Overview
- Headquarters
- Olympia, WA
- Total Firm Assets
- $2.2 billion
- Average High-Net-Worth Client Portfolio Size
- $2.0 million
- Minimum Account Size
- $100,000
Fee Structure
Primary Fee Schedule (KILEY JUERGENS WEALTH MANAGEMENT ADV BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.00% |
| $250,001 | $500,000 | 0.95% |
| $500,001 | $1,000,000 | 0.90% |
| $1,000,001 | $2,000,000 | 0.85% |
| $2,000,001 | $3,500,000 | 0.80% |
| $3,500,001 | $5,000,000 | 0.75% |
| $5,000,001 | and above | 0.70% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $9,375 | 0.94% |
| $5 million | $41,125 | 0.82% |
| $10 million | $76,125 | 0.76% |
| $50 million | $356,125 | 0.71% |
| $100 million | $706,125 | 0.71% |
Clients
- High-Net-Worth Share of Firm Assets
- 55.95%
- Number of High-Net-Worth Clients
- 618
- Total Client Accounts
- 6,799
- Discretionary Accounts
- 6,674
- Non-Discretionary Accounts
- 125
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 151088
Additional Brochure: KILEY JUERGENS WEALTH MANAGEMENT ADV BROCHURE (2026-07-17)
View Document Text
ITEM 1 - COVER PAGE
ADV PART 2A
BROCHURE
KILEY JUERGENS WEALTH MANAGEMENT, LLC
2409 PACIFIC AVENUE SE
OLYMPIA, WA 98501
P/ 360.350.4747
F/ 360.350.4744
W/ WWW.KJ-WM.COM
APRIL 29, 2026
This brochure provides information about the qualifications and business practices of Kiley Juergens Wealth Management, LLC (“KJWM”).
If you have any questions about this brochure's contents, 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 (“SEC”) or any state securities authority. KJWM is a
Registered Investment Adviser (“RIA”). Registration as an Investment Adviser with the SEC or any state securities authority does not imply a
certain level of skill or training.
Additional information about KJWM is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can search this site by a
unique identifying number called an IARD number. The IARD number for KJWM is 151088.
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 1 OF 46
ITEM 2 - MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
Under federal and state law, fiduciaries must make full disclosure to Clients of all material facts relating to the
advisory relationship. This brochure provides clients or prospective clients with information and conflicts of
interest about Kiley Juergens Wealth Management, LLC that should be considered before or when obtaining
our investment advisory services. We are required to update this item to describe the material changes made to
this brochure on an annual basis and deliver to you, within 120 days of the end of the fiscal year, a free updated
brochure that includes or is accompanied by a summary of material changes; or a summary of material changes
and an offer to provide an updated brochure and how to obtain it. We will also provide interim disclosures
regarding material changes, as necessary.
Since the last annual amendment filing on September 18, 2025, this brochure has been amended as follows:
-
Item 5: The firm does not require prepayment of more than $1,200 per client six or more months in advance.
This has not changed our practice but has been updated to reflect regulatory requirements.
-
Item 10: The firm is no longer engaged with Osaic Wealth, Inc.
This brochure may be updated periodically for non-material changes to clarify and provide additional
information.
QUESTIONS & CONCERNS
We encourage you to read this document in its entirety. Our Chief Compliance Officer, Martin Juergens, remains
available to address any questions or concerns regarding this Part 2A Brochure, including any material change
disclosure or information described below.
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 2 OF 46
ITEM 3 - TABLE OF CONTENTS
ITEM 1 - COVER PAGE ____________________________________________________________________________ 1
ITEM 2 - MATERIAL CHANGES ____________________________________________________________________ 2
SUMMARY OF MATERIAL CHANGES ___________________________________________________________ 2
QUESTIONS & CONCERNS ____________________________________________________________________ 2
ITEM 3 - TABLE OF CONTENTS ___________________________________________________________________ 3
ITEM 4 - ADVISORY BUSINESS _____________________________________________________________________ 5
ABOUT OUR FIRM ____________________________________________________________________________ 5
ADVISORY SERVICES WE OFFER _______________________________________________________________ 5
CLIENT OBJECTIVES & RESTRICTIONS _________________________________________________________ 8
WRAP FEE PROGRAM ________________________________________________________________________ 8
REGULATORY ASSETS UNDER MANAGEMENT __________________________________________________ 8
ITEM 5 - FEES AND COMPENSATION ______________________________________________________________ 8
INVESTMENT MANAGEMENT FEE _____________________________________________________________ 8
ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES _________________________ 10
ADDITIONAL FEES & EXPENSES _____________________________________________________________ 11
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT _____________________________ 11
ITEM 7 - TYPES OF CLIENTS ____________________________________________________________________ 12
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS ___________________________________ 12
METHODS OF ANALYSIS ____________________________________________________________________ 12
INVESTMENT STRATEGIES __________________________________________________________________ 13
RISK OF LOSS ______________________________________________________________________________ 14
ITEM 9 - DISCIPLINARY INFORMATION __________________________________________________________ 17
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS _______________________________ 17
INDUSTRY ACTIVITIES ______________________________________________________________________ 17
INSURANCE COMPANIES ___________________________________________________________________ 18
BROKER-DEALER AFFILIATED _______________________________________________________________ 18
PERSONAL RELATIONSHIPS _________________________________________________________________ 18
THIRD PARTY MONEY MANAGERS ___________________________________________________________ 19
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL
TRADING _____________________________________________________________________________________ 19
ITEM 12 - BROKERAGE PRACTICES ______________________________________________________________ 20
INVESTMENT MANAGEMENT SERVICES ______________________________________________________ 20
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 3 OF 46
CHARLES SCHWAB & CO. INC. ______________________________________________________________ 20
ITEM 13 - REVIEW OF ACCOUNTS _______________________________________________________________ 24
CLIENT REVIEWS ___________________________________________________________________________ 24
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION _________________________________________ 24
BROKERAGE PRACTICES ____________________________________________________________________ 24
LEAD GENERATION & REFERRALS ___________________________________________________________ 25
OTHER PROFESSIONALS ____________________________________________________________________ 26
ITEM 15 - CUSTODY ____________________________________________________________________________ 26
FEE DEDUCTION ___________________________________________________________________________ 26
STANDING LETTERS OF AUTHORIZATION (“SLOA”) ___________________________________________ 26
ITEM 16 - INVESTMENT DISCRETION ____________________________________________________________ 26
DISCRETIONARY AUTHORITY _______________________________________________________________ 26
NON-DISCRETIONARY AUTHORITY __________________________________________________________ 27
ITEM 17 - VOTING CLIENT SECURITIES ___________________________________________________________ 27
PROXY VOTING ____________________________________________________________________________ 27
CLASS ACTION LAWSUITS __________________________________________________________________ 27
ITEM 18 - FINANCIAL INFORMATION ____________________________________________________________ 27
FINANCIAL CONDITION ___________________________________________________________________ 27
ADDITIONAL INFORMATION ___________________________________________________________________ 28
PRIVACY POLICY ___________________________________________________________________________ 28
BUSINESS CONTINUITY PLAN _______________________________________________________________ 28
CONTACTING US __________________________________________________________________________ 28
VARYING DISRUPTIONS _____________________________________________________________________ 28
ADV 2B: JOHN F. KILEY III ______________________________________________________________________ 30
ADV 2B: MARTIN E. JUERGENS _________________________________________________________________ 34
ADV 2B: MARK T. BOYER _______________________________________________________________________ 37
ADV 2B: ROBERT D. HECK ______________________________________________________________________ 40
ADV 2B: TIMOTHY D. HUME ____________________________________________________________________ 43
ADV 2B: CARLY SIPE ___________________________________________________________________________ 45
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ITEM 4 - ADVISORY BUSINESS
ABOUT OUR FIRM
Kiley Juergens Wealth Management, LLC is currently registered with the Securities and Exchange Commission
("SEC") as an investment adviser, with its principal place of business located in Washington state. Kiley Juergens
Wealth Management, LLC has been in business since 2009, and its principal owners are Martin Juergens and
John Kiley. Our Firm was registered with the SEC as an investment adviser in 2009. Registration as an Investment
Adviser with the United States SEC or any state securities authority does not imply a certain level of skill or
training.
This brochure is designed to provide detailed and precise information about each item noted in the table of
contents. Certain disclosures are repeated in one or more items, and other disclosures are referred throughout
to be as comprehensive as possible on the broad subject matters discussed.
Within this brochure, specific terms in either are used as follows:
•
•
•
•
•
•
“KJWM” refers to Kiley Juergens Wealth Management, LLC.
“Firm,” “we,” “us,” and “our” refer to Kiley Juergens Wealth Management, LLC.
“Advisor,” “Investment Advisor Representative,” and “IAR” refers to our professional representatives
who provide investment recommendations or advice on behalf of Kiley Juergens Wealth Management,
LLC.
“You,” “yours,” and “Client” refers to Clients of Kiley Juergens Wealth Management, LLC and its
advisors.
“Code” refers to our Firm’s Code of Ethics.
“CCO” refers to our Chief Compliance Officer, Martin Juergens.
ADVISORY SERVICES WE OFFER
Our Firm offers a variety of advisory services, which includes discretionary and non-discretionary investment
management, financial planning, and independent third-party money management. Before rendering any
preceding advisory services, Clients must enter into one or more written Investment Advisory Agreements
(“Agreements”), setting forth the relevant terms and conditions of the advisory relationship.
We do not provide tax or legal advice. Clients should consult with an expert on tax or legal issues.
INVESTMENT ADVISORY SERVICES
Our Firm manages portfolios for individuals, high-net-worth individuals and families, estates, trusts, retirement
plans, corporations, and charitable foundations. We provide investment management and advisory services to
multi-generational families using separately managed accounts under a custodial relationship with an
independent brokerage firm.
With our discretionary relationship, we will reallocate and rebalance the portfolio as appropriate to help meet
your financial objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial
goals.
With our non-discretionary relationship, we will provide recommendations to help meet your financial objectives,
but we must obtain your approval before making any transactions in your account.
