KFG, LLC

Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure, March 2026 KFG, LLC 1010 9th Street, Suite 1 Rapid City, SD, 57701 (605) 343-1400 Firm Contact: Paul Friedel, CPA, MST, CTFA, CMA, CFM, CGMA, CPIM, Chief Compliance Officer Firm Website Address: www.kahlerfinancial.com Firm Blog Address: www.financialawakenings.com This Brochure provides information about the qualifications and business practices of KFG, LLC (”KFG”). If there are any questions about the contents of this brochure, please contact us at (605) 343-1400 or info@kahlerfinancial.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 KFG, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD# 337331. Please note that the use of the term “registered investment adviser” and description of KFG, LLC and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for additional information on the qualifications of our firm and its advising associates.  Item 2: Material Changes KFG, LLC is required to advise clients of any material changes to our Firm Brochure (“Brochure”) from our last annual update With this initial annual amendment filing we succeeded the business of formerly registered investment adviser, Kahler Financial Group, Inc. (CRD# 124042). Kahler Financial Group, Inc. (controlled by Rick Kahler) along with Paul Freidel and Ben Paulding make up the ownership of KFG, LLC. The following material changes were made to Form ADV Part 2A of Kahler Financial Group, Inc. dated March 2025: 1. 2. 3. Item 5 – Fees and advisory services for legacy clients of Astute Financial who migrate to KFG, LLC will not change unless otherwise negotiated. Item 8 – Includes expanded risk disclosure language for individual stock, concentrated and foreign holdings and small cap securities. Item 10 – Paul Freidel is Managing Member and CCO of Astute Financial, LLC, a registered investment adviser with the State of South Dakota since January 2020. Clients of KFG, LLC are not solicited to become clients of Astute Financial. Certain clients of Astute Financial may migrate to KFG, LLC if in their best interest. Mr. Freidel is also Managing Member of Freidel and Associates, LLC, a Rapid City based full-service CPA firm. Clients of KFG, LLC may be solicited by the affiliated accounting firm. Clients are under no obligation to utilize tax and accounting services of Freidel and Associates. Clients must separately engage the account firm. Fees for tax and account services are separate from KFG, LLC service fees. There is no compensation for referrals between firms. Fees charged to clients by any of Mr. Freidel’s firms are not increased for referrals between firms. Mr. Freidel may provide fee discounts for clients of multiple firms. In no way will Mr. Freidel through is his advisory activities and practices take custody of advisory client assets. 4. As of February 12, 2026, Paul Freidel became Chief Compliance Officer. 5. The fee schedule was amended to decrease the top tier as well as making fees for assets over $8,000,000 under management negotiable. Please see Item 5 for more information. 2  Item 3: Table of Content Section: Page: Item 2: Material Changes ............................................................................................................................................................ 2 Item 3: Table of Content ............................................................................................................................................................. 3 Item 4: Advisory Business ........................................................................................................................................................... 4 DATA GATHERING ............................................................................................................................................................... 5 DISCOVERY .......................................................................................................................................................................... 5 FINANCIAL PLAN DESIGN .................................................................................................................................................... 5 Financial Planning Services ................................................................................................................................................. 5 Investment Advisory Services ............................................................................................................................................. 5 Lightning Meetings .............................................................................................................................................................. 6 IMPLEMENTATION .............................................................................................................................................................. 6 MAINTENANCE .................................................................................................................................................................... 6 Item 5: Fees & Compensation ..................................................................................................................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management ................................................................................................ 8 Item 7: Types of Clients & Account Requirements ..................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss .......................................................................................... 9 Item 9: Disciplinary Information ............................................................................................................................................... 11 Item 10: Other Financial Industry Activities & Affiliations ....................................................................................................... 11 Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading ............................................... 12 Item 12: Custodial Broker/Dealer Practices ............................................................................................................................. 13 Research and Other Soft Dollar Benefits .......................................................................................................................... 14 Brokerage for Client Referrals .......................................................................................................................................... 14 Directed Brokerage ........................................................................................................................................................... 14 Trade Aggregation and Allocation .................................................................................................................................... 15 Item 13: Review of Accounts or Financial Plans ....................................................................................................................... 