysis
Technical analysis is used to attempt to forecast the price movement of virtually any
tradable instrument that is generally subject to forces of supply and demand, including
common stocks, bonds, futures and currency pairs. In fact, technical analysis can be
viewed as simply the study of supply and demand forces as reflected in the market price
movements of a security. It is most commonly applied to price changes, but some
analysts may additionally track numbers other than just price, such as trading volume or
open interest figures.
Over the years, numerous technical indicators have been developed by analysts in
attempts to accurately forecast future price movements. Some indicators are focused
primarily on identifying the current market trend, including support and resistance areas,
while others are focused on determining the strength of a trend and the likelihood of its
continuation. Commonly used technical indicators include trend-lines and multiple
moving averages, such as the 50-day moving average and the 200-day moving average.
Economic (Cyclical) Analysis
Economic analysis takes into consideration economic cycles in order to predict how
various sectors of the market and a market index will perform. Stocks in consumer
staples such as food and household products may be appropriate in one cycle while in a
period of recovery consumer discretionary stocks may become more attractive. The
expectation of rising or falling interest rates during economic cycles can also affect risk
premiums. This type of analysis is useful over longer periods of time for portfolio
planning and allocation but does not generally provide a basis for day-to-day investment
management.
Mutual Fund and ETF Analysis
In analyzing mutual funds and ETFs, we heavily scrutinize the experience and track
record of the portfolio managers to determine if they have demonstrated the ability to
invest successfully in varying economic conditions. We continuously monitor the funds
in an attempt to determine if they are deviating from their stated investment strategies.
We also evaluate the fees of each fund to ensure they are reasonable for the asset class we
are investing in. A risk of our mutual fund and ETF analysis is that, as in all investments,
past performance does not guarantee future results. A manager who has been successful
in the past may not be able to replicate that success in the future. In addition, managers
of different mutual funds and ETF’s may purchase the same security in a client’s
portfolio, increasing the risk to the client if that security were to fall in value. There is
also a risk that a manager may deviate from the stated investment mandate or strategy of
the fund, which could make the fund less suitable for the client's portfolio. We
specifically rely on Morningstar for our mutual fund and ETF analytical data.
Sources of information
Keudell Morrison subscribes to numerous financial newspapers, investment magazines,
trade association publications, and research services including The Wall Street Journal,
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
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The Economist, Ned Davis Research, Mauldin Economics, Cass Freight Index, Alpine
Macro and Hedgeye Risk Management. In addition, Keudell Morrison also uses free
online resources including but not limited to FRED (Federal Reserve Economic
Database), The IMF (International Monetary Fund), The World Factbook – Central
Intelligence Agency, The Atlanta Federal Reserve’s GDP Now, US Department of Labor,
The Congressional Budget Office, and the Bureau of Economic Analysis.
Risk of Errors in Investment Decisions
There is a risk that our judgment about the attractiveness, relative value, or potential
appreciation of a particular security or market sector, or about the timing of investment
purchases or sales, may prove to be incorrect, resulting in losses to a client's account.
The success of Keudell Morrison’s strategy for an account or portfolio is subject to
Keudell Morrison 's ability to continually analyze and select appropriate mutual fund,
ETF, and SMA investments, and allocate and re-allocate the investments consistent with
the intended investment objectives and risk parameters of the client.
Investment Strategies & Risks
We reserve the right to employ a number of investment strategies in pursuit of the
investment objectives for client portfolios, including long-term investments (investments
expected to be held for more than a year) and short-term investments (investments
expected to be held for less than a year). In general, clients should expect that our
strategies will emphasize long-term investments in common stocks, bonds, mutual funds,
and ETF’s. Portfolio composition and allocation at any given time will vary based on our
assessment of current market conditions and the relative risk and reward of particular
investments.