KILEY JUERGENS WEALTH MANAGEMENT, LLC
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We primarily invest in equities, fixed income and debt securities, mutual funds, and exchange-traded funds. A
portion of the account may be held in cash, cash equivalents, certificates of deposit, or money market funds as
part of the overall investment strategy. Cash balances may have a higher concentration and represent a sizable
portion of your overall portfolio, depending on the current investment outlook or strategy.
Clients may impose reasonable restrictions on investing in certain securities by notifying Us through written
notification.
Our Firm typically requires a minimum account size of $100,000 for advisory accounts. However, sometimes, at
our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets,
related accounts, and other individual Client circumstances.
THIRD-PARTY MONEY MANAGER
Our Firm provides discretionary investment management services that may be implemented
using model portfolios or investment strategies developed by unaffiliated third parties
(“TPMM”). Under this arrangement, the TPMM provides model allocations and/or security lists,
and KJWM is responsible for selecting the model, determining suitability for each client, and
implementing the model within the client’s custodial account.
Our Firm retains discretionary authority over client accounts and is responsible for trade
implementation, rebalancing, ongoing monitoring, and any modifications necessary to reflect
client-specific restrictions or circumstances. TPMM do not have discretionary trading authority
over client accounts unless separately engaged as an SMA manager under a different
agreement.
INITIAL PUBLIC OFFERINGS
When offered through the account Custodian, we may have the ability to request shares of initial public
offerings (“IPOs”) and secondary offerings for our Clients. These are short-term, speculative investments.
At this time, we will only request shares of an IPO (Initial Public Offerings) for a Client that has specifically
requested those shares.
If several Clients request the shares of an IPO, and we receive fewer shares than were requested, we must
allocate those shares among the participating Clients. The allocations are typically equal or proportionate
to the number of shares requested. Investing in securities involves the risk of loss that Clients should be
prepared to bear. See Item 8 for more detail on the risk associated with investing.
LEGACY MANAGEMENT SERVICES
Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can
limit or restrict our trading and/or billing in these positions.
FINANCIAL PLANNING SERVICES
Our Firm offers financial planning services, which involve preparing a written financial plan covering specific or
multiple topics. We provide full written financial plans, which may address one or several topics: Investment
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 6 OF 46
Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios, and Allocation
Review.
Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to implement our
financial planning recommendations. Our financial planning services do not involve implementing transactions
on your behalf nor include active and ongoing monitoring or management of your investments or accounts.
The Client must execute a separate written agreement if the Client elects to implement any of our investment
recommendations through our Firm or retain our Firm to monitor and manage investments actively.
RETIREMENT PLAN FIDUCIARY AND NON-FIDUCIARY SERVICES
When providing any non-discretionary investment advisory services, we will solely be making investment
recommendations to the Sponsor, and the Sponsor retains full discretionary authority or control over assets of
the retirement plan. We agree to perform any non-discretionary investment advisory services to the retirement
plan as a fiduciary, as defined in ERISA Section 3(21)(A)(ii). The Sponsor may accept or reject any
recommendation. We will act in good faith and with the degree of diligence, care, and skill that a prudent person
rendering similar services would exercise under similar circumstances.
When providing administrative services, we may support the Sponsor with plan governance and committee
education; vendor management and service provider selection and review; investment education; or plan
participant non-fiduciary education services. We agree to perform any administrative services solely in a capacity
that would not be considered a fiduciary under ERISA or any other applicable law. Participant education is
general in nature and does not include individualized investment advice unless otherwise agreed in writing.
When we provide investment models and related recommendations to a plan or its fiduciaries for a fee pursuant
to a written agreement, we will act as a “fiduciary” as defined under Section 3(21) of ERISA and Section 4975 of
the Code with respect to such advice. If we provide only general information or non-fiduciary tools, we will not
be acting as an ERISA or Code fiduciary for those services.
ROLLOVER RECOMMENDATION DISCLOSURE
Our Firm is considered a fiduciary under the Investment Advisers Act of 1940. When we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries
within the meaning of Title I of the Employee Retirement Income Security Act and the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We must act in your best interest and not put our
interests ahead of yours. At the same time, how we make money conflicts with Client interests.
A Client leaving an employer typically has four options regarding an existing retirement plan (and may engage
in a combination of these options):
•
•
•
•
leave the money in the former employer’s plan, if permitted,
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
rollover to an Individual Retirement Account (“IRA”), or
cash out the account value (which depending upon the Client’s age, could result in adverse tax
consequences).
Our Firm may recommend a Client rollover plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its advisors may earn an asset-based fee on the rolled assets. In contrast, a
recommendation that a Client leave their plan assets with their previous employer or rollover the assets to a plan
sponsored by a new employer will result in no compensation to our Firm. Therefore, our Firm has an economic
incentive to encourage a Client to roll plan assets into an IRA that our Firm will manage, which presents a conflict
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of interest. To mitigate the conflict of interest, there are numerous factors that our Firm will consider before
recommending a rollover, including but not limited to:
the investment options available in the plan versus the investment options available in an IRA,
fees and expenses in the plan versus the fees and expenses in an IRA,
the services and responsiveness of the plan’s investment professionals versus those of our Firm,
required minimum distributions and age considerations, and
•
•
•
• protection of assets from creditors and legal judgments,
•
• employer stock tax consequences, if any.
The Chief Compliance Officer remains available to address client questions regarding the supervision and
oversight of rollover and transfer assets.
CLIENT OBJECTIVES & RESTRICTIONS
Our Firm tailors our investment management and advisory services continuously to meet the needs of our
Clients. We seek to ensure Client portfolios are managed consistently with those needs and objectives in mind.
We meet with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity
constraints, and other related factors relevant to managing their portfolios. Clients may impose reasonable
restrictions on managing the accounts if the conditions do not impact the performance of a management
strategy.
WRAP FEE PROGRAM
Our Firm does not sponsor or participate in a Wrap Program.
REGULATORY ASSETS UNDER MANAGEMENT
As of December 31, 2025, our Firm had $2,200,220,068 in regulatory assets under management, approximately
$1,910,210,265 of which was managed on a discretionary basis and $290,009,803 on a non-discretionary basis.
ITEM 5 - FEES AND COMPENSATION
In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s services and
each service’s fees and compensation arrangement. The Client and KJWM’s Investment Advisory Agreement
will outline and agree upon the exact costs and other terms related to the Client’s Accounts.
INVESTMENT MANAGEMENT FEE
Our Firm offers investment management services for an annual fee based on the amount of assets under
management. Our maximum annual fee is 1.00%, can be a fixed fee or blended tiered fee schedule, and we
have a minimum account size of $100,000. We retain the right to waive the minimum account size at our
discretion.
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ANNUAL
ADVISORY FEE
ADVISORY
ACCOUNTS
ASSETS UNDER
MANAGEMENT
BILLING
FREQUENCY
FEES ARE BILLED
BASED ON
First $250,000
1.00%
Next $250,000
0.95%
Next $500,000
0.90%
Next $1,000,000
0.85%
CHARLES SCHWAB &
CO., INC.
Quarterly in
Advance
Market Value of Previous
Quarter End
Next $1,500,000
0.80%
Next $1,500,000
0.75%
$5,000,001 and above
0.70%
The fee schedule above is applied on a blended basis: each asset tier is charged the rate applicable to that tier,
and the total annual advisory fee equals the sum of the fees calculated for each tier. The rate applicable to a
given tier applies only to the assets within that tier, not to the Client's entire account value. Clients may
alternatively elect a single flat annual fee, not to exceed 1.00%, as documented in the Client's Investment
Advisory Agreement.
Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by other investment
advisers offering similar services/programs.
Our annual fee is prorated and charged quarterly, in advance, based on the value of the Client’s assets under
management as of the close of business on the last business day of the previous quarter. Cash and cash
equivalents, including money market funds, are subject to the agreed-upon advisory fee. Clients should
understand that the advisory fees charged on these balances may exceed the returns provided by cash, cash
equivalents, or money market funds, especially in low-interest rate environments.
Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on any Client.
The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified
Custodian(s) of your account. The Client will authorize your account's qualified Custodian(s) to deduct fees from
the account and pay such fees directly to our Firm. All account assets, transactions, and advisory fees will be
shown on the monthly or quarterly statements provided by the Custodian. You should review your account
statements received from the qualified Custodian(s) and verify that appropriate investment advisory fees are
being deducted. The qualified Custodian(s) will not verify the accuracy of the investment advisory fees deducted.
We may aggregate related Client accounts to calculate the advisory fee applicable to the Client. The investment
management agreement will outline the fee charged to a Client and any breakpoints based on the level of assets
managed. The fees are subject to change with prior written notice to the Client.
Our annual investment advisory fee may be higher than that of other investment advisers that offer similar
services and programs. In addition to our compensation, you may incur charges imposed at the mutual fund
level (e.g., advisory fees and other fund expenses).
Accounts initiated or terminated during a calendar quarter will be charged a prorated fee based on the days the
Client account was open during that quarter. Any prepaid, unearned fees will be refunded upon termination of
any account.
THIRD-PARTY MONEY MANAGER
Clients pay an advisory fee to KJWM for discretionary investment management services. In
addition, clients may pay separate fees associated with Third-Party Money Manager
(“TPMM”) services and/or platform fees if the models are accessed through a third-party
program. Any such fees are disclosed in the applicable program documents and are in
addition to the Firm’s fee. Fees are generally calculated as a percentage of assets under
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 9 OF 46
management and are billed in advance or in arrears on a monthly or quarterly basis and may
be deducted directly from the client’s account with authorization. Specific fees will be
disclosed in the agreement signed between the client and the TPMM.
FINANCIAL PLANNING FEE
Our Firm provides financial planning services under a fixed or hourly fee arrangement. This arrangement charges
a mutually agreed-upon fee for financial planning services. Hourly fees will not exceed $350 per hour and flat
fees will range from $500 - $3,000 depending on the scope and complexity of the Client’s individual
circumstances.
Fees charged for our financial planning services are negotiable based upon the type of Client, the services
requested, the investment adviser representative providing advice, the complexity of the Client's situation, the
composition of the Client's account, other advisory services provided, and the relationship of the Client and the
investment adviser representative.