15 Investment Review ............................................................................................................................................................ 15 Financial Planning Review ................................................................................................................................................. 16 Item 14: Other Compensation & Client Referrals .................................................................................................................... 16 Other Compensation Arrangements ................................................................................................................................ 16 Client Referrals .................................................................................................................................................................. 16 Item 15: Custody ....................................................................................................................................................................... 16 Item 16: Investment Discretion ................................................................................................................................................ 17 Item 17: Voting Client Securities ............................................................................................................................................... 17 Item 18: Financial Information .................................................................................................................................................. 17 3  Item 4: Advisory Business KFG’s core purpose is to transform the financial and emotional well-being of people. Our firm is a limited liability company formed under the laws of the State of South Dakota. KFG, LLC is owned by Paul Freidel, Ben Paulding and Kahler Financial Group, Inc. (controlled by Richard Kahler). KFG, LLC has taken over operations of Kahler Financial Group, Inc.’s registration as an RIA and continues to provide the same advisory services clients know and appreciate. All of obligations of the RIA have been assumed by KFG, LLC. Please refer to the Material Changes in Item 2 above to learn more about the changes made with our August 2025 succession. We manage $ 144,400,000on a discretionary basis and $ 43,700,000on a non-discretionary basis as of October 31, 2025. We are an independent, client-centered, fee-only financial planning firm that does not sell investment products. We do not receive compensation from third parties, such as a mutual fund or insurance company. We strive to provide complete objective advice and should there ever be conflicts of interest, we will promptly disclose them. We work solely for the client. We charge a percentage on investment assets. We help business owners, professionals, retirees, and families make good financial decisions by integrating the nuts and bolts of financial planning with what clients think, feel, and believe about money. We call this the “blending” of our emotions and beliefs about finance with the mechanical aspect of integrated financial planning. We do that by: 1. 2. 3. 4. 5. 6. 7. 8. Putting our clients first Guiding clients to reach a destination in an unfamiliar area Giving sound advice and creative solutions Constantly educating ourselves Practicing what we preach Taking clients only where we have gone ourselves Being serial innovators Taking personal responsibility for our actions and contributions We work best with people who recognize big goals happen by making small changes and have a willingness to change behavior to further their long-term goals. They have realistic investment expectations and can ignore the investment ‘du jour’ as touted by the financial press. Most are affluent or becoming affluent and have the ability to save a portion of their income. Some have complex tax, investment, and other planning needs. We offer specialization in our core area of competence and utilize other professionals when specialization is needed in other areas such as legal, psychological, or accounting. Ongoing planning reviews, workshops, study groups, tele classes, and special events help both new and existing clients feel part of our community. We may offer an initial complimentary consultation to review client interests, needs and objectives, and to discuss the services available. Advisory services are initiated only after an Engagement Agreement and a Retainer Agreement is executed with us. We specialize in the following types of services: Integrated financial planning for individuals Investment portfolio management • • • Specialized problem-solving and analysis of complex financial issues • Estate and tax planning strategies • Strategies for gaining financial independence • Cash flow and budget analysis • Mortgage analysis and refinancing decisions • Business planning, including succession planning • Asset protection strategies • Financial Coaching 4  Our integrated financial planning is supported by a five-step process: Data Gathering; Discovery; Design; Implementation; and Maintenance. Our process is designed to help clients identify goals and objectives, to find and implement personalized solutions, and to maintain and monitor progress. Our firm utilizes the sub-advisory services of third-party investment advisory firms or individual advisors to aid in the implementation of investment management services and financial planning services. Before selecting a firm or individual, our firm will ensure the chosen party is properly licensed or registered. DATA GATHERING Our Data Gathering process asks clients to provide us with all financial documents and statements. We request input and information, including historical financial information, present financial condition and account information, and investment history and experience. The information requested may vary, depending upon the individual needs and objectives expressed to us or what we may discover in our interviews. We treat the information given to us as reliable and current. We also request the names and relationships of other trusted advisors (i.e., attorney, accountant, banker, etc.). It is important to note the other trusted advisors may bill clients for assisting us in gathering pertinent information. KFG will not be responsible for these fees. DISCOVERY Our Discovery process goes beyond compiling financial documents and statements, which is the first step of the process. This second aspect is uniquely designed to help identify client values, goals, and priorities, and how they relate to finances. This discovery session focuses on what matters to the client –beliefs about money, unique history with money, values, and dreams. It helps clients bring into focus an action plan for the life he/she wants to be living, as opposed to the life he/she is living. FINANCIAL PLAN DESIGN Based upon the collected data in the Discovery process, we provide a choice of options which present solutions to accomplishing client objectives. We