Additional Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following
investment risks:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
•
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic, and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as
much as a dollar next year, because purchasing power is eroding at the rate of
inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
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• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding
oil and then refining it, a lengthy process, before they can generate a profit. They
carry a higher risk of profitability than an electric company, which generates its
income from a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
B
We use our best judgment and good faith efforts in rendering services to Client. We
cannot warrant or guarantee any particular level of account performance, or that an
account will be profitable over time. Not every investment recommendation we make
will be profitable. Investing in securities involves risk of loss that Clients should be
prepared to bear. Clients assume all market risk involved in the investment of account
assets. Investments are subject to various market, currency, economic, political, and
business risks.
It is the responsibility of the Client to give us complete information and to notify us of
any changes in financial circumstances or goals.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you
withdraw the assets from your employer's retirement plan and roll the assets over to an
individual retirement account ("IRA") that we will manage on your behalf. If you elect to
roll the assets to an IRA that is subject to our management, we will charge you an asset
based fee as set forth in the agreement you executed with our firm. This practice presents
a conflict of interest because persons providing investment advice on our behalf have an
incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to complete the rollover. Moreover, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their
company plan. Also, current employees can sometimes move assets out of their company
plan before they retire or change jobs. In determining whether to complete the rollover to
an IRA, and to the extent the following options are available, you should consider the
costs and benefits of:
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An employee will typically have four options:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we
encourage you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here
are a few points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address
your needs or whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu
than IRAs.
b. Employer retirement plans may have unique investment options not available
to the public such as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand
the cost structure of the share classes available in your employer's retirement
plan and how the costs of those share classes compare with those available in
an IRA.
b. You should understand the various products and services you might take
advantage of at an IRA provider and the potential costs of those products and
services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially
delay your required minimum distribution beyond age 70.5.
6. Your 401k may offer more liability protection than a rollover IRA; each state may
vary. Generally, federal law protects assets in qualified plans from creditors. Since
2005, IRA assets have been generally protected from creditors in bankruptcies.
However, there can be some exceptions to the general rules so you should consult
with an attorney if you are concerned about protecting your retirement plan assets
from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary
income tax and may also be subject to a 10% early distribution penalty unless they
qualify for an exception such as disability, higher education expenses, or the
purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at
a lower capital gains tax rate.
It is important that you understand the differences between these types of accounts and to
decide whether a rollover is best for you. Prior to proceeding, if you have questions
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KEUDELL MORRISON WEALTH MANAGEMENT, LLC
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contact your investment adviser representative, or call our main number as listed on the
cover page of this brochure.
Voting Client Securities.
Without exception, Keudell Morrison does not vote proxies on behalf of Clients.
Additionally, Keudell Morrison will not provide advice to Clients on how the Client should
vote.
Keudell Morrison does not have authority to vote Client securities unless authorized by the
Client. Most Clients will receive proxies and other solicitations directly from the custodian
or transfer agent. If any proxy materials are received on behalf of a Client, they will be
sent directly to the Client or a designated representative of the Client, who is responsible
to vote the proxy.
We manage $921,506,676 of Client assets on a discretionary basis.. This amount was
calculated as of December 31, 2025.
Item 7 – Client Information Provided to Portfolio Managers
Once the Client selects an investment advisor representative and an advisory relationship is
initiated, the investment advisor representative will obtain information from the Client on the
Client’s financial background, prior investment experience, investment objectives, goals and
restrictions, if any, and risk tolerance, among other things. This information is shared with any
separate account manager selected by the Client.
Item 8 – Client Contact with Portfolio Managers
Keudell Morrison does not place any restrictions on its Client’s ability to contact and consult with
their portfolio managers.
Item 9 – Additional Information
A
Disciplinary Information.
Keudell Morrison is required to disclose all material facts regarding any legal or
disciplinary event that would be material to your evaluation of our firm, or the integrity of
our management.
In order to avoid the time and expense associated with arbitration, on September 26, 2008,
without admitting or denying any allegations, Larry Keudell reached a settlement over a
disputed claim with a client. Mr. Keudell made no payment towards the settlement and the
matter did not result in any fine, or regulatory action against him. Keudell Morrison
remains committed to observing the highest standards of integrity and regulatory
compliance in all aspects of our operations. We welcome any inquiries regarding this
matter.
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Other Financial Industry Activities and Affiliations.