The amount of the fee for your engagement is specified in your financial planning agreement with us. At our
sole discretion, the Client may be required to pay the fee at the time the agreement is executed with our Firm;
however, our Firm does not require or solicit prepayment of more than $1,200 in fees per Client, six months or
more in advance. The fee is considered earned upon delivery of the financial plan, and any unpaid amount is
immediately due.
The Client may pay the fees owed for the financial planning services by submitting payment directly via check.
If the Client elects to pay by automatic deduction from an existing investment account, they will provide written
authorization to our Firm for such a charge.
If the Client terminates the financial planning services after entering into an agreement with our Firm, the Client
will be invoiced and responsible for immediate payment of any hourly financial planning services performed by
us before receiving notice of termination. For financial planning services, our Firm performs under a fixed or
hourly fee arrangement, the Client will be responsible for paying a pro-rated fixed fee equivalent to the
percentage of work that our Firm completed. If there is a remaining balance of any fees paid in advance after
deducting fees from the final invoice, those remaining proceeds will be refunded to the Client.
RETIREMENT PLAN FIDUCIARY AND NON-FIDUCIARY FEE
For Retirement Plan Advisory Services compensation, we charge an advisory fee as negotiated with the Plan
Sponsor and as disclosed in the Employer-Sponsored Retirement Plans Consulting Agreement (“Plan Sponsor
Agreement”).
Typically, the billing period for these fees is paid quarterly. This fee is negotiable, but the terms and the advisory
fee are agreed upon in advance and acknowledged by the Plan Sponsor Agreement or Plan Provider’s account
agreement. Fee billing methods vary depending on the Plan Provider.
Our Firm or the Plan Sponsor may terminate the Agreement upon 30 days written notice to the other party. The
Plan Sponsor is responsible for paying for the services rendered until the termination of the Agreement.
ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON TECHNOLOGIES
Our Firm has contracted with Advyzon Technologies to utilize its technology platforms to support data
reconciliation, performance reporting, fee calculation, client relationship maintenance, quarterly performance
KILEY JUERGENS WEALTH MANAGEMENT, LLC
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evaluations, and other functions related to managing Client accounts' administrative tasks. Due to this
arrangement, Advyzon will have access to client accounts, but Advyzon will not serve as an investment advisor
to our clients or bill the accounts. Advyzon charges our firm an annual fee for each account administered by its
software. Please note that our Firm’s annual fee to Advyzon will not increase the Client's fee. Our firm will pay
the annual fee from the portion of the management fee retained by Our Firm. Our Firm and Advyzon are non-
affiliated companies.
ADDITIONAL FEES & EXPENSES
In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other third parties,
such as broker-dealers, Custodians, trust companies, banks, and other financial institutions. These additional
charges include securities, transaction fees, custodial fees, fees charged by the SMA, ITPM, and Manager
charges imposed by a mutual fund or ETF (Exchange Traded Funds) in a Client’s account, as disclosed in the
fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage
accounts and securities transactions. Our brokerage practices are described at length in Item 12 below. Neither
our Firm nor its supervised persons accept commission compensation for selling securities or other investment
products. Further, we do not share any additional fees and expenses outlined above.
Our Firm’s investment strategies may include mutual and exchange-traded funds (“ETFs”). Our policy is to
purchase institutional share classes of those mutual funds selected for the Client’s portfolio. The institutional
share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or
ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds
expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset-
based costs incurred by the fund. Some fund families offer different classes of the same fund, and one share
class may have a lower expense ratio than another. Mutual fund expense ratios are in addition to our fees; we
do not receive any portion of these charges. If an institutional share class is not available for the mutual fund
selected, the adviser will purchase the least expensive share class available for the mutual fund. As share classes
with lower expense ratios become available, we may use them in the Client’s portfolio or convert the existing
mutual fund position to the lower-cost share class. Clients who transfer mutual funds into their accounts with our
Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a
mutual fund has a frequent trading policy, the policy can limit a Client’s transactions in fund shares (e.g., for
rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the
respective mutual fund prospectus.
When selecting investments for our Clients’ portfolios, we might choose mutual funds on your account
Custodian’s Non-Transaction Fee (NTF) list. This means that your account Custodian will not charge a transaction
fee or commission associated with the purchase or sale of the mutual fund.
The mutual fund companies that choose to participate in the Client’s Custodial NTF fund program pay a fee to
the Custodian to be included in the NTF program. The mutual fund owners bear the fee that a company pays to
participate in the program, as captured in the fund’s expense ratio. When choosing a fund from the Client’s
Custodial NTF list, our Firm considers the expected holding period, position size, and expense ratio versus
alternative funds. Depending on our Firm’s analysis and future events, NTF funds might not always be in the
Client’s best interest.
ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
Performance-based fees are based on a share of capital gains on or appreciation of the assets in a Client’s
account.
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Our Firm does not accept performance-based or other fees based on a share of capital gains or appreciation of
a Client's assets.
ITEM 7 - TYPES OF CLIENTS
Our Firm provides investment management, financial planning, and third-party portfolio management to
individuals, high-net-worth individuals and families, estates, trusts, partnerships, retirement plans, corporations,
and charitable foundations.
Our firm requires a minimum account value of $100,000 for advisory services. Clients have the option to
aggregate all household accounts to meet this minimum. Exceptions to the minimum account requirement may
be granted based on the Client's relationship with their representative.
For fee calculation purposes, unless instructed otherwise, we will automatically aggregate related client
accounts, a practice commonly known as "householding" portfolios. Householding may result in lower fees than
if each account were billed separately, as the combined value is used to determine the account size and the
corresponding annualized fee.
Our approach to householding considers the overall family dynamic and relationship. Additionally, if applicable,
and as noted in Appendix B of the Investment Management Agreement, legacy positions may be excluded from
the fee calculation.
Clients must execute a written agreement with our Firm specifying the advisory services to establish a Client
arrangement with us.
ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS
METHODS OF ANALYSIS
Our Investment Advisory Representatives will generally use the following analysis methods to formulate our
investment advice and manage Client assets. However, each IAR can manage its Client’s account as necessary,
and their specific analysis method may vary from below. Clients should acknowledge that investing in securities
involves the risk of loss, regardless of the strategies, that Clients should be prepared to bear.
CHARTING
In this type of technical analysis, we review market and security activity charts to identify when the market is
moving up or down and to predict how long the trend may last and when that trend might reverse.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
because a poorly managed or financially unsound company may underperform regardless of market movement.
FUNDAMENTAL
Fundamental analysis attempts to identify stocks offering sturdy growth potential at a competitive price by
examining the underlying company's business and conditions within its industry or the broader economy.
Investors have traditionally used fundamental analysis for longer-term trades, relying on metrics such as earnings
per share, price-to-earnings ratio, price-to-earnings growth, and dividend yield.
MODEL MANAGER
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Our Firm examines the Manager's experience, expertise, investment philosophies, and past performance to
determine if that Manager has demonstrated an ability to invest over time and in different economic conditions.
Our Firm monitors the Manager’s underlying holdings, strategies, concentrations, and leverage as part of our
Firm’s periodic risk assessment. Additionally, as part of our due diligence process, our Firm surveys the
Manager’s compliance and business enterprise risks.
TECHNICAL
Technical analysis is a form of security analysis that uses price and volume data, typically displayed graphically
in charts. The charts are analyzed using various indicators to make investment recommendations. Technical
analysis has three main principles and assumptions: (1) The market discounts everything, (2) prices move in trends
and countertrends, and (3) price action is repetitive, with specific patterns recurring.
RISKS FOR ALL FORMS OF ANALYSIS
Our Firm’s securities analysis method relies on the assumption that the companies whose securities we purchase
and sell, the rating agencies that review these securities, and other publicly available sources of information
about these securities, are providing accurate and unbiased data. While we are alert to indications that data
may be incorrect, there is always a risk that the analysis may be compromised by inaccurate or misleading
information.
INVESTMENT STRATEGIES
Our Firm may use any of the following investment strategies when managing Client assets and providing
investment advice:
LONG-TERM HOLDING
Our Firm purchases securities with the intent to hold them in the Client's account long-term (longer than one
year). In extreme circumstances, we may be forced to sell a fund completely within a year of buying it. An
example would be a fund Manager resigns, and we do not have confidence in the new management. Also, fund
positions may be trimmed occasionally to rebalance the portfolio.
A risk in a long-term purchase strategy is that holding the security for this length of time may decline in value
before we decide to sell. We do not guarantee the future performance of the account or any specific level of
performance, the success of any investment decision or strategy we may use, or the success of the overall
management of the account. The Client understands that the investment decisions our Firm makes for the
Client’s account are subject to various market, currency, economic, political, and business risks and that those
investment decisions will not always be profitable. Clients are reminded that investing in any security entails the
risk of loss, which they should be willing to bear.
STRATEGIC ASSET ALLOCATION
The primary investment strategy used by our Firm is based on the diversification of the Client's assets among
various investment vehicles and asset classes, popularly termed "Asset Allocation." Our Firm's recommendations
focus primarily on achieving a diversified portfolio of investment assets with desirable risk and return
characteristics. We meet regularly to evaluate new and reevaluate existing investment opportunities. During
these meetings, we deliberate on issues regarding the proper allocation of Client assets based on current
conditions.
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TACTICAL ASSET ALLOCATION
Tactical asset allocation is an active management portfolio strategy that shifts the percentage of assets held in
various categories to take advantage of market pricing anomalies or strong market sectors. This strategy allows
portfolio Managers to create extra value by taking advantage of certain situations in the marketplace. It is a
moderately active strategy since Managers return to the portfolio's original asset mix once reaching the desired
short-term profits.
CASH & CASH EQUIVALENT ALLOCATION
Our Firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit,
high-grade commercial paper and/or government backed debt instruments. Ultimately, our Firm tries to achieve
the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at
least a partial cash balance will be maintained in a money market account so that our Firm may debit advisory
fees for our services related to our Asset Management and Comprehensive Portfolio Management services, as
applicable.
RISK OF LOSS
A Client’s investment portfolio is affected by general economic and market conditions, such as interest rates,
availability of credit, inflation rates, economic conditions, changes in laws, and national and international political
circumstances.
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Our Firm will assist Clients in determining an appropriate
strategy based on their tolerance for risk.