do this through a series of meetings where we conduct dialogue and education on solutions in each of three areas: financial planning, investment strategy, and financial coaching. Financial Planning Services Cash flow planning addresses the issue of organizing and monitoring the client’s cash flow. It helps identify where the money is being spent and how to manage the process. Investment education will assist clients in learning how to save and invest wealth. We will help decide which type of investment vehicle is appropriate and adapt an appropriate asset allocation. Planning for financial independence is a detailed look at post-employment cash flow projections that are a result of considering all potential sources of post-employment income, company retirement plan options, and the best strategies for maximizing assets to be used for financial needs when the client is no longer earning a salary. Asset protection and risk management are an important part of the financial planning process, designed to reduce risk to acceptable levels. This planning helps protect from catastrophe or a frivolous lawsuit. It includes a review of all types of insurance coverage to ensure the appropriate levels of coverage are in place. Estate and tax planning is important to improving wealth building efficiency and helping transfer lifetime assets according to final wishes. An appropriate estate plan can help minimize the time it takes to distribute an estate and minimize federal taxes. Investment Advisory Services Investment planning and management starts with a review of the client’s current investment portfolio and an analysis of its ability to help achieve authentic goals presented during the Discovery portion of the process. The review will involve selecting asset classes, and sub classes. We believe good asset allocation consists of a variety of appropriately selected asset classes. We do not time the market or give investment advice on specific stocks. Instead, we follow a “constant- 5  weighting asset allocation” philosophy where we rebalance the asset classes to their original targets periodically. Both our experience and academic research has shown most portfolio returns are the result of the asset allocation decision and not market timing or individual security selection. We also manage the portfolio, continuously reviewing and upgrading managers. We usually do not allow clients to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in account management. We may occasionally provide clients with investment advice and external management of investments without our extensive financial planning and coaching as designated in the Financial Services Agreement. Lightning Meetings Our firm provides a variety of standalone consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Lightning Meetings will typically involve a 60-minute meeting and cost is based on the level of planning expertise desired. A 60-minute meeting with our principal financial planner is $990 per hour; 60-minute meeting with a lead financial planner is $650 per hour; or 60-minute meeting with an associate financial planner is $350 per hour for individuals based on the requested topic and data provided at the time of the meeting. The Lightning Meeting may encompass retirement planning, estate planning, education planning, personal tax planning, real estate analysis, mortgage/debt analysis and insurance analysis. Lightning Meetings rendered usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Lightning Meetings are not typically accompanied by a written summary of observations and recommendations, as the process is less formal. Lightning Meetings will only consider the information and documents the client provides at the time of the meeting are typically completed at the close of the meeting. Payment for Lightning Meetings is due prior to the commencement of the meeting. IMPLEMENTATION In the Implementation process, we assist in acting on the decisions made in the Data Gathering process and coordinate them with the client’s other advisors. We communicate the specific strategies and our recommendations to the client’s accountant and attorney, if the client requests us to do so. We execute the selected portfolio, helping to liquidate and acquire securities and managers we’ve identified in the plan. identified with our clients. The third-party managers Once your strategy and portfolio construction are created, we engage third-party managers to trade in your portfolio to help achieve the financial goals we’ve implement our recommendations to our clients. The performance of client portfolios is monitored by our KFG advisors on an ongoing basis to ensure they stay within acceptable ranges and risk tolerance levels. MAINTENANCE We believe integrated financial planning is dynamic, ever changing, and never complete. The maintenance process includes the on-going oversight of goal implementation. Some services like investment planning, planning for financial independence, cash flow management, estate planning, financial coaching or tax planning are ongoing or completed over a longer period of time. We hold periodic meetings with a minimum of an annual meeting. The number of meetings per year depends upon the complexity and needs of the client in any one year. More complex client needs indicate more frequent meetings. Annual meetings are focused on financial planning work done per direction of the client. In our meetings we focus on the issues the client identifies as important and a continuous review of all the components of changing financial needs. Third-party managers will rebalance portfolios on at least an annual basis to account for overweighted holdings and drift that occurs over time from targeted goals. More frequent trading will take place in the event that market events, economic conditions or other circumstances dictate. 6  We usually do not allow the client to impose restrictions on investing in certain securities or types of securities due to the level of difficulty this would entail in managing the account. We do not offer wrap fee programs. Item 5: Fees & Compensation Below we describe fees and expenses so clients will know exactly how much we charge for the advisory services provided. Fees are typically not negotiable; however, we reserve the right to discount advisory fees based on the scope and complexity (or lack thereof) of the engagement. Because our firm’s primary focus is the discovery, design, and review of the financial plan, we charge our fees based on the total asset value of investment assets under our advisement. This excludes personal assets like primary residence, vehicles, other personal property, and illiquid assets. For calculation purposes we round to the nearest dollar. KFG Planning Charge Matrix to to to to $780,000 $1,825,000 $3,675,000 $8,000,000 Asset under Management and Advisement Tiered Range $0 $780,000.01 $1,825,000.01 $3,675,000.01 Over $8,000,000 Annual Percentage 1.30% 1.00% 0.80% 0.55% Negotiable KFG Fee Structure (Investment Only) to to to $1,825,000 $3,675,000 $8,000,000 Asset under Management Tiered Range $0 $1,825,000.01 $3,675,000 .01 Over $8,000,000 Annual Percentage 1.00% 0.75% 0.50% Negotiable Financial planning fees are established annually based on the assets under advisement which includes asset managed under KFG (including cash and cash equivalents) as of October 31st of the previous year. We have a one-time data-gathering and design fee of up to 50% of the annual financial planning fee. Financial Planning clients have a minimum quarterly fee of $1,875 and for their assets in managed accounts held at Schwab there is an additional 0.04% charged quarterly to partially cover third-party manager fees. The one-time data-gathering and design fee, and the first quarterly fee are due at the beginning of the engagement. Thereafter, financial planning fees are due quarterly in arrears. Legacy Investment Only advisory fees are based on account balances (including cash and cash equivalents) on October 31st of each year and charged quarterly in arrears during the following year for legacy clients. New Investment Only clients will be charge on account balances on the last day of the quarter. We do not make adjustments for deposits and withdrawals in fee calculations. For sub-advisory services rendered to our clients, our firm compensates third party investment advisory firms or individual advisors a percentage of the overall investment advisory fee charged by our firm. Advisory fees are deducted from client’s managed accounts by the third-party manager and paid to us. The advisory fee paid shall not exceed the fee published for this service. We rebalance portfolios held at Schwab at least annually. We offer rebalance recommendation for employer-controlled retirement portfolios held away from Schwab annually. We need timely information on assets held away from Schwab. Assets, on which the client does not provide KFG with automatic and timely updated statements, will not be included in any asset allocations, financial statements, or reports. This significantly slows down our internal process and the quality of advice received from us. 7  Because we calculate our annual financial planning fee on a percentage of investment assets, there exists a potential conflict of interest regarding advice given by us since our revenues are directly impacted by the size of the client portfolio. There is also a potential conflict of interest if a client decides to convert investment assets, on which we charge a fee, to tangible assets like real estate, closely held businesses, permanent life insurance, and other personal assets, on which we don’t charge a fee. Other services not listed above will be billed on an hourly basis. A project fee may be quoted based upon the time and effort required. The total fee and services to be provided are agreed upon at the time of engagement. Project fees will vary based upon the amount of time we incur for the project, in addition to the nature and complexity of services. These may be billed at a rate of up to $500 per hour. Unless otherwise negotiated, terms and conditions under an advisory agreement with Astute Financial, LLC, will be honored for those clients who migrate to KFG, LLC. We will automatically deduct fees from one of the client’s managed accounts unless directed otherwise. As part of this process, the client understands and acknowledges the following: a) The independent custodian sends statements at least quarterly to clients showing all disbursements from the account, including the amount of the financial planning fees paid as well as the asset management fee paid. b) The client provides authorization permitting us to be directly paid by these terms. The client will incur transaction charges for trades executed in the accounts. These transaction fees are separate from our annual financial planning fees. Also, the client will pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). Our firm’s annual financial planning fees are billed on a quarterly basis in arrears. Since we are billing in arrears, our invoices are due and payable when received. If the client wishes to terminate our advisory services, 30 days’ notice in writing is required, stating the wish to cancel the service agreement. Upon receipt of the letter of termination, we will proceed to close out the account and charge a pro-rata annual financial planning fee(s) for services rendered up to the point of termination. LIGHTNING MEETING Our firm charges a flat fee for Lightning Meetings. The fee for 60-minute Lightning meetings with our firm principal is $990; lead financial planner $650 or associate financial planner $350, respectively. Payment is due prior to the commencement of the Lightning Meeting. We do not sell securities or receive any commissions. In order to sell securities for a commission, we would need to have our associated persons licensed with FINRA and registered with a broker-dealer. We have chosen not to do so because we feel strongly it would be difficult to maintain unbiased and objective financial advice if we were to receive commissions from product sales. We do not hold any insurance licenses. When reviewing insurance products for clients, we rely on information given to us by the client’s insurance agent. From time to time, we may request (with client permission and direction) analysis, quotes, and recommendations from licensed insurance agents and brokers whom we trust or have done business within the past. We receive no compensation, directly or indirectly from any insurance product purchased from any insurance agent or broker. Item 6: Performance-Based Fees & Side-By-Side Management We do not charge performance fees. 8  Item 7: Types of Clients & Account Requirements Types of clients we typically provide our services to include Individuals accumulating wealth, high net-worth individuals, business owners, professionals, and retirees. We also provide investment services to trusts, estates and charitable organizations. Our requirements for opening and maintaining accounts or otherwise engaging us: There is no account minimum for either service. • Financial Planning clients have a minimum quarterly fee of $1,875 and for their assets in managed accounts held at Schwab there is an additional 0.04% charged quarterly to partially cover third-party manager fees. New clients pay an initial data-gathering and design fee which is less than or equal to the first two quarterly financial planning fees. • We reserve the right to decline services to any person or firm. We reserve the right to terminate services to any client with a 30-day notice. We may waive the minimum fee where special circumstances exist. For example, the fee may be waived with pre-existing relationships, friends or family members, or family members of clients. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss We choose assets for the client’s portfolio based on the client’s needs, economic conditions, liquidity requirements, proposed investment time horizon, need for diversification, and importance of current income. In addition, we consider each client’s risk tolerance, present and anticipated tax situation, as well as an investment’s historical yield, potential appreciation, and marketability. We rely on the information provided by the client (and other professional advisers), and we are not obligated to independently verify the accuracy of such information or reports. Investment strategies used to implement our advice are generally long-term in nature and primarily utilize a “constant- weighting asset allocation” philosophy. However, investment strategies may include shorter-term purchases depending upon the individual needs and objectives of the client. All proposed investment strategies are evaluated in advance to ensure they are consistent with the client’s stated or written investment policy or directives. We recommend and manage a variety of asset types, including exchange-listed securities, mutual fund shares, corporate debt securities, U.S. government securities, real estate investments, limited partnerships, variable annuities, and Certificates of Deposit. Information used in our analysis is gathered from a variety of sources, including research organizations, professional publications, mutual fund and corporate rating services, prospectuses, financial newspapers and magazines, and annual reports. At its core, asset allocation seeks to achieve efficient diversification of assets to help reduce risk and volatility without unduly sacrificing the portfolio’s ability to meet the client’s stated objectives. Because we believe risk management is a critical component of long-term investment success, asset allocation principles are central to our overall approach. A key element of our investment philosophy is the allocation of assets among multiple asset classes, which may include US stocks, foreign stocks, US bonds, TIPS, High Yield bonds, foreign bonds, cash, public / private REITS, natural resources, absolute return, public / private managed futures. Allocation percentages are tailored to each client’s goals and risk tolerance. Our investment management services include: Identifying specific securities and investment managers within each asset class • Designing and implementing an appropriate asset allocation plan • • Developing a written Investment Policy Statement • Monitoring performance of selected investments • Recommending changes to the Investment Policy Statement as appropriate • Rebalancing portfolios when appropriate 9  • Meeting with clients periodically • Tax-loss and/or gain harvesting • Preparing and presenting periodic reports We utilize publicly available information, including financial news and research materials, as well as subscription-based databases available to professional investment advisers. These resources are reviewed regularly. We may also engage unaffiliated service providers to supply statistical reports, tax alerts, and investment reviews. When appropriate, we may consult with outside experts (without sharing nonpublic personally identifiable client information), including attorneys, investment managers, accountants, or pension specialists. Any fees associated with such consultations are generally borne by us unless otherwise agreed in a separate arrangement between the client and the third-party provider. Risk of Loss and Additional Investment Risks Investing in securities involves risk of loss that clients should be prepared to bear. While markets may increase in value and client accounts may generate gains, it is also possible that markets will decline and client accounts may suffer losses. Clients should understand the risks associated with investing and ensure that their portfolios are aligned with their risk tolerance and objectives. In addition to general market risk, the following specific risks may apply: Individual Security Risk (Issuer Risk): Investments in individual securities are subject to risks specific to the issuing company, including poor management decisions, competitive pressures, regulatory developments, or financial deterioration. These factors may cause a security’s value to decline significantly, regardless of broader market performance. Portfolios holding individual securities may experience greater volatility, particularly where position sizes are significant. Concentration Risk: Concentration risk arises when a portfolio is heavily invested in a limited number of securities, sectors, or asset classes. Such concentration increases sensitivity to events affecting those holdings and may result in greater volatility and the potential for substantial losses. Clients who direct or maintain concentrated positions should understand that these positions may significantly increase both potential gains and losses. Foreign Investment Risk: Investments in foreign securities involve additional risks not typically associated with U.S. investments, including currency fluctuations, political and economic instability, differences in accounting standards, reduced regulatory oversight, and lower liquidity. These risks may be more pronounced in emerging markets. Changes in currency exchange rates may negatively impact returns even when the underlying investment performs favorably in its local market. Small- and Mid-Capitalization Company Risk: Investments in small- and mid-cap companies involve greater risks than those associated with larger, more established companies. These companies may have limited financial resources, less seasoned management, and lower trading volumes, which can lead to increased volatility and reduced liquidity. As a result, these securities may be more susceptible to sudden or significant declines in value, and it may be more difficult to sell positions at desired prices during market stress. Asset Allocation Risk: While asset allocation is designed to help manage risk through diversification, it does not guarantee a profit or protect against loss. Different asset classes may perform differently under varying market conditions, and a diversified portfolio may underperform a more concentrated portfolio during certain periods. 10  Cash Balances: We generally invest client cash balances in money market funds, FDIC-insured Certificates of Deposit, high-grade commercial paper, and/or government-backed debt instruments. Our objective is to seek competitive returns on cash balances while maintaining a relatively conservative risk profile. In some cases, a portion of client assets may remain in cash or cash equivalents for liquidity purposes or to facilitate the payment of advisory fees, as authorized by the client. Please note: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and client account(s) could enjoy a gain, it is also possible that the stock market may decrease, and client account(s) could suffer a loss. It is important clients understand the risks associated with investing in the stock market, that clients are appropriately diversified in investments, and ask us any questions clients may have. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities & Affiliations Richard S. Kahler, MS, CFP®, CFT™, CeFT® is an inactive and non-practicing real estate agent and an inactive and non- practicing certified general appraiser in South Dakota. Clients of our firm will not be solicited to partake in any real estate investment for which Mr. Kahler will earn a commission. Furthermore, neither Mr. Kahler nor the employees, contractors or agents of KFG, LLC will make any referrals to Keller Williams Black Hills, dba, Kahler, Inc., which is partially owned by Marcia Kahler’s living trust. Marcia is the spouse of Mr. Kahler. Should a client of our firm request real estate services; Mr. Kahler may refer them to other real estate firms. Mr. Kahler does not receive any compensation for these referrals. Additionally, Mr. Kahler, a related person, has periodically recommended investments in limited partnerships and Delaware Structured Trusts to clients and has also invested in some of these partnerships himself. This creates a conflict of interest since activity in client portfolios affects portfolios of our related persons. In order to minimize this conflict of interest, Mr. Kahler will notify those clients in similar limited partnerships prior to his personal interest increasing or liquidating. Further, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Mr. Kahler is an indirect owner of Advanced Wellbeing, LLC, which provides financial mental health coaching. Mr. Kahler provides non-advisory services to both KFG and non-KFG clients through Advanced Wellbeing. Clients have the option of engaging in these services at a fee of $325 per hour. As a fiduciary, KFG has certain legal obligations, including the obligation to act in clients’ best interest. KFG maintains a Business Continuity and Succession Plan and seeks to avoid a disruption of service to clients in the event of an unforeseen loss of key personnel, due to disability or death. To that end, KFG has entered into a succession agreement with Focus Partners Wealth, LLC. KFG can provide additional information to any current or prospective client upon request to Richard S. Kahler, at (605) 343-1400 or Rick@kahlerfinancial.com. Paul Freidel is Managing Member and CCO of Astute Financial, LLC, a registered investment adviser with the State of South Dakota since January 2020. Clients of KFG, LLC are not solicited to become clients of Astute Financial. Certain clients of Astute Financial may migrate to KFG, LLC if in their best interest. Paul Freidel and Benjamin Paulding are partners of Freidel & Associates, LLC, a Rapid City based full-service CPA firm. Clients of KFG, LLC may be solicited by the affiliated accounting firm. Clients are under no obligation to utilize tax and accounting services of Freidel & Associates. Clients must separately engage the account firm. Fees for tax and account services are separate from KFG, LLC service fees. There is no compensation for referrals between firms. Fees charged to clients by any 11  of Mr. Freidel’s firms are not increased for referrals between firms. Fee discounts may be offered to clients of multiple firms. In no way will Messrs. Freidel and Paulding through their advisory activities and practices take custody of advisory client assets. Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading At times, the investment interests of the advisory representatives or related persons may coincide with the interest of clients’ accounts. Due to the relatively insignificant investments made by the members or related persons of our firm, in relation to total market investments, these transactions would have no noticeable effect on market prices or movement. However, at no time will we, our representatives, or any related person receive an added benefit or advantage over clients with respect to these transactions as a result of their position. Client interests and needs are at the forefront of our practice. All rules and regulations of the United States Securities and Exchange Commission’s (“SEC”) Investment Advisers Act of 1940 will be strictly enforced. We will not permit insider trading and have established the required internal policy relating to insider trading. The Chief Compliance Officer of our firm is responsible for monitoring its staff’s personal securities holdings records. In 2005, investment advisers were required to implement a written Code of Ethics. Our Code of Ethics is as follows: Fiduciary Responsibilities: We are a fiduciary to each and every one of our clients. The SEC takes the position that investment advisers owe their clients several specific duties as fiduciaries and these include: Advice that is suitable; Full disclosure of material facts and potential conflicts of interest (such that the client has complete and honest disclosure in order to make an informed decision about services of the adviser and about investment recommendations); Utmost and exclusive loyalty and good faith; Seeking best execution of transactions; Our reasonable care to avoid ever misleading the client; and only acting in the client’s best interests. It is our policy to protect the interests of each client and to place his/her interests first and foremost in each and every situation. Further, we monitor the personal trading of all access persons, defined as staff members who have access to client trading and investment recommendations prepared by us. Our staff shall always act in good faith and with candor; we shall be proactive in our disclosure of any conflicts of interest that may impact our clients; and we shall not accept any referral fees or compensation that is contingent upon the purchase or sale of a financial product. Internal Code of Ethics: We take the issue of regulatory compliance seriously. Our firm and our staff are required to comply with state and applicable federal securities regulations. We require that all staff members (advisory representatives and associated persons) immediately report any known or suspected violations of the Adviser’s Fiduciary Duties, Code of Ethics or securities rules and regulations to our Chief Compliance Officer. Failure to report material information will result in loss of authority or termination and possible additional action by a regulator. We will abide by honest and ethical business practices to include, but are not limited to: • We will not induce trading in a client’s account that is excessive in size or frequency in view of the financial resources and character of the account; • We will make investment decisions with reasonable grounds to believe that the decisions are suitable for the client on the basis of information furnished by the client and we will document suitability; • We will place non-discretionary orders only after obtaining client authorization; • We are never to borrow money or securities from, or lend money or securities to a client; • We will not place an order for the purchase or sale of a security if the security is not registered, or the security or transaction is not exempt from registration in states where we provide investment advice; • We will not place orders or