Certain investment advisor representatives of Keudell Morrison are also licensed to sell
insurance in one or more states, either through a licensed general insurance agency or as
direct agent representative of a specific insurance company. Insurance related business is
transacted with advisory Clients and individuals may receive commissions from
insurance products sold to Clients. Clients are advised that the fees paid to Keudell
Morrison for investment advisory services are separate and distinct from the commissions
earned by any individual for selling Clients other insurance products. If requested by a
Client, we will disclose the amount of commission expected to be paid.
The receipt of commissions by an individual associated with the firm presents a conflict
of interest. As fiduciaries we must act primarily for the benefit of investment advisory
Clients. As such, we will only transact insurance related business with Clients when fully
disclosed, suitable, and appropriate. Further, we must determine in good faith that any
commissions paid to our representatives are appropriate. Clients are informed that they
are under no obligation to use any individual associated with Keudell Morrison for
insurance products or services. Clients may use any insurance firm or agent they choose.
Keudell Morrison may, on occasion, recommend that all or a portion of a Client’s assets
be managed by an unaffiliated investment manager or sub-advisor. Fees charged by a sub-
advisor will be fully disclosed to Clients. Sub-advisory fees may be deducted directly from
Client accounts and may result in increased fees to Client. In all discretionary accounts,
except to the extent the Client directs otherwise, we are authorized to use our discretion in
selecting or changing a sub-advisor and/or outside money manager to the account without
prior approval from a Client. Clients may be required to execute a limited power of attorney
with a sub-advisor selected by us. Prior to selecting other advisers to manage Client assets,
Keudell Morrison will confirm that the other advisers are properly licensed or registered
as an investment adviser.
B
Code of Ethics, Participation or interest in Client transactions and personal trading.
Keudell Morrison has a Code of Ethics which all employees are required to follow. The
Code of Ethics outlines our high standard of business conduct, and fiduciary duty to
Clients. The Code of Ethics includes provisions relating to the confidentiality of Client
information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions
on the acceptance of significant gifts, the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other things.
We do not own or manage any companies or investments that we advise our Clients to buy.
Keudell Morrison or individuals associated with our firm may buy and sell some of the
same securities for their own account that Keudell Morrison buys and sells for its Clients.
When appropriate, we will purchase or sell securities for Clients before purchasing the
same for our account or allowing representatives to purchase or sell the same for their own
account. In some cases, Keudell Morrison or representatives may buy or sell securities for
their own account for reasons not related to the strategies adopted for our Clients. Our
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employees are required to follow the Code of Ethics when making trades for their own
accounts in securities which are recommended to and/or purchased for Clients. The Code
of Ethics is designed to assure that the personal securities transactions will not interfere
with decisions made in the best interest of advisory Clients while at the same time, allowing
employees to invest their own accounts.
Keudell Morrison will disclose to advisory Clients any material conflict of interest relating
to us, our representatives, or any of our employees which could reasonably be expected to
impair the rendering of unbiased and objective advice.
Receiving Economic Benefits can be a conflict of interest, which is why there should be a
disclosure regarding it.
As any advisory situation could present a conflict of interest, we have established the
following restrictions to ensure our fiduciary responsibilities:
1. A director, officer, associated person, or employee of Keudell Morrison shall not buy or
sell securities for his personal portfolio where his decision is substantially derived, in
whole or in part, by reason of his employment unless the information is also available
to the investing public on reasonable inquiry. No person of Keudell Morrison shall
prefer his or her own interest to that of the advisory Client.
2. Keudell Morrison maintains a list of all securities holdings for itself and for anyone
associated with its advisory practice that has access to advisory recommendations. An
appropriate officer of Keudell Morrison reviews these holdings on a regular basis.
3. Any individual not in observance of the above may be subject to termination.
Review of Accounts.
Accounts are reviewed by Amanda Shine who is responsible for overseeing all investment
advisory activities for the firm. The frequency of reviews is determined based on the
Client’s investment objectives. Accounts are generally reviewed quarterly, but in any
event, no less than annually.