While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
ACTIVE MANAGEMENT RISK
Due to its active management, a portfolio could underperform other portfolios with similar investment objectives
or strategies.
ALLOCATION RISK
A portfolio may use an asset allocation strategy to pursue its investment objective. There is a risk that a portfolio’s
allocation among asset classes or investments will cause a portfolio to lose value or cause it to underperform
other portfolios with a similar investment objective or strategy or that the investments themselves will not
produce the returns expected.
COMPANY RISK
The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices, growth strategy,
and other factors particular to a company rather than the overall market. Some of these risks cannot be predicted,
such as the retirement or death of a senior executive, which may lead to negative performance in the future.
CONCENTRATION RISK
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Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could
expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified
portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an
investor if there is a negative sector move.
CYBERSECURITY RISK
Increased Internet use makes a portfolio susceptible to operational and informational security risks. In general,
cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include but are not
limited to infection by computer viruses or other malicious software code, gaining unauthorized access to
systems, networks, or devices through “hacking” or other means to misappropriate assets or sensitive
information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party
service providers may cause disruptions at third-party service providers and impact our business operations,
potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and
other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation
costs; or additional compliance costs. Our Firm has an established business continuity and disaster recovery plan
and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent
limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics.
EQUITY RISK
Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate over short or
extended periods. Equity securities have greater price volatility than fixed-income securities. The market price
of equity securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may decline
in value due to factors affecting markets, industries, sectors or geographic regions represented in those markets,
or individual security concerns.
EVENT RISK
The possibility is that an unforeseen event will negatively affect a company or industry and, thus, increase security
volatility.
FIXED INCOME & DEBT RISK
Debt securities are affected by changes in interest rates. When interest rates rise, the value of debt securities is
likely to decrease. Conversely, when interest rates fall, the values of debt securities are likely to increase. The
values of debt securities may also be affected by changes in the issuing entities' credit rating or financial
condition.
FREQUENT TRADING RISK
A portfolio Manager may actively and frequently trade investments in a portfolio to carry out its investment
strategies. Frequent trading of investments increases the possibility that a portfolio, as relevant, will realize
taxable capital gains (including short-term capital gains, which are typically taxable at higher rates than long-
term capital gains for U.S. federal income tax purposes), which could reduce a portfolio's after-tax return.
Frequent trading can also mean higher brokerage and other transaction costs, which could reduce a portfolio's
return. The trading costs and tax effects of portfolio turnover can adversely affect its performance.
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INTEREST RATE RISK
When interest rates increase, the value of the account’s investments may decline, and the account’s share value
may decrease. This effect is typically more pronounced for intermediate and longer-term obligations. This effect
is also typically more pronounced for mortgages and other asset-backed securities since the value may fluctuate
more significantly in response to interest rate changes. When interest rates decrease, the account’s current
income may decline.
LEGACY HOLDING RISK
Investment advice may be offered on any investment a Client holds at the start of the advisory relationship.
Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets
invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect
to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client.
LIQUIDITY RISK
Low trading volume, large positions, or legal restrictions are some conditions that could limit or prevent a
portfolio from selling securities or closing positions at desirable prices. Securities that are relatively liquid when
acquired could become illiquid over time. The sale of any such illiquid investment might be possible only at
substantial discounts or might not be possible at all. Further, such investments may take more work to value.
MANAGEMENT RISK
An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the
account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the
intended results, the account could underperform other accounts with similar objectives and investment
strategies.
MARKET RISK
Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events
will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is
the risk that you will lose money, and your investment may be worth less upon liquidation. Due to a lack of
demand in the marketplace or other factors, an account may only be able to sell some or all the investments
promptly or may only be able to sell assets at desired prices.
MODEL RISK
Models are based on assumptions about markets, interest rates, correlations, volatility, and other
factors and there is no assurance that these assumptions will prove accurate. A Model may
underperform other investment approaches, may not achieve a client’s intended objectives, and may
expose a client to unintended risks, including concentration risk, style drift, or sector/asset class
exposure that may not be apparent from the Model’s stated objective.
MUNICIPAL BOND RISK
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Investments in municipal bonds are affected by the municipal market and the factors in the cities, states, or
regions where the strategy invests. Issues such as legislative changes, litigation, business and political conditions
relating to a particular municipal project, municipality, state, or territory, and fiscal challenges can impact the
value of municipal bonds. These matters can also impact the ability of the issuer to make payments. Also, the
public information about municipal bonds is less than that for corporate equities or bonds. Additionally, supply
and demand imbalances in the municipal bond market can cause deterioration in liquidity and a lack of price
transparency.
THIRD PARTY MONEY MANAGER RISK
When implementing third-party model portfolios, the Firm selects the model and determines its
appropriateness for a client. The Adviser may deviate from a model to accommodate restrictions, tax
considerations, cash flows, or other client circumstances, which may cause performance to differ
from model results. Clients are subject to model risk including the risk that the model’s assumptions,
allocations, or underlying holdings may underperform or be changed by the model provider without
notice.
TIMING RISK
The risk is that the investment needs to perform better after its purchase or sale. Moreover, if the Client requires
redemption, the Client may face a loss due to poor overall market performance or security performance at that
time.
ITEM 9 - DISCIPLINARY INFORMATION
Registered investment advisers are required to provide information about all disciplinary information that would
be material to a Client’s evaluation of our Firm or the integrity of its management. Clients should refer to the
Advisor’s Form ADV Part 2B Brochure Supplement. If the Client did not receive the Advisor’s Form ADV Part 2B
Brochure Supplement, the Client should contact the Chief Compliance Officer using the information provided
on the cover page of this Brochure. Our Chief Compliance Officer is available to address any questions a Client
or prospective client may have regarding the above or any information outlined in this Brochure.
Our Firm has no legal or disciplinary events that are material to a Client or prospective clients, evaluation of our
advisory business, or the integrity of our management services.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
INDUSTRY ACTIVITIES
Clients should review our IARs Form ADV Part 2B Brochure Supplement to determine whether the Client’s IAR
is engaged in any of the activities described below that may create a conflict of interest. If the Client did not
receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should contact the Firm’s Chief
Compliance Officer using the information on the cover page of this Brochure. The Chief Compliance Officer is
available to address any questions a Client or prospective client may have regarding any of the below conflicts
of interest, or any other information outlined in this Brochure.
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INSURANCE COMPANIES
In their individual capacities, some of our Firm’s IARs are agents for various third-party insurance companies. As
such, these individuals may receive separate yet customary commission compensation for implementing product
transactions on our advisory Clients' behalf. Clients, however, are not obligated to engage IARs when
considering implementing advisory or insurance recommendations. Implementing any or all recommendations
is solely at the Client's discretion.
BROKER-DEALER AFFILIATED
Our Firm is not a broker-dealer, but some of the IARs are Registered Representatives of Purshe Kaplan Sterling
Investments (“PKS”), a full-service broker-dealer, member FINRA/SIPC, which compensates them for effecting
securities transactions. When placing securities transactions through PKS in their capacity as Registered
Representatives, they will earn sales commissions. Because some of the IARs are dually registered
representatives and agents of PKS and our Firm, PKS, has specific supervisory and administrative duties under
the requirements of FINRA Conduct Rule 3280. PKS and our Firm are not affiliated companies. Some of our IARs
spend a portion of their time in connection with broker-dealer activities.
As a broker-dealer, PKS engages in various activities normally associated with securities brokerage firms.
Pursuant to the investment advice given by our Firm or its IARs, investments in securities may be recommended
for Clients. If PKS is selected as the broker-dealer, PKS and its Registered Representatives, including some of
the IARs of our Firm, may individually receive commissions for executing securities transactions.
If PKS is selected as the broker-dealer, the transaction charges may be higher or lower than the charges you may
pay if the transactions were executed at other broker-dealers. You should note, however, that you are under no
obligation to purchase securities through the IARs of our Firm or PKS.
Moreover, you should note that under the rules and regulations of FINRA, PKS must maintain certain Client
records and perform other functions regarding certain aspects of the investment advisory activities of its
Registered Representatives. These obligations require PKS to coordinate with and have the cooperation of its
Registered Representatives that operate as or are otherwise associated with investment advisors other than PKS.
Some of the IARs, in their capacity as Registered Representatives of PKS or as agents appointed with various
life, disability, or other insurance companies, receive insurance commissions, fee trails, or other compensation
from the respective product sponsors or because of effecting securities transactions for Clients. However, Clients
should note that they are not obligated to purchase investment products through our IARs.
As a result of the relationship with PKS, they may have access to certain confidential information (e.g., financial
information, investment objectives, transactions, and holdings) about our Clients, even if the Client does not
establish any account through PKS. If you would like a copy of the PKS Privacy Policy, please contact our Firm’s
CCO. The contact information for our Firm can be found on the Cover Page of this Brochure.
PERSONAL RELATIONSHIPS
From time to time, our firm may provide investment advisory services to individuals with whom our personnel
have personal relationships, such as friends or family members. These relationships may include jointly held
accounts, informal financial assistance, or investment management services provided at a reduced or waived
fee.
While these accounts are subject to the same investment process, policies, and procedures as all other client
accounts, there is a potential for perceived or actual conflicts of interest, including the possibility of preferential
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treatment or allocation of investment opportunities. To address this, we monitor and supervise these accounts
as we would any other client account, and any deviations in treatment (e.g., fees or access to products) are
documented and reviewed by the Chief Compliance Officer.
Our policies prohibit favoritism and require that investment decisions be made in the best interest of each client,
regardless of relationship status.
THIRD PARTY MONEY MANAGERS
The Firm may recommend third-party money managers (“TPMM”). The Firm’s recommendation of a TPMM
may create a conflict of interest if the Firm receives any economic benefit from such TPMM (e.g., reduced
platform fees, marketing support, access to research, or other non-cash benefits). The Adviser addresses this
conflict by disclosing it and by selecting providers believed to be appropriate based on the client’s needs and
the Firm’s due diligence.
ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT
TRANSACTIONS, & PERSONAL TRADING
Our Firm maintains a Code of Ethics to reinforce the fiduciary principles governing our Firm and its employees.