recommend that the client place an order to purchase or sell a security through a broker-dealer or agent; engage the services of a broker-dealer or agent; or advisory representative or advisory firm that is not licensed in states where we provide investment advice or with the SEC. 12  All access persons will report all but exempt personal securities trading to the Chief Compliance Officer for themselves and for beneficial relationships. The Chief Compliance Officer is charged with approval and monitoring of personal securities transactions. CFP® Code: Richard S. Kahler, MS, CFP®, CFT™, CeFT®, Nathan Gehring, CFP®, Cecilia Fleming, CFP® and Ben Paulding CFP® all hold the Certified Financial Planner™ designation (“CFP®”). The Certified Financial Planner Board of Standards Inc. (CFP® Board) also has adopted its own Code of Ethics and Professional Responsibility (Code of Ethics) to provide principles and rules to all persons whom it has recognized and certified to use the CFP®, Certified Financial Planner™ and certification marks (collectively “the marks”). The CFP® Board determines who is certified and thus authorized to use the marks. Implicit in the acceptance of this authorization is an obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. The CFP® Code of Ethics’ Principles expresses the profession’s recognition of its responsibilities to the public, to the client, to colleagues and to employers. They apply to all CFP® Board designees and provide guidance to them in the performance of their professional services. Clients are welcome to request a copy of the CFP® Code of Ethics from us. If there are any questions relating to our Code of Ethics or one would like copies of the above Codes, please contact the Chief Compliance Officer of our firm. Further information concerning the CFP® Code of Ethics is available by visiting www.cfp.net. Item 12: Custodial Broker/Dealer Practices Liquidity of the securities traded We seek to recommend a custodian/broker dealer who will hold assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • Ability to maintain the confidentiality of trading intentions • Timeliness of execution • Timeliness and accuracy of trade confirmations • • Willingness to commit capital • Ability to place trades in difficult market environments • Research services provided • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition and Business reputation With this in consideration, our firm recommends the Charles Schwab and Co., Inc., member FINRA/ SIPC (“Schwab“). Schwab is an independent and unaffiliated SEC-registered broker-dealer. Schwab offers our firm services which include custody of securities, trade execution, clearance and settlement of transactions generally used to service all of our clients. We receive some benefits from Schwab through our participation in the program. (Please see the disclosure under Item 14 of this Brochure.) 13  Research and Other Soft Dollar Benefits Schwab may make certain research and brokerage services available at no additional cost to our firm all of which qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. These services may be directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab may include 1) research reports on recommendations or other information about particular companies or industries; 2) economic surveys, data and analyses; 3) financial publications; 4) portfolio evaluation services; 5) financial database software and services; 6) computerized news and pricing services; 7) quotation equipment for use in running software used in investment decision-making; and 8) other products or services that provide lawful and appropriate assistance by Schwab to our firm in the execution of our investment decision-making responsibilities. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. There is no direct link between our firm’s participation in the program and the investment advice we give to our clients, although our firm receives economic benefits through our participation in the program that are typically not available to Schwab retail investors. The benefits received by our firm or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to Schwab. Schwab charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by Schwab may be higher or lower than those charged by other custodians and broker-dealers. Although we will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. As a result of receiving the services discussed above for no additional cost, we may have an incentive to continue to use or expand the use of Schwab’s services. This interest may conflict with the client’s interest of obtaining the lowest commission rate available. Our firm examined this potential conflict of interest when we chose to enter the relationship with Schwab, and we have determined in good faith that such commissions are reasonable in relation to the value of the services provided by such executing broker-dealers. Brokerage for Client Referrals Our firm does not direct client transactions to a particular custodian/broker-dealer in return for client referrals. Directed Brokerage Neither we nor any of our firm’s related persons have discretionary authority in making the determination of the custodian/broker-dealer with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are affected. We routinely recommend that a client directs us to execute through a specified custodian/broker-dealer. Our firm recommends the use of Schwab. Each client will be required to establish their account(s) with Schwab if not already done. Please note that not all advisers have this requirement. A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific custodian/broker-dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. 14  We allow clients to direct brokerage outside our recommendation. However, we may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, the client may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Trade Aggregation and Allocation We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such aggregate orders occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. Proportional allocations to each account will take place in the event of incomplete orders. In all cases trades of KFG and its employees will always trade after clients. Item 13: Review of Accounts or Financial Plans Investment Review The Chief Compliance Officer of KFG holds strategic oversight of all our clients' portfolios and is responsible for energizing the process involved in reviewing the portfolios and is responsible for the project-based work related to investments. The portfolio review process that KFG uses is as follows: As part of our ongoing asset management, we assign the client’s portfolio a minimum of an annual review with more frequent reviews on an as-needed basis. A review of the portfolio could also occur at the time of significant new deposits or withdrawals, material changes in client’s financial information, significant changes in the market, as often as the client may prefer as agreed to at the time of engagement, or