Overview

Assets Under Management: $1.9 billion
Headquarters: OLYMPIA, WA
High-Net-Worth Clients: 386
Average Client Assets: $3 million

Frequently Asked Questions

KILEY JUERGENS WEALTH MANAGEMENT, LLC is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #151088), KILEY JUERGENS WEALTH MANAGEMENT, LLC is subject to fiduciary duty under federal law.

KILEY JUERGENS WEALTH MANAGEMENT, LLC is headquartered in OLYMPIA, WA.

KILEY JUERGENS WEALTH MANAGEMENT, LLC serves 386 high-net-worth clients according to their SEC filing dated March 03, 2025. View client details ↓

According to their SEC Form ADV, KILEY JUERGENS WEALTH MANAGEMENT, LLC offers financial planning, portfolio management for individuals, pension consulting services, and selection of other advisors. View all service details ↓

KILEY JUERGENS WEALTH MANAGEMENT, LLC manages $1.9 billion in client assets according to their SEC filing dated March 03, 2025.

According to their SEC Form ADV, KILEY JUERGENS WEALTH MANAGEMENT, LLC serves high-net-worth individuals and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection

Clients

Number of High-Net-Worth Clients: 386
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 63.59
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 6,242
Discretionary Accounts: 6,116
Non-Discretionary Accounts: 126

Regulatory Filings

CRD Number: 151088
Filing ID: 1948888
Last Filing Date: 2025-03-03 15:35:00
Website: https://kj-wm.com

Form ADV Documents

Primary Brochure: KILEY JUERGENS WEALTH MANAGEMENT ADV BROCHURE (2025-09-18)