The Code, among other things, requires all employees to act with integrity and ethics, and professionalism.
Policies against overreaching, self-dealing, insider trading, and conflicts of interest are outlined in our Code. Our
Code forbids employees from trading, either personally or on behalf of others, based on non-public material
information or communicating non-public material information to others violating the law.
Additionally, our Code sets forth restrictions and quarterly attestations on receiving gifts, outside business
activities, personal trading activity, maintenance of personal brokerage accounts, and other matters. The Code
is appropriately designed and implemented to prevent or eliminate potential conflicts of interest between our
Firm, our employees and IARs, Clients, and investors. We always strive to make decisions in our Client's best
interest should a conflict of interest arise.
Clients should be aware that no set of rules, policies, or procedures can anticipate, avoid, or address all potential
conflicts of interest.
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
Our employees, IARs, and our associated persons are not prohibited from owning or trading securities bought,
sold, and recommended to our Clients, provided such personal trading activity complies with the parameters,
limitations, and requirements of the Code. Employees, IARs, and associated persons must receive approval from
our Firm’s CCO when engaging in reportable securities transactions. Our CCO is responsible for reviewing all
employees', IARs, and associated persons' trading when they occur and periodically reviewing trading activity.
Our CCO has broad discretion to reject employee trading for any reason. Our Firm’s policies and procedures
related to the personal trading activity of employees aim to demonstrate our commitment to placing Clients’
interests ahead of our trading interests.
While our Firm does not maintain a proprietary trading account and therefore does not have a direct material
financial interest in any securities it recommends to Clients, in certain situations, our Firm’s employees and
associated persons may purchase interests in the same securities at the same or different portfolio percentages
or risk levels, in which one or more Clients is investing or has invested. Conversely, a Client may purchase
interests in security where our employees, IARs, and associated persons are investing or have invested.
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Any exceptions to the Code require the prior approval of the CCO. We will provide a copy of the Code to any
Client or prospective client upon such written or verbal request. Such requests should be directed to our Firm’s
CCO. The contact information for our Firm can be found on the Cover Page of this Brochure.
ITEM 12 - BROKERAGE PRACTICES
INVESTMENT MANAGEMENT SERVICES
Clients must maintain assets in an account with a “qualified Custodian,” a broker-dealer or bank. If our Firm is
asked to give a recommendation, our recommendation is based on the broker’s cost and fees, skills, reputation,
dependability, and compatibility with the Client. The Client may obtain lower commissions and fees from other
brokers.
CHARLES SCHWAB & CO. INC.
While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and
open accounts with Schwab by entering into account agreements directly with them. The Client opens the
accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s.
HOW OUR FIRM SELECTS CUSTODIAN-BROKER
Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on
terms that are, overall, most advantageous compared to other available providers and their services. Our Firm
considers a wide range of factors, including, among others:
Combination of transaction execution and asset custody services (without a separate fee for custody).
• Capability to execute, clear, and settle trades (buy and sell securities for Client accounts).
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payments, etc.).
• The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), 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, other fees, etc.) and willingness to
negotiate the prices.
• Reputation, financial strength, and stability.
• Prior service to our Firm and our other Clients.
Availability of other products and services that benefit our Firm, as discussed below (see “Products and Services
Available to Us from Schwab”).
CLIENT BROKERAGE & CUSTODY COSTS
For Clients' accounts, Schwab maintains and generally does not charge separately for custody services. However,
Schwab receives compensation by charging ticket charges or other fees on trades it executes or settling into
Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker"
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or "trade away" fee for each trade that our Firm has executed by a different broker-dealer but where the
securities bought or the funds from the securities sold are deposited (settled) into a Client’s Schwab account.
These fees are in addition to the ticket charges or compensation the Client pays the executing broker-dealer.
Because of this, our Firm has Schwab execute most trades for Client accounts to minimize trading costs. Our
Firm has determined that having Schwab execute most trades is consistent with our duty to seek the "best
execution" of Client trades. Best execution means the most favorable terms for a transaction based on all
relevant factors, including those listed above (see How Our Firm Selects Custodian-Broker).
PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB
Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory
Firms and 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; others help us
manage and grow our business. Schwab’s support services typically are available on an unsolicited basis and at
no charge to our Firm. These are typically considered soft dollar benefits because there is an incentive to do
business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have established policies
in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker is in
the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in
carrying out services to Clients. The following is a more detailed description of Schwab’s support services:
SERVICES THAT BENEFIT OUR CLIENTS
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 we might not otherwise have access to or would require a significantly higher minimum initial investment
by our Clients. Schwab’s services described in this paragraph benefit our Clients and their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
Schwab also makes other products and services available that benefit our Firm but may not directly benefit our
Clients or their accounts. These products and services assist our Firm in managing and administering our Clients’
accounts. They include investment research, both Schwab’s own and that of third parties. Our Firm may use this
research to service all or a substantial number of our Client's accounts, including accounts not maintained at
Schwab. In addition to investment research, Schwab also makes available software and other technology that:
• Provides 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, recordkeeping, and Client reporting.
SERVICES THAT GENERALLY BENEFIT ONLY US
Schwab also offers other services to help our Firm manage and further develop our business enterprise.
These services include:
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• 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 our Firm. 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 our Firm with other benefits, such as occasional business
entertainment for our personnel.
OUR INTEREST IN SCHWAB’S SERVICES
The availability of these services from Schwab benefits our Firm because we do not have to produce or purchase
them. These services are not contingent upon our Firm committing any specific amount of business to Schwab
in trading commissions. We believe our selection of Schwab as Custodian and Broker is in our Client’s best
interests.
Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit
our Client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be
based, in part, on the benefits Schwab provides to our Firm or our Agreement to maintain certain Assets Under
Management at Schwab and not solely on the nature, cost, or quality of custody and execution services
provided by Schwab.
• Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and other
fiduciary duties. Schwab's execution quality may be different from other broker-dealers.
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions
through a specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage.
We place trades for Client accounts subject to our duty to seek the best execution and other fiduciary duties.
• We will aggregate trades for ourselves or our associated persons with your trades, providing that the
following conditions are met:
o Our policy for the aggregation of transactions shall be fully disclosed separately to our existing
Clients (if any) and the broker/dealer(s) through which such transactions will be placed.
o We will only aggregate transactions if we believe that aggregation is consistent with our duty
to seek the best execution (which includes the duty to seek the best price) for the Client and is
consistent with the terms of our investment advisory agreement.
o No advisory Client will be favored over any other Client; each Client that participates in an
aggregated order will participate at the average share price for all transactions in a given
security on a given business day, with transaction costs based on each Client's participation in
the transaction.
o Our Firm will prepare a written statement (“Allocation Statement”) specifying the participating
o
Client accounts and how to allocate the order among those Clients.
If the aggregated order is filled in its entirety, it will be allocated among Clients per the
allocation statement; if the order is partially filled, the accounts that did not receive the previous
trade's positions should be "first in line" to receive the next allocation.
o Notwithstanding the preceding, the order may be allocated on a basis different from that
specified if all Client accounts receive fair and equitable treatment. The reason for the
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difference in allocation will be documented and reviewed by our Firm’s Compliance Officer.
Our Firm’s books and records will separately reflect, for each Client account, the orders which
are aggregated, and the securities held by and bought for that account.
o Our Firm will not receive additional compensation or remuneration of any kind because of the
o
proposed aggregation; and
Individual advice and treatment will be accorded to each advisory Client.
AGGREGATION & ALLOCATION OF TRANSACTIONS
Our Firm does not typically aggregate transactions; however, we may aggregate transactions if we believe that
aggregation is consistent with the duty to seek the best execution for our clients and is consistent with the
disclosures made to clients and terms defined in the client Investment Advisory Agreement. If we do aggregate
trades for ourselves or our associated persons with your trades, we will ensure that the following conditions are
met:
• When only a small percentage of the order is executed, with respect to purchase allocations, allocations
may be given to accounts high in cash.
• Concerning sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, to the smallest position, or to an account
that is out of line concerning security or sector weightings relative to other portfolios with similar
mandates.
•
•
• We may allocate one account when that account has limitations in its investment guidelines prohibiting
it from purchasing other securities that we expect to produce similar investment results, and other
accounts can purchase that in the block.
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account's assets after placing an order.
If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more
account(s), we may exclude the account(s) from the allocation.
• Our Firm will document the reasons for any deviation from a pro-rata allocation.
In certain cases, client requests or specific needs will trigger an unplanned transaction in a security where an
aggregate transaction occurred previously during the day. Under these circumstances, client transactions will be
excluded from the block transaction and receive differing pricing.
TRADE ERRORS
Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always avoid
Client trade errors.
Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in the
Client's best interest. In cases where the Client causes the trade error, the Client will be responsible for any loss
resulting from the correction. Depending on the specific circumstances of the trade error, the Client may not be
able to receive any gains generated due to the error correction. In all situations where the Client does not cause
the trade error, the Client will be made whole, and we would absorb any loss resulting from the trade error if
our Firm caused the error. If the Custodian causes the error, the Custodian will cover all trade error costs. If an
investment error results in a gain when correcting the trade, the gain will be donated to charity. Our Firm will
never benefit or profit from trade errors.
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DIRECTED BROKERAGE
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transaction
through a specified broker-dealer. Additionally, our Firm typically does not permit the Client to direct brokerage.
Our Firm places trades for Client accounts subject to its duty to seek the best execution and other fiduciary
duties.
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific
broker or dealer to obtain goods or services on the plan's behalf. 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.
ITEM 13 - REVIEW OF ACCOUNTS
CLIENT REVIEWS
Our Firm reviews Client accounts and financial plans periodically. Our IARs will monitor Client accounts regularly
and perform annual reviews with each Client. All accounts are reviewed for consistency with Client investment
strategy, asset allocation, risk tolerance, and performance. More frequent reviews may be triggered by changes
in an account holder’s personal, tax, or financial status. Geopolitical and macroeconomic-specific events may
also trigger reviews. Our recommendations depend on the information provided by the Client. Our Client must
notify our Firm of any situation that would impair our ability to manage our Client accounts properly.
The Client receives a copy of each trade confirmation (unless the Client has authorized the Custodian to suppress
the confirmations) and the standard written account statement from the qualified account Custodian every
quarter.
ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION
BROKERAGE PRACTICES
As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer
programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There is no
direct link between our participation in the program and the investment advice we give to our Clients. However,
we receive economic benefits through our participation in the program that is typically not available to any other
independent advisors participating in the program. These benefits include the following products and services
(provided without cost or at a discount):
• Receipt of duplicate Client statements and confirmations.
• Research-related products and tools.
• Consulting services.
• Access to a trading desk serving adviser participants.
• Access to block trading (which provides the ability to aggregate securities transactions for execution
and then allocate the appropriate shares to Client accounts);
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• The ability to have advisory fees deducted directly from Client accounts.
• Access to an electronic communications network for Client order entry and account information.
• Access to mutual funds with no transaction fees and certain institutional money Managers.
• Discounts on compliance, marketing, research, technology, and practice management products or
services provided to us by third-party vendors.
Custodians may also have paid for business consulting and professional services received by some of our IARs.
Some of the products and services made available by Custodians through the program may benefit us but may
not benefit your account. These products or services may assist us in managing and administering Client
accounts, including accounts not maintained at our recommended Custodian. Other services made available by
the Custodian are intended to help us manage and further develop our business enterprise. The benefits our
Firm or our IARs receive through participation in the program do not depend on the amount of brokerage
transactions directed to the Custodian. Due to these arrangements, our Client does not pay more for assets
maintained at Schwab. As part of our fiduciary duties to Clients, we always endeavor to put our Client's interests
first. Clients should be aware, however, that receiving economic benefits from our Firm or our IARs in and of
itself creates a conflict of interest because the cost of these services would otherwise be borne directly by us.
These arrangements could indirectly influence our choice of Custodian for custody and brokerage services.
Clients should consider these conflicts of interest when selecting a Custodian. The products and services
provided by the Custodian, how they benefit us, and the related conflicts of interest are described above.
LEAD GENERATION & REFERRALS
SCHWAB ADVISOR NETWORK
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
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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.
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other
professionals. However, we do not receive monetary or other material compensation for referring Clients to such
professionals. We also do not pay any person or firm commissions or other items of material value when referring
Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn a referral fee, nor are there
established quid pro quo arrangements. Each Client can accept or deny such referral or subsequent services.
ITEM 15 - CUSTODY
Regulators have defined custody as having access or control over Client funds or securities. As it applies to our
Firm, we do not have physical custody of funds or securities.
FEE DEDUCTION
Our Firm is deemed to have constructive custody over those Client accounts where it can deduct our fees directly
from the Client account. If we comply with certain regulatory requirements, this constructive custody does not
mandate that our Firm undergo a surprise audit for those accounts. Our Clients receive account statements
directly from the qualified Custodian at least quarterly.
We strongly urge our Clients to compare such reports with the statements received from the qualified Custodian.
Furthermore, when our Firm calculates our investment management fees and instructs the Custodian to remit
these fees to us directly from Clients’ accounts, the Custodian does not verify our calculation of fees. Our Firm
performs quarterly testing to ensure that our fees are charged per the Client’s Investment Advisory Agreement
on file with our Firm.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Additionally, our Firm is deemed to have custody of the Client’s funds or securities when you have standing
authorizations with their Custodian to move money from your account to a third-party Standing Letter of
Authorization (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers
with the Custodian. The SEC has set forth standards to protect your assets in such situations, which we follow.
We do not have a beneficial interest in any of the accounts we are deemed to have Custody of where SLOAs
are on file. In addition, account statements reflecting all activity on the account(s) are delivered directly from the
qualified Custodian to each Client or the Client’s independent representative at least monthly. You should
carefully review those statements and are urged to compare the statements against reports received from us.
When you have questions about your account statements, contact us, your Advisor, or the qualified Custodian
preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
DISCRETIONARY AUTHORITY
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Upon receiving written authorization from the Client, our Firm provides discretionary investment advisory
services for Client accounts. For discretionary accounts, before engaging our Firm to provide investment
advisory services, you will enter into a written Investment Advisory Agreement with us granting our Firm the
authority to supervise and direct, on an ongoing basis, investments per the Client's investment objective and
guidelines. In addition, our Client will need to execute additional documents required by the Custodian to
authorize and enable our Firm, in its sole discretion, without prior consultation with or ratification by our Client,
to purchase, sell or exchange securities in and for your accounts. We are authorized, at our discretion and
without prior consultation with the Client, to (1) buy, sell, exchange, and trade any stocks, bonds, or other
securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the
Custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you,
the Client.
The limitations on investment and brokerage discretion held by our Firm are:
• For discretionary accounts, we require that we be given the authority to determine which securities and
the amounts to be bought or sold.
• Any limitations on this discretionary authority shall be in writing as indicated in the Investment Advisory
Agreement. Clients may change or amend these limitations as required.
NON-DISCRETIONARY AUTHORITY
In some instances, we may not have discretionary authority. For non-discretionary accounts, our Firm will discuss
all transactions with our Client before execution, or the Client will be required to make the trades in an employer-
sponsored account.
ITEM 17 - VOTING CLIENT SECURITIES
PROXY VOTING
Our Firm cannot vote for Client securities. Clients will receive proxies or other solicitations directly from the
Custodian or a transfer agent. Clients are responsible for obtaining and voting proxies for all securities
maintained in their portfolios. We may provide advice to you regarding your voting of proxies. Clients can
contact our Firm with any questions or concerns about a particular solicitation.
CLASS ACTION LAWSUITS
Our Firm does not advise or instruct Clients on whether to participate as a member of class action lawsuits and
will not automatically file claims on the Client’s behalf. However, if a Client notifies us that they wish to participate
in a class action, we will provide the Client with transaction information about the Client’s account that is required
to file a proof of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
FINANCIAL CONDITION
Our Firm has no financial commitment that impairs its ability to meet Client contractual and fiduciary obligations
and has not been the subject of a bankruptcy proceeding. We do not require or solicit prepayment of more than
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$1,200 in fees per Client six months or more in advance. Therefore, we are not required to include a balance
sheet for the most recent fiscal year.
ADDITIONAL INFORMATION
PRIVACY POLICY
Our Firm collects non-public personal information about Clients from information received on applications or
other forms and information about Client transactions with firm affiliates, others, or our Firm. We do not disclose
any nonpublic personal information about current or former Clients except as permitted by law or to provide
services. Firm employees have limited access to Clients' data based on their responsibilities to provide products
or services to Clients.
Our Firm maintains physical, electronic, and procedural safeguards in compliance with federal standards to
protect Client information. If the IAR servicing a Client account leaves our Firm to join another firm, the IAR is
not permitted to retain copies of specific Client information.
BUSINESS CONTINUITY PLAN
Our Firm has developed a Business Continuity Plan to address how our Firm will respond to events that
significantly disrupt the operation of our business. Since the timing and impact of disasters and disruptions are
unpredictable, our Firm will be flexible in responding to current events as they occur.
Within 24 hours after a significant business disruption, our Firm plans to quickly recover and resume business
operations and respond by safeguarding employees and property, making a financial and operational
assessment, protecting our Firm’s books and records, and allowing Clients to transact business. Given the scope
and severity of the significant business disruption, our business continuity plan is designed to permit our Firm to
resume operations as quickly as possible.
Our Firm’s business continuity plan addresses: data back-up and recovery; all mission critical systems; financial
and operational assessments; alternative communications with customers, employees, and regulators; alternate
physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory
reporting; and assuring Clients’ prompt access to their funds and securities if our Firm is unable to continue as
a business.
Our Firm backs up essential records in a geographically separate area. At the same time, every emergency poses
unique problems based on external factors, such as the time of day and the severity of the disruption. Its
objective is to restore operations and be able to complete existing transactions and accept new transactions
and payments within four hours of the disruptive event. Client orders and requests for funds and securities could
be delayed during this period.
CONTACTING US
If a Client cannot contact our Firm via (360) 350-4747 after a significant business disruption, please visit the
website at www.kj-wm.com to review updated contact information.
VARYING DISRUPTIONS
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Significant business disruptions can vary in scope, such as disruption that affects only our Firm, a single building
housing our Firm, the business district where our Firm is located, the city where our Firm is located, or the whole
region. Within each area, the disruption's severity can also vary from minimal to severe. In a disruption to only
our Firm or a building housing our Firm, our Firm will transfer operations to a local site when needed and expect
to recover and resume business within 24 hours.
In a disruption affecting our Firm’s business district, city, or region, our Firm will transfer operations to a site
outside the affected area and recover and resume business within three (3) days. In either situation, our Firm
plans to continue the business, transfer operations to its clearing firm if necessary, and provide Clients with
instructions on contacting our Firm through its website: www.kj-wm.com. If the significant business disruption is
so severe that it prevents our Firm from remaining in business, our Firm will ensure the Client’s prompt access
to their funds and securities.
This information is provided solely to Clients of our Firm, and no further distribution or disclosure is permitted
without the prior written consent of our Firm. No person other than our Firm Clients can rely on any statement
herein. Our Firm’s Business Continuity Plan is reviewed and updated regularly and is subject to change.
Please visit the website at www.kj-wm.com for the most current copy of this disclosure. You can request an
updated copy by contacting our Firm at (360) 350-4747 or writing our Firm at 2409 Pacific Ave. SE Olympia, WA
98501.
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ITEM 1 - COVER PAGE
ADV PART 2B
BROCHURE
JOHN KILEY III
MARTIN JUERGENS
MARK T. BOYER, CFP®
ROBERT HECK, MBA, CFP®
TIMOTHY HUME
CARLY SIPE
KILEY JUERGENS WEALTH MANAGEMENT, LLC
2409 PACIFIC AVENUE SE
OLYMPIA, WA 98501
P/ 360.350.4747
F/ 360.350.4744
W/ WWW.KJ-WM.COM
APRIL 29, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John Kiley III
(CRD# 2343432), Martin Juergens (CRD# 4604990), Mark Boyer (CRD #5516829), Robert Heck (CRD# 6244995), Timothy
Hume (CRD# 6901076), and Carly Sipe (CRD# 7804297). The information in this brochure supplements the Part 2A brochure
of Kiley Juergens Wealth Management, LLC (hereinafter “KJWM” or “firm”), which you should have received a copy of.