More frequent reviews may be triggered by a change in Client’s investment objectives; tax
considerations; large deposits or withdrawals; large sales or purchases; loss of confidence
in corporate management; or, changes in the economic climate.
Investment advisory Clients receive standard account statements from the custodian of
their accounts on a monthly basis. Keudell Morrison also provides Clients with a written
report summarizing the account activity generally quarterly, but in any event, no less than
annually.
Client Referrals and Other Compensation.
Charles Schwab & Co., Inc. Advisor Services provides Keudell Morrison with access to
Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services,
which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail
investors. These services generally are available to independent investment advisers on an
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unsolicited basis, at no charge to them so long as a total of at least $10 million of the
adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor
Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that
are related to the execution of securities transactions, custody, research, including that in
the form of advice, analyses and reports, and access to mutual funds and other investments
that are otherwise generally available only to institutional investors or would require a
significantly higher minimum initial investment. For Keudell Morrison client accounts
maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not
charge separately for custody services but is compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are
executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles
Schwab & Co., Inc. Advisor Services accounts.
information
technology, business succession,
Charles Schwab & Co., Inc. Advisor Services also makes available to Keudell Morrison
other products and services that benefit Keudell Morrison but may not benefit its clients’
accounts. These benefits may include national, regional or Keudell Morrison specific
educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor
Services. Other potential benefits may include occasional business entertainment of
personnel of Keudell Morrison by Charles Schwab & Co., Inc. Advisor Services personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms
of entertainment, some of which may accompany educational opportunities. Other of these
products and services assist Keudell Morrison in managing and administering clients’
accounts. These include software and other technology (and related technological training)
that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for
multiple client accounts, if applicable), provide research, pricing information and other
market data, facilitate payment of Keudell Morrison’s fees from its clients’ accounts (if
applicable), and assist with back-office training and support functions, recordkeeping and
client reporting. Many of these services generally may be used to service all or some
substantial number of Keudell Morrison’s accounts. Charles Schwab & Co., Inc. Advisor
Services also makes available to Keudell Morrison other services intended to help Keudell
Morrison manage and further develop its business enterprise. These services may include
professional compliance, legal and business consulting, publications and conferences on
practice management,
regulatory
compliance, employee benefits providers, and human capital consultants, insurance and
marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available,
arrange and/or pay vendors for these types of services rendered to Keudell Morrison by
independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or
waive fees it would otherwise charge for some of these services or pay all or a part of the
fees of a third-party providing these services to Keudell Morrison. Keudell Morrison is
independently owned and operated and not affiliated with Charles Schwab & Co., Inc.
Advisor Services. Receiving Economic Benefits can be a conflict of interest.
Client Experience Panel disclosure
Amanda Shine serves on the Schwab Advisor Services Technology, Operations and
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Service Advisory Board (the “TOS Advisory Board”). Advisors may recommend that
clients establish brokerage accounts with Charles Schwab to maintain custody of the
clients’ assets and effect trades for their accounts. The TOS Advisory Board consists of
representatives of independent investment advisory firms who have been invited by
Schwab management to participate in meetings and discussions of Schwab Advisor
Services’ services for independent investment advisory firms and their clients. TOS
Advisory Board members enter nondisclosure agreements with Schwab under which they
agree not to disclose confidential information shared with them. This information
generally does not include material nonpublic information about the Charles Schwab
Corporation, whose common stock is listed for public trading on the New York Stock
Exchange (symbol SCHW). The TOS Advisory Board meets in person or virtually
approximately twice per year and has periodic conference calls scheduled as needed. TOS
Advisory Board members are not compensated by Schwab for their service, but Schwab
does pay for or reimburse TOS Advisory Board members’ travel, lodging, meals and other
incidental expenses incurred in attending Board meetings.
Financial Information.
Keudell Morrison does not require or solicit prepayment of more than $1,200 in fees per
Client, six months or more in advance.
Keudell Morrison does have discretionary authority over Client funds or securities, but we
have no financial commitments that would impair our ability to meet contractual and
fiduciary commitments to Clients.
Neither Keudell Morrison, nor any of the principals, have been the subject of a bankruptcy
petition at any time in the past.
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