View Document Text
Kiley Juergens Wealth Management, LLC 2409 Pacific Avenue SE Olympia, Washington 98501 Telephone: (360) 350-4747 Facsimile: (360) 350-4744 Website: www.kj-wm.com September 18, 2025 FORM ADV PART 2A BROCHURE This Brochure provides information about the qualifications and business practices of Kiley Juergens Wealth Management, LLC. If you have any questions about the contents of this Brochure, please contact us at 360.350.4747. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Kiley Juergens Wealth Management, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Kiley Juergens Wealth Management, LLC is 151088. Kiley Juergens Wealth Management, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1 Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated February 20, 2024 we do not have any material changes to report. You should carefully review these statements promptly when you receive them. 2 Item 3 Table Of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table Of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Item 20 Additional Information Page 1 Page 2 Page 3 Page 4 Page 8 Page 10 Page 10 Page 10 Page 13 Page 13 Page 14 Page 14 Page 17 Page 18 Page 19 Page 20 Page 20 Page 20 Page 21 Page 21 3 Item 4 Advisory Business Description of Services and Fees Kiley Juergens Wealth Management, LLC is a registered investment adviser based in Olympia, Washington. We are organized as a limited liability company under the laws of the State of Washington. We have been providing investment advisory services since 2009. Martin Juergens and John Kiley are our principal owners. Currently, we offer the following investment advisory services, which are personalized to each individual client: • Portfolio Management Services • Financial Planning Services • Selection of Other Advisers • Pension Consulting Services We provide clients access to the Tamarac Reporting and Portfolio Management system which provides clients with a website portal and smartphone app where clients can view, in real time, their accounts and access certain reports. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this Brochure, the words "we", "our" and "us" refer to Kiley Juergens Wealth Management, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. The following additional terms will be noted throughout this Brochure: • Charles Schwab & Co., Inc. is referred to as "Schwab" • Osaic Wealth, Inc. is referred to as "Osaic" • American Funds Service Company® is referred to as "AFS" • The Schwab Advisor Network® is referred to as "SAN" Portfolio Management Services - Separate Account Services If you engage us for this service, we will ask you to provide information concerning your personal and financial situation, investment objectives, tolerance for risk, and your investment time horizon. We will also request that you inform us of any reasonable restrictions you wish to impose on the management of your account. We will provide continuous advice to you regarding the investment of your funds based on your individual needs. Through personal discussions in which your goals, objectives and particular circumstances are established, we will create and manage a portfolio. We will manage advisory accounts on a discretionary and non-discretionary basis. Your account supervision is guided by your stated objectives for example; income, growth and income or growth in conjunction with a risk tolerance of conservative, moderate or aggressive. We will create a portfolio consisting primarily of no-load and load-waived mutual funds and exchange- traded funds ("ETFs"). However, portfolios may also include individual equities and/or other investment products. We will allocate your assets among various investments taking into consideration the overall management style selected by you. The mutual funds will be selected on the basis of any or all of the following criteria: the fund's performance history; the industry sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market 4 sectors will be determined by your individual needs and circumstances. You will have the opportunity to place reasonable restrictions on the types of investments which will be made on your behalf. You will retain individual ownership of all securities. Our annual fee for the Separate Account Services will be no more than 1.0% of your managed assets. This fee may be negotiable under certain circumstances. Fees are negotiable depending on individual client circumstances such as client's total assets managed, the scope of work required for an account or household, and the relationship a client has with the adviser and/or our firm. Our fee for the Separate Account Services will be calculated and paid quarterly in advance (in certain circumstances we may negotiate other fee paying arrangements, such as quarterly in arrears). Except for the initial calendar quarter the Advisory Agreement is in effect, our fee will be calculated as of the first day of each calendar quarter in an amount equal to one-fourth of our annualized fee, based on the value of your account as of the close of the last trading day of the preceding calendar quarter; provided, we may, in our discretion, calculate our fee based on the actual number of days in such calendar quarter, or a weighted average value during such period, as long as the method of calculation for your account is consistently applied. Fees are assessed on all AUM, including securities, cash, and money market balances. For the first calendar quarter that the Advisory Agreement is in effect, and for all other quarters in which an asset is transferred into your account after the last business day of the preceding quarter, our fee will be calculated and billed with respect to each such asset beginning on the date such asset is posted by Charles Schwab & Co., Inc. ("Schwab"), the acting custodian(s), to your custodial account (including any additional account established with Schwab to receive the assets for the account), using the value determined by Schwab as of such date; provided, in our discretion, we may bill our fee for any partial calendar quarter with our fee for the following quarter. You may terminate the portfolio management agreement by providing written notice to our firm. Our fee for the last calendar quarter will be prorated based on the number of calendar days the Advisory Agreement is in effect, and any unearned amount will be refunded to you promptly. Our unpaid fees are due and payable immediately upon termination of the Advisory Agreement. We assist some clients establish direct F-2 share class fund purchases with Capital Group / American Funds for their small business retirement accounts with American Funds Service Company ("AFS") serving as the transfer agent registered with the U.S. Securities and Exchange Commission. AFS is not a qualified custodian under the Custody Rule 206(4)-2 of the Investment Advisers Act of 1940. Please see below for additional information regarding fee debiting from AFS. AFS shall deduct fees from client accounts unless otherwise instructed by KJWM or a client. Fees shall be deducted by redeeming fund shares proportionately for each fund position within a client account unless the client has specifically elected a single fund account. Such redemptions may result in a tax reportable transaction. AFS will take account instructions directly from the clients and fees shall continue until instructions are received by KJWM or a client to cancel the fee debiting. On an ongoing basis KJWM will confirm the fee rate on the client account is accurate and in accordance with the client's AFS Direct Agreement fee debiting schedule. AFS shall invoice KJWM for any losses to the funds resulting from a fee adjustment or transaction correction requested by the KJWM. If the client's assets in a fund account in the program are fully redeemed prior to the quarter-end, then the client's average daily net asset value of the fund will be equal to the client's average daily net asset value through the day prior to the total redemption. The fees taken throughout the quarter shall be paid within thirty (30) days following the end of the quarter for which such fees are payable. 