at our discretion. These reviews are not necessarily based on the timing of meetings with the client. This review is done on an aggregate client basis and does not require timing decisions. We review the investment managers or securities in the portfolio on an ongoing basis (at least quarterly). Reviews entail analyzing the portfolio, securities, investment managers’ performance, sensitivity to overall markets, economic changes, investment results and asset allocations, to help ensure the investment strategy is structured to continue to meet the client’s stated needs and objectives. We examine each individual holding to see if any significant changes have occurred. We give particular attention to mutual funds held by researching the performance, risk, style, or current operational data of each fund. We then compare the current allocation among the asset classes to the allocation in the client’s target portfolio and Investment Policy Statement. If we determine that adjustments need to be made to bring the portfolio into closer conformity with the target allocation, we research all the assets in the categories in question to determine what changes to make. We then develop the trades needed to make these adjustments and instruct the manager accordingly. Generally, on at least a quarterly basis, we will review the allocation of the directly managed portfolio among asset classes and compare that with the target allocation. We will also periodically compare portfolio returns to appropriate benchmarks. Reports are available through the Client Portal but will be provided upon request, or as the advisor deems appropriate. Clients may call the office at any time during normal business hours to discuss their account, financial situation, or investment needs with their financial advisor or directly with the Chief Compliance Officer. We request that the client contact us no less than annually and promptly if there has been a change in the financial situation as new information may warrant a review or change in the investment strategies. We will request an update of the client’s financial information annually so we can determine if there have been any changes that merit a change in the financial plan. 15  Financial Planning Review The Director of Financial Planning is responsible for strategic oversight of all the financial planning and for supervising the financial planners reviewing the portfolio. The portfolio review process that the financial planning team uses is as follows. We assign the financial plan a minimum of an annual review with more frequent reviews on an as needed basis. A review of the financial plan could also occur at the time of significant changes in a client’s life or material changes in a client’s financial situation. These reviews are not necessarily based on the timing of meetings with the client. Reviews typically involve a review of these areas: insurance, asset protection, estate planning, taxation, financial independence, and cash flow. Hourly and project services terminate upon project completion. In these cases, reviews or updates are not included in the services. We may recommend annual reviews or other follow-up services, but it would be the client’s responsibility to engage additional services from our firm, under a new or amended engagement. Item 14: Other Compensation & Client Referrals Other Compensation Arrangements In addition to the benefits described in Item 12 of this brochure, Schwab may make available to our firm other products and services that benefit us or some of our clients, but not all clients. Some of these products and services assist our firm in managing and administering client accounts. These include software and other technology (and related technological training) that provide access to account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of our fees from client accounts; 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 our accounts, including accounts not maintained at Schwab. As a fiduciary, our firm endeavors to act in client’s best interests. Our recommendation to maintain client assets in accounts at Schwab may be based in part on the benefit to our firm of the availability of some of the foregoing products and services and other arrangements. The nature, cost, or quality of custody and brokerage services provided by Schwab are the ultimate factors in our custodial recommendation, however, the fact we may benefit more by Schwab than another custodian is a conflict of interest. Client Referrals We do not pay referral fees to independent solicitors (non-registered representatives) for the referral of their clients to our firm in accordance with Rule 206 (4)-3 of the Investment Advisers Act of 1940. Item 15: Custody Clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's contact information. If we decide to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. The SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with the account custodian: 16  • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client can terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We encourage clients to raise any questions with us about the custody, safety, or security of client assets. The custodians we do business with will send clients independent account statements listing account balance(s), transaction history, and any fee debits or other fees taken out of the account. Item 16: Investment Discretion If the client chooses to have us manage their portfolio on a non-discretionary basis, that means all trades are reliant on a confirmation from the client which is obtained prior to the trade. If the client chooses to have us manage their portfolio on a discretionary basis, we will discretionarily execute all trades in accordance and compliance with the Investment Policy Statement and its subsequent modifications based on mutual agreement with the client. Discretionary asset management services are designed for clients who prefer to leave the decisions regarding the selection of specific investment vehicles to our firm. This service is similar in all aspects to our non- discretionary services, with the exception that we choose the investments for the portfolio that are in compliance with the Investment Policy Statement and execute the trades discretionarily. Item 17: Voting Client Securities We do not and will not accept the proxy authority to vote client securities. The client will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to the client and ask the party who sent them to mail them directly to the client in the future. The client may call, write, or email us to discuss questions about proxy votes, corporate actions, or other solicitations. Item 18: Financial Information We are not required to provide financial information in this Brochure because: • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. • We do not take custody of client funds or securities. • We do not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. • We have never been the subject of a bankruptcy proceeding. 17