Please get in touch with our Chief Compliance Officer at (360) 350-4747 or info@kj-wm.com if you did not receive KJWM’s
Part 2A brochure or have any questions about the contents of this supplement. Additional information about Mark Boyer is
available on the SEC’s website at www.adviserinfo.sec.gov.
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
JOHN F. KILEY III
• CRD #: 2343432
• YEAR OF BIRTH: 1968
EDUCATIONAL BACKGROUND:
• 1990: University of Washington; B.A., Finance
BUSINESS BACKGROUND:
• 2026 – Present: Purshe Kaplan Sterling Investments: Registered Representative
• 2009 – Present: Kiley Juergens Wealth Management: President/Wealth Advisor
• 2023 – 2026: Osaic Wealth, Inc.; Registered Representative
• 2018 – 2023: Royal Alliance Associates, Inc.; Registered Representative
• 2016 – 2018: Signator Investors, Inc.; Registered Representative
• 2013 – 2018: Signator Financial Services, Inc.; Registered Representative
• 2012 – 2013: Symetra Investment Services, Inc.; Registered Representative
• 2009 – 2012: Pacific West Securities, Inc.; Registered Representative
• 2007 – 2009: Birchtree Financial Services, Inc.; Registered Representative
• 2007 – 2009: RSM McGladrey, Inc.; Investment Advisor Representative
• 1993 – 2007: CitiGroup Global Markets, Inc.; First Vice President / Registered Representative /
Investment Advisor Representative
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
John Kiley has no history of any legal or disciplinary events deemed material to a client’s consideration of John
Kiley to act as their investment adviser representative. FINRA’s BrokerCheck® system and the Investment
Adviser Public Disclosure system provides additional information regarding the registration and disciplinary
history of John Kiley. Please visit FINRA’s BrokerCheck® system at https://brokercheck.finra.org or the IAPD
system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
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LICENSED INSURANCE REPRESENTATIVE
John Kiley is a licensed insurance agent. Insurance recommendation implementation is separate and apart
from Mr. Kiley’s role with KJWM. As an insurance professional, [Advisor] will receive customary commissions
and related revenues from the various insurance companies selling products. [Advisor] is not required to
offer the products of any particular insurance company. Commissions generated by insurance sales do not
offset regular advisory fees. This practice presents a conflict of interest in recommending certain insurance
companies' products. Clients are not obligated to implement any recommendations made by [Advisor].
[Advisor] will spend approximately 10% of his time per month in this capacity.
REGISTERED REPRESENTATIVE
John Kiley is a Registered Representative and Investment Advisor Representative of Purshe Kaplan Sterling
Investments, a securities broker/dealer, Financial and a member of the Industry Regulatory Authority, Inc.
(“FINRA”) and an investment adviser registered with the US Securities and Exchange Commission (“SEC”).
As a broker-dealer, Purshe Kaplan Sterling Investments engages in various activities normally associated
with securities brokerage firms. Pursuant to the investment advice given by John Kiley, investments in
securities will be recommended for you. If Purshe Kaplan Sterling Investments is selected as the broker-
dealer, it will affect transactions in securities for you, a client of [FIRM NAME] and [ADVISOR NAME]. By
serving as the broker-dealer, Purshe Kaplan Sterling Investments and John Kiley will receive commissions
for executing securities transactions.
If Purshe Kaplan Sterling Investments is selected as the broker-dealer, the transaction charges can be higher
or lower than the charges you pay if the transactions were executed at other broker-dealers. You should
note, however, that you are under no obligation to purchase securities through John Kiley, KJWM or Purshe
Kaplan Sterling Investments.
John Kiley will provide advice regarding investment company securities. You should be aware that, in
addition to the advisory fees you pay, each investment company also charges its own separate investment
advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual
funds can be purchased separately independent of the investment management services of [NAME OF
FIRM].
John Kiley, in their capacity as registered representatives of Purshe Kaplan Sterling Investments, or as
agents appointed with various life, disability or other insurance companies, receives commissions, 12(b) -1
fees, trails, or other compensation from the respective product sponsors and/or as a result of effecting
securities transactions for you. However, you should note that you are not obligated to purchase investment
products through John Kiley. They can offer various advisory programs and services through Purshe Kaplan
Sterling Investments in addition to the advisory services they can offer through KJWM.
ITEM 5: ADDITIONAL COMPENSATION
John Kiley does not receive any economic benefit outside of the salaries and bonuses described in Item 4 of
this brochure or on Form ADV Part 2A Items 10 and 12.
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ITEM 6: SUPERVISION
John Kiley is supervised through a compliance program designed to prevent and detect federal and state
securities law violations. This compliance program is overseen by Martin Juergens, the Chief Compliance Officer
of KJWM. As Chief Compliance Officer, Martin Juergens reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed.
Martin Juergens can be reached at (360) 350-4747 or info@kj-wm.com.
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
MARTIN E. JUERGENS
• CRD #: 4604990
• YEAR OF BIRTH: 1977
EDUCATIONAL BACKGROUND:
• 2001: Western Washington University; B.A., Finance
BUSINESS BACKGROUND:
• 2026 – Present: Purshe Kaplan Sterling Investments: Registered Representative
• 2009 – Present: Kiley Juergens Wealth Management: CEO/CCO/Wealth Advisor
• 2023 – Present: Osaic Wealth, Inc.; Registered Representative
• 2018 – 2023: Royal Alliance Associates, Inc.; Registered Representative
• 2016 – 2018: Signator Investors, Inc.; Registered Representative
• 2013 – 2016: Signator Financial Services, Inc.; Registered Representative
• 2013 – 2013: Symetra Investment Services, Inc.; Registered Representative
• 2009 – 2012: Pacific West Securities, Inc.; Registered Representative
• 2007 – 2009: RSM McGladrey, Inc.; Investment Advisor Representative
• 2002 – 2007: CitiGroup Global Markets, Inc.; Second Vice President / Registered Representative /
Investment Advisor Representative
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
history
of Martin
Juergens.
visit
FINRA’s BrokerCheck®
system
Martin Juergens has no history of any legal or disciplinary events deemed material to a client’s consideration of
Martin Juergens to act as their investment adviser representative. FINRA’s BrokerCheck® system and the
Investment Adviser Public Disclosure system provides additional information regarding the registration and
disciplinary
at
Please
https://brokercheck.finra.org or the IAPD system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
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LICENSED INSURANCE REPRESENTATIVE
Martin Juergens is a licensed insurance agent. Insurance recommendation implementation is separate and
apart from Mr. Juergens’ role with KJWM. As an insurance professional, Mr. Juergens will receive customary
commissions and related revenues from the various insurance companies selling products. Mr. Juergens is
not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain insurance companies' products. Clients are not obligated to implement any
recommendations made by Mr. Juergens. Mr. Juergens will spend approximately 10% of his per month in
this capacity.
REGISTERED REPRESENTATIVE
Martin Juergens is a Registered Representative and Investment Advisor Representative of Purshe Kaplan
Sterling Investments, a securities broker/dealer, Financial and a member of the Industry Regulatory
Authority, Inc. (“FINRA”) and an investment adviser registered with the US Securities and Exchange
Commission (“SEC”).
As a broker-dealer, Purshe Kaplan Sterling Investments engages in various activities normally associated
with securities brokerage firms. Pursuant to the investment advice given by Martin Juergens, investments
in securities will be recommended for you. If Purshe Kaplan Sterling Investments is selected as the broker-
dealer, it will affect transactions in securities for you, a client of KJWM and Mr. Juergens. By serving as the
broker-dealer, Purshe Kaplan Sterling Investments and Martin Juergens will receive commissions for
executing securities transactions.
If Purshe Kaplan Sterling Investments is selected as the broker-dealer, the transaction charges can be higher
or lower than the charges you pay if the transactions were executed at other broker-dealers. You should
note, however, that you are under no obligation to purchase securities through Martin Juergens, Mr.
Juergens or Purshe Kaplan Sterling Investments.
Martin Juergens will provide advice regarding investment company securities. You should be aware that,
in addition to the advisory fees you pay, each investment company also charges its own separate investment
advisory fees and other expenses (internal management fees). In addition, you should be aware that mutual
funds can be purchased separately independent of the investment management services of KJWM.
Martin Juergens, in their capacity as registered representatives of Purshe Kaplan Sterling Investments, or
as agents appointed with various life, disability or other insurance companies, receives commissions, 12(b)
-1 fees, trails, or other compensation from the respective product sponsors and/or as a result of effecting
securities transactions for you. However, you should note that you are not obligated to purchase investment
products through Martin Juergens. They can offer various advisory programs and services through Purshe
Kaplan Sterling Investments in addition to the advisory services they can offer through KJWM.
ITEM 5: ADDITIONAL COMPENSATION
Martin Juergens does not receive any economic benefit outside of the salaries and bonuses described in Item
4 of this brochure or on Form ADV Part 2A Items 10 and 12.
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ITEM 6: SUPERVISION
Martin Juergens is supervised through a compliance program designed to prevent and detect violations of the
federal and state securities laws. Martin Juergens is the firm’s Chief Compliance Officer. Supervision is
conducted by John Kiley. Compliance supervision includes review of portfolios, review of investment policy
statements, review of advisory agreements, review of emails, personal transactions, and portfolio
trading. John Kiley can be reached at (360) 350-4747 or john@kj-wm.com.
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
MARK T. BOYER, CFP ®
• CRD #: 5516829
• YEAR OF BIRTH: 1981
EDUCATIONAL BACKGROUND:
• 2010: University of Washington; B.A
BUSINESS BACKGROUND:
• 2014 – Present: Kiley Juergens Wealth Management, LLC; Investment Advisory Representative
• 2023 – 2026: Osaic Wealth, Inc.; Registered Representative
• 2018 – 2023: Royal Alliance Associates, Inc.; Registered Representative
• 2016 – 2018: Signator Investors, Inc.; Registered Representative
• 2014 – 2016: Signator Financial Services, Inc.; Registered Representative
• 2008 – 2014: TwinStar Financial Advisers & Cetera Financial Services; Financial Advisor & Registered
Investment Adviser Representative
• 2007 – 2008: Green Realty Group; Relator
• 2006 – 2008: TwinStar Credit Union; Personal Banker
PROFESSIONAL DESIGNATIONS:
• CERTIFIED FINANCIAL PLANNER™ (CFP®) 1
CERTIFIED FINANCIAL PLANNER (“CFP ®”) DESIGNATION MINIMUM QUALIFICATIONS 1
I am certified for financial planning services in the United States by the Certified Financial Planner Board of Standards, Inc. (“CFP
Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may
use these and the CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP® certification is voluntary.