5 Financial Planning Services We offer broad-based, modular, and consultative financial planning services for a fee. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to our firm, we may deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. We charge an hourly fee of $350 for financial planning services, which is negotiable depending on the scope and complexity of the plan, your situation, and your financial objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. We may also offer financial planning services for a fixed fee, which generally ranges between $500 and $3,000. In limited circumstances, your financial circumstances might require financial planning services exceeding our typical scope of services. In such cases, our fee may exceed our standard fee range. Our financial planning fees are negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. Fees are typically due upon completion of services rendered. In some instances, we may require that you pay 50% of the fee in advance and the remaining portion upon the completion of the services rendered. We do not require prepayment of a fee more than six months in advance and in excess of $500. You may terminate the financial planning agreement by providing written notice to our firm. You will incur a pro-rata charge for services rendered prior to the termination of the agreement. If you have pre- paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Selection of Other Advisers As part of our investment advisory services, we may recommend that you use the services of a third party asset manager ("TPAM") to manage your entire, or a portion of your, investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPAM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPAM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will periodically monitor the TPAM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives. Our recommendations to use third party asset managers are included in our portfolio management fee. We do not charge you a separate fee for the selection of other advisers nor will we share in the advisory fee you pay directly to the TPAM. Advisory fees that you pay to the TPAM are established 6 and payable in accordance with the Form ADV Part 2 or other equivalent disclosure document provided by each TPAM to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPAM's brochure for information on its fees and services. You will be required to sign an agreement directly with the recommended TPAM(s). You may terminate your advisory relationship with the TPAM according to the terms of your agreement with the TPAM. You should review each TPAM's Brochure for specific information on how you may terminate your advisory relationship with the TPAM and how you may receive a refund, if applicable. You should contact the TPAM directly for questions regarding your advisory agreement with the TPAM. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as: Diversification; Asset allocation; Risk tolerance; and, Time horizon. Our educational seminars may include other investment-related topics specific to the particular plan. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Our advisory fees for these customized services will be negotiated with the plan sponsor or named fiduciary on a case-by-case basis not to exceed 1.0% of assets under management. Either party to the pension consulting agreement may terminate the agreement by providing written notice to the other party. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client. Types of Investments We primarily recommend Mutual Funds and Exchange Traded Funds; however, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 7 When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Assets Under Management As of December 31, 2024, we provide continuous management services for $1,617,411,871 in client assets on a discretionary basis, and $254,951,796 in client assets on a non-discretionary basis. Item 5 Fees and Compensation Please refer to Item 4 - Advisory Business in this Brochure for information on our advisory fees, fee deduction arrangements, and refund policy according to each service we offer. Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in Mutual Funds and Exchange Traded Funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to Item 12 - Brokerage Practices in this Brochure. Compensation for the Sale of Securities or Other Investment Products Persons providing investment advice on behalf of our firm are registered representatives with Osaic Wealth, Inc., a registered broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. In their capacity as registered representatives, these persons will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by these persons in their capacities as registered representatives is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment 8 advice on behalf of our firm who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase securities products through any person affiliated with our firm. Persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. However, you are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. Persons providing investment advice on behalf of our firm may own interests in multiple commercial or residential real estate companies or private businesses. These persons devote a limited amount of time to such businesses each month. Generally, you will not be solicited to invest in such companies or enter into agreements with such companies to purchase or lease any properties which such companies may own or manage. However, in the event we determine that such an investment or agreement would be suitable for you outside of our advisory relationship, we may present such proposed investment or agreement to you with disclosure of the conflicts of interest that you should consider. Advisory Services to Retirement Plans and Plan Participants As disclosed above, we offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the service agreement that you have previously signed. Our compensation for these services is described in Item 4 - Advisory Business in this Brochure, and also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. We are registered as an investment adviser under the Investment Advisers Act of 1940, and represent that we are not subject to any disqualification as set forth in Section 411 of ERISA. To the extent we perform Fiduciary Services, we are acting as a fiduciary of the Plan as defined in Section 3(21) under the Employee Retirement Income Security Act ("ERISA"). 9 Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Our fees are calculated as described in the Advisory Business section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We offer investment advisory services to individuals, trusts, estates, charitable organizations, corporations, and other business entities. Generally, you must maintain minimum account assets of $100,000, subject to negotiation or waiver by our firm. We may waive the minimum or require a higher or lower minimum, in our sole discretion. If the aggregate value of your account falls below the account minimum, we have the right to require deposit of additional amounts to bring the value of your account up to required minimum or close and liquidate your account and send the proceeds to you in accordance with your written delivery instructions. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our Methods of Analysis and Investment Strategies We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Depending on the particular service, we may use performance analyses, research reports, market data, or other information or services from third parties to assist in selecting the investments for you and in developing and maintaining the Models or Account portfolios. In particular, we may rely on third-party charting services, or third-party services that provide technical or cyclical analyses, in managing your account and identifying market sectors or asset classes. Investments may be selected on the basis of any or all of the following criteria: performance history; the industry sector in which the security invests; the track record of any investment manager; the security's objectives, management style and philosophy, fee structure, trading restrictions, and the ability of Adviser and Custodians to execute orders and maintain records in an efficient manner, at reasonable costs. The strategies to be used to achieve your objectives may include, among others, long-term purchases, short-term purchases, trading (securities sold within 30 days), margin transactions, or option transactions or strategies. Our use of options or margin will tend to increase the potential risk of losses in your account. We may use model portfolios (each a "Model") that our firm (or a third party) constructs and adjusts from time to time to achieve specific investment objectives. During the initial discussions with you, if we determine it is appropriate, we will recommend and assist you to select a suitable Model for your account; however, you will have sole authority to select the Model for the Account. Models we may use are described below: 10 • Charting Analysis - involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. • Technical Analysis - involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. • Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and trends. • Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. • Short Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. • Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. • Option Writing - a securities transaction that involves selling an option. An option is the right, but not the obligation, to buy or sell a particular security at a specified price before the expiration date of the option. When an investor sells an option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. The seller pays the buyer a premium (the market price of the option at a particular time) in exchange for writing the option. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Charting and Technical Analysis - The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. We may use short-term trading (in general, selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Short-term trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and tolerance for risk. Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a tax professional prior to and throughout the investing of your assets. Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-Out) accounting method for calculating the cost basis of your 11 investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Please note that decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities As disclosed under the "Advisory Business" section in this Brochure, we primarily recommend Mutual Funds and Exchange Traded Funds however may recommend any type of investments as appropriate for you since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. Mutual Funds and Exchange Traded Funds: Mutual funds and Exchange Traded Funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. Exchange traded funds differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. During time of extreme market volatility ETF pricing may lag versus the actual net underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day) however there is no guarantee this relationship will always occur. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely which can dilute other investors' interests. Margin: Buying on margin means borrowing money from a broker to purchase stock. Margin trading allows you to buy more stock than you'd be able to normally. An initial investment of at least $2,000 is required for a margin account, though some brokerages require more. This deposit is known as the minimum margin. Once the account is opened and operational, you can borrow up to 50% of the purchase price of a stock. This portion of the purchase price that you deposit is known as the initial margin. Some brokerages require you to deposit more than 50% of the purchase price. Not all stocks qualify to be bought on margin. When you sell the stock in a margin account, the proceeds go to your broker against the repayment of the loan until it is fully paid. There is also a restriction called the maintenance margin, which is the minimum account balance you must maintain before your broker will force you to deposit more funds or sell stock to pay down your loan. When this happens, it's known as a margin call. If for any reason you do not meet a margin call, the brokerage has the right to sell your 12 securities to increase your account equity until you are above the maintenance margin. Additionally, your broker may not be required to consult you before selling. Under most margin agreements, a firm can sell your securities without waiting for you to meet the margin call and you can't control which stock is sold to cover the margin call. You also have to pay the interest on your loan. The interest charges are applied to your account unless you decide to make payments. Over time, your debt level increases as interest charges accrue against you. As debt increases, the interest charges increase, and so on. Therefore, buying on margin is mainly used for short-term investments. The longer you hold an investment, the greater the return that is needed to break even. In volatile markets, prices can fall very quickly. You can lose more money than you have invested. Options: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts; A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. Item 9 Disciplinary Information Kiley Juergens Wealth Management, LLC has been registered and providing investment advisory services since 2009. Neither our firm nor any of our Associated Persons has any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations Persons providing investment advice on behalf of our firm are registered representatives with Osaic Wealth, Inc., a securities broker-dealer, member FINRA/SIPC. At the inception of Kiley Juergens Wealth Management, LLC in 2009, individuals providing investment advice were registered representatives of Pacific West Securities, Inc. until their close in the year 2012. In 2012, we decided to move to Symetra Investment Services, Inc. As a result of acquisition by John Hancock Financial Services, Inc. and other sales, Symetra Investment Services' name has been changed multiple times and has included Signator Financial Services, Inc. and Signator Investors, Inc. On November 5, 2018, Signator Investors, Inc. was acquired by Royal Alliance Associates, Inc. In June of 2023, Royal Alliance Associates, Inc. changed their name to Osaic Wealth, Inc. Osaic Wealth, Inc. is a registered broker-dealer and a member of the FINRA/SIPC. Persons providing investment advice on behalf of our firm are licensed as insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate from our advisory fees. Please see Item 5 - Fees and Compensation in this Brochure for more information on the compensation received by insurance agents who are affiliated with our firm. 13 We may recommend that you use a third party adviser ("TPAM") based on your needs and suitability. Our recommendations to use third party asset managers are included in our portfolio management fee. We do not charge you a separate fee for the selection of other advisers nor will we share in the advisory fee you pay directly to the TPAM. Advisory fees that you pay to the TPAM are established and payable in accordance with the Form ADV Part 2 or other equivalent disclosure document provided by each TPAM to whom you are referred. These fees may or may not be negotiable. You should review the recommended TPAM's brochure for information on its fees and services. You are not obligated, contractually or otherwise, to use the services of any TPAM we recommend. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our firm submit reports of their personal account holdings and transactions to a qualified representative of our firm who will review these reports on a periodic basis. Persons associated with our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover page of this Brochure. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this Brochure. Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We do not maintain custody of your assets that we manage (although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 - Custody, in this Brochure). Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. ("Schwab"), a registered broker- dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account 14 agreement directly with them. We do not open the account for you, although we may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see Your Brokerage and Custody Costs below). How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your 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: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds, etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, and stability of the provider • Prior service to us and our other clients • Availability of other products and services that benefit us, as discussed below (see Products and Services Available to Us From Schwab below) Your Brokerage and Custody Costs For our clients' accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Schwab's commission rates applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. This commitment benefits you because the overall commission rates you pay are lower than they would be otherwise. In addition to commissions, Schwab charges you a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek "best execution" of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How We Select Brokers/Custodians"). For our clients' CollegeAmerica® 529 accounts through AFS, AFS is not a custodian and does not charge you separately for custody services nor will they be compensated by charging you commissions or other fees on trades that it executes or that settle into your CollegeAmerica® 529 account. We cannot deduct our advisory fees directly from the CollegeAmerica® 529 account. Products and Services Available to Us From Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab's business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage— trading, custody, reporting, and related services—many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients' accounts, while others help us 15 manage and grow our business. Schwab's support services generally are available on an unsolicited basis (we don't have to request them) and at no charge to us as long as our clients collectively maintain a total of at least $10 million of their assets in accounts at Schwab. If our clients collectively have less than $10 million in assets at Schwab, Schwab may charge us a quarterly service fee of $1,200. Following is a more detailed description of Schwab's support services: Services That Benefit You Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab's services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients' accounts. They include investment research, both Schwab's own and that of third parties. We may use this research to service all or a substantial number of our clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, record keeping, and client reporting Services That Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party's fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab's Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don't have to pay for Schwab's services so long as our clients collectively keep a total of at least $10 million of their assets in accounts at Schwab. The $10 million minimum may give us an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab's services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and 16 broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab's services (see How We Select Brokers/Custodians above) and not Schwab's services that benefit only us. Research and Other Soft Dollar Benefits We do not have any soft dollar arrangements. Brokerage for Client Referrals See Item 14 - Client Referrals and Other Compensation in this Brochure. Directed Brokerage We routinely recommend that you direct our firm to execute transactions through Schwab. In limited circumstances, and at our discretion, you may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from aggregating trades with other client accounts or from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Not all advisers require their clients to direct brokerage. Block Trades For both discretionary and non-discretionary Separate Accounts, you will authorize us, in our discretion, to bunch or aggregate orders for your account with orders of other clients and to allocate the aggregate amount of the investment among accounts in the manner in which we shall determine appropriate. Block trading may allow trades to be executed in a timelier, equitable manner and may reduce overall transaction costs because such costs are generally shared on a pro-rated basis among all Accounts included in the block. However, you should be aware that due to differences in types of investments, and differences in client objectives, cash positions, and other factors, we cannot anticipate the number of transactions, if any, that will be effected each year through block transactions. We will have the authority to engage in block trading, unless otherwise provided in the client agreement. Clients with non-discretionary Program Accounts should be aware that orders for their accounts may not be included in such block orders, if we determine that including them could adversely affect other Program Accounts participating in the block order or our efficient management of the accounts. In certain situations, aggregation of client orders may operate to the disadvantage of some clients, such as where an account may have been able to have its order executed at a more favorable time. We will attempt to ensure that no client is unreasonably or systematically disadvantaged through the use of block trading. Subject to our Code of Ethics, our firm and our employees may participate in blocks orders with you, as long as we participate in the block on the same terms as you. Item 13 Review of Accounts John F. Kiley, III, Martin E. Juergens, Mark T. Boyer, Robert D. Heck, or Timothy D. Hume will monitor your accounts on a continuous basis and will conduct account annual reviews to ensure the advisory services provided to you and that the portfolio mix is consistent with your stated investment needs and 17 objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: contributions and withdrawals; year-end tax planning; market moving events; security specific events; and/or; changes in your risk/return objectives. We will not provide you with additional or regular written reports in conjunction with account reviews. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). We will review your investment account(s) or your financial plan only at your request. Otherwise, we do not review or monitor your investment account(s), review your financial plan, or review statements you receive from your third-party money manager or account custodian. At your request, we may meet with you and/or your third-party money manager(s) to discuss asset allocation, but we will not make recommendations regarding specific investments or provide any regular written reports to you. Item 14 Client Referrals and Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 - Brokerage Practices in this Brochure). The availability to us of Schwab's products and services is based on us giving particular investment advice, such as buying particular securities for our clients. We receive client referrals from Schwab through our participation in the Schwab Advisor Network® ("SAN"). SAN is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with Kiley Juergens Wealth Management, LLC. Schwab does not supervise us and has no responsibility for our management of clients' portfolios or our other advice or services. We pay Schwab fees to receive client referrals through SAN. Our participation in SAN may raise potential conflicts of interest described below. We pay Schwab a Participation Fee on all referred clients' accounts that are maintained in custody at Schwab and a Non-Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by us is a percentage of the fees the client owes to us or a percentage of the value of the assets in the client's account, subject to a minimum Participation Fee. We pay Schwab the Participation Fee for so long as the referred client's account remains in custody at Schwab. The Participation Fee is billed to us quarterly and may be increased, decreased or waived by Schwab from time to time. The Participation Fee is paid by us and not by the client. We have agreed not to charge clients referred through SAN fees or costs greater than the fees or costs we charge clients with similar portfolios who were not referred through SAN. We generally pay Schwab a Non-Schwab Custody Fee if custody of a referred client's account is not maintained by, or assets in the account are transferred from Schwab. This Fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The Non-Schwab Custody Fee is higher than the Participation Fees we generally would pay in a single year. Thus, we will have an incentive to recommend that client accounts be held in custody at Schwab. 18 The Participation and Non-Schwab Custody Fees will be based on assets in accounts of our clients who were referred by Schwab and those referred clients' family members living in the same household. Thus, we will have incentives to encourage household members of clients referred through SAN to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit Advisor's fees directly from the accounts. For our client accounts maintained in custody at Schwab, Schwab will not charge the client separately for custody but will receive compensation from our clients in the form of commissions or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab's fees for trades executed at other broker-dealers are in addition to the other broker-dealer's fees. Thus, we may have an incentive to cause trades to be executed through Schwab rather than another broker-dealer. We nevertheless, acknowledges our duty to seek best execution of trades for client accounts. Trades for client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for our other clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker- dealers. We do not receive any compensation from any third party in connection with providing investment advice to you. Please refer to Item 12 - Brokerage Practices in this Brochure for disclosures on research and other benefits we may receive resulting from our relationship with Schwab. As disclosed under the Fees and Compensation section in this Brochure, persons providing investment advice on behalf of our firm are licensed insurance agents, and are registered representatives with Osaic Wealth, Inc., a registered broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. For information on the conflicts of interest this presents, and how we address these conflicts, please refer to Item 5 - Fees and Compensation in this Brochure. Item 15 Custody Under government regulations, we are deemed to have custody of your assets if you authorize us to instruct the acting custodian (e.g., Schwab) to deduct our advisory fees directly from your account. The acting custodian maintains actual custody of your assets. You will receive account statements directly from the acting custodian at least quarterly. They will be sent to the email or postal mailing address you provided to the acting custodian. You should carefully review these statements promptly when you receive them. Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, or we may have signatory and check writing authority for client accounts, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third party wire transfers or to sign checks on a client\'s behalf has access to the client\'s assets, and therefore has custody of the client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 19 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We hereby confirm that we meet the above criteria. Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement and/or trading authorization forms. You may grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to Item 4 - Advisory Business in this Brochure for more information on our discretionary management services. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities Proxy Voting We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Item 18 Financial Information We are not required to provide financial information to our clients because we do not: require the prepayment of more than $1,200 in fees and/or prepayment six or more months in advance; or, take custody of client funds or securities; or, have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. 20 Item 19 Requirements for State-Registered Advisers We are a federally registered investment adviser, therefore, we are not required to respond to this item. Item 20 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any non-public personal information about you to any non-affiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys. We restrict internal access to non-public personal information about you to employees, who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your non-public personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. It will be sent to the postal mailing address you provided to Schwab unless you have completed our Electronic Delivery Authorization Form, whereby we will send it to the email address provided on the aforementioned form. Please contact our main office at the telephone number on the cover page of this Brochure if you have any questions regarding this policy. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a profit, the trade error will be corrected in the trade error account of the executing broker-dealer and you will not keep the profit. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 21