No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.CFP.net.
CFP® professionals have met the CFP Board’s high standards for education, examination, experience, and ethics. To become a
CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-
approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the
financial planning subject areas the CFP Board has determined are necessary for the competent and professional delivery
of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may
satisfy some of the coursework requirements through other qualifying credentials. CFP Board implemented the bachelor’s
degree or higher requirement in 2007 and the financial planning development capstone course requirement in March
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or
higher degree or completed a financial planning development capstone course.
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•
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an
individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial
planning situations.
•
Experience – Complete 6,000 hours of professional experience related to the personal financial planning process or 4,000
hours of apprenticeship experience that meets additional requirements.
•
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking
Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”),
which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and
maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with the CFP Board’s Code and Standards. This includes a
commitment to the CFP Board, as part of the certification, to act as a fiduciary, and therefore, act
in the best interests of the client, at all times when providing financial advice and financial
planning. CFP Board may sanction a CFP® professional who does not abide by this commitment,
but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar
commitment should obtain a written engagement that includes a fiduciary obligation to the
client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement
process, which could result in suspension or permanent revocation of their CFP® certification.
Check designation status online at www.cfp.net/verify-a-cfp-professional.
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
Mark Boyer has no history of any legal or disciplinary events deemed material to a client’s consideration of Mark
Boyer to act as their investment adviser representative. FINRA’s BrokerCheck® system and the Investment
Adviser Public Disclosure system provides additional information regarding the registration and disciplinary
history of Mark Boyer. Please visit FINRA’s BrokerCheck® system at https://brokercheck.finra.org or the IAPD
system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
Mark Boyer does not engage in any other investment-related businesses or occupations deemed material in
your consideration of Mark Boyer as your investment advisor representative.
ITEM 5: ADDITIONAL COMPENSATION
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Mark Boyer does not receive any economic benefit outside of the salaries and bonuses described in Item 4 of
this brochure or on Form ADV Part 2A Items 10 and 12.
ITEM 6: SUPERVISION
Mark Boyer is supervised through a compliance program designed to prevent and detect federal and state
securities law violations. This compliance program is overseen by Martin Juergens, the Chief Compliance Officer
of KJWM. As Chief Compliance Officer, Martin Juergens reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed.
Martin Juergens can be reached at (360) 350-4747 or info@kj-wm.com
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
ROBERT D. HECK, MBA, CFP ®
• CRD #: 6244995
• YEAR OF BIRTH: 1984
EDUCATIONAL BACKGROUND:
• 2011: Willamette University; MBA
• 2007: Willamette University; B.A.
BUSINESS BACKGROUND:
• 2013 – Present: Kiley Juergens Wealth Management, LLC; Investment Advisor Representative
• 2013 – 2026: Osaic Wealth, Inc.; Registered Representative
• 2018 – 2023: Royal Alliance Associates, Inc.; Registered Representative
• 2016 – 2018: Signator Investors, Inc.; Registered Representative
• 2013 – 2016: Signator Financial Services, Inc.; Registered Representative
• 2013: Symetra Investment Services, Inc.; Registered Represetnative
• 2013: National Alliance of State Health Co-ops; Executive Director & CEO
• 2011 – 2012: Denny Heck For Congress; Scheduler / Personal Aide
• 2007 – 2011: Willamette University; Assistant Director of Annual Giving
PROFESSIONAL DESIGNATIONS:
• CERTIFIED FINANCIAL PLANNER™ (CFP®)
CERTIFIED FINANCIAL PLANNER (“CFP ®”) DESIGNATION MINIMUM QUALIFICATIONS
I am certified for financial planning services in the United States by the Certified Financial Planner Board of Standards, Inc. (“CFP
Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and I may
use these and the CFP Board’s other certification marks (the “CFP Board Certification Marks”). The CFP® certification is voluntary.
No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about
the CFP® certification at www.CFP.net.
CFP® professionals have met the CFP Board’s high standards for education, examination, experience, and ethics. To become a
CFP® professional, an individual must fulfill the following requirements:
•
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-
approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the
financial planning subject areas the CFP Board has determined are necessary for the competent and professional delivery
of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may
satisfy some of the coursework requirements through other qualifying credentials. CFP Board implemented the bachelor’s
degree or higher requirement in 2007 and the financial planning development capstone course requirement in March
KILEY JUERGENS WEALTH MANAGEMENT, LLC
05.2026 | PAGE 40 OF 46
2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or
higher degree or completed a financial planning development capstone course.
•
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an
individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial
planning situations.
•
Experience – Complete 6,000 hours of professional experience related to the personal financial planning process or 4,000
hours of apprenticeship experience that meets additional requirements.
•
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking
Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”),
which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and
maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with the CFP Board’s Code and Standards. This includes a
commitment to the CFP Board, as part of the certification, to act as a fiduciary, and therefore, act
in the best interests of the client, at all times when providing financial advice and financial
planning. CFP Board may sanction a CFP® professional who does not abide by this commitment,
but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar
commitment should obtain a written engagement that includes a fiduciary obligation to the
client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement
process, which could result in suspension or permanent revocation of their CFP® certification.
Check designation status online at www.cfp.net/verify-a-cfp-professional.
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
Robert Heck has no history of any legal or disciplinary events deemed material to a client’s consideration of
Robert Heck to act as their investment adviser representative. FINRA’s BrokerCheck® system and the
Investment Adviser Public Disclosure system provides additional information regarding the registration and
disciplinary history of Robert Heck. Please visit FINRA’s BrokerCheck® system at https://brokercheck.finra.org
or the IAPD system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
Robert Heck does not engage in any other investment-related businesses or occupations deemed material in
your consideration of Robert Heck as your investment advisor representative.
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ITEM 5: ADDITIONAL COMPENSATION
Robert Heck does not receive any economic benefit outside of the salaries and bonuses described in Item 4 of
this brochure or on Form ADV Part 2A Items 10 and 12.
ITEM 6: SUPERVISION
Robert Heck is supervised through a compliance program designed to prevent and detect federal and state
securities law violations. This compliance program is overseen by Martin Juergens, the Chief Compliance Officer
of KJWM. As Chief Compliance Officer, Martin Juergens reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed.
Martin Juergens can be reached at (360) 350-4747 or info@kj-wm.com.
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
TIMOTHY D. HUME
• CRD #: 6901076
• YEAR OF BIRTH: 1965
EDUCATIONAL BACKGROUND:
• 1988: Seattle University; B.S., Civil Engineering
• 1994: University of Washington; M.S., Civil Engineering
BUSINESS BACKGROUND:
• 2018 – Present: Kiley Juergens Wealth Management, LLC; Investment Advisor Representative
• 2023 – 2026: Osaic Wealth, Inc.; Registered Representative
• 2018 – 2023: Royal Alliance Associates, Inc.; Registered Representative
• 2018: Signator Investors, Inc.; Registered Representative
• 1988 – 2018: HDR Engineering, Inc.; Professional Associate
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
Timothy Hume has no history of any legal or disciplinary events deemed material to a client’s consideration of
Timothy Hume to act as their investment adviser representative. FINRA’s BrokerCheck® system and the
Investment Adviser Public Disclosure system provides additional information regarding the registration and
disciplinary history of Timothy Hume. Please visit FINRA’s BrokerCheck® system at https://brokercheck.finra.org
or the IAPD system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
Timothy Hume does not engage in any other investment-related businesses or occupations deemed material in
your consideration of Timothy Hume as your investment advisor representative.
ITEM 5: ADDITIONAL COMPENSATION
Timothy Hume does not receive any economic benefit outside of the salaries and bonuses described in Item 4
of this brochure or on Form ADV Part 2A Items 10 and 12.
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ITEM 6: SUPERVISION
Timothy Hume is supervised through a compliance program designed to prevent and detect federal and state
securities law violations. This compliance program is overseen by Martin Juergens, the Chief Compliance Officer
of KJWM. As Chief Compliance Officer, Martin Juergens reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed.
Martin Juergens can be reached at (360) 350-4747 or info@kj-wm.com.
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ITEM 2 – EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
CARLY SIPE
• CRD #: 7804297
• YEAR OF BIRTH: 1999
EDUCATIONAL BACKGROUND:
• 2021: University of Dayton: BS Mechanical Engineering
BUSINESS BACKGROUND:
• 2023 – Present: Kiley Juergens Wealth Management, LLC; Wealth Advisor
• 2023 – 2026: OSAIC WEALTH, INC.; Registered Representative
• 2022 – 2023: Koha Health; Account Executive
• 2021 – 2022: Sonamation; Data Scrubber
• 2021 –2022: Eimagine and Orr Fellowship: Business Analyst / Orr Fellow
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisers must disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice.
Carly Sipe has no history of any legal or disciplinary events deemed material to a client’s consideration of Carly
Sipe to act as their investment adviser representative. FINRA’s BrokerCheck® system and the Investment
Adviser Public Disclosure system provides additional information regarding the registration and disciplinary
history of Carly Sipe. Please visit FINRA’s BrokerCheck® system at https://brokercheck.finra.org or the IAPD
system at www.adviserinfo.sec.gov for additional information.
ITEM 4: OTHER BUSINESS ACTIVITIES
Disclosure of Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other Financial Industry
Activities and Affiliations.
Carly Sipe does not engage in any other investment-related businesses or occupations deemed material in your
consideration of Carly Sipe as your investment advisor representative.
ITEM 5: ADDITIONAL COMPENSATION
Carly Sipe does not receive any economic benefit outside of the salaries and bonuses described in Item 4 of
this brochure or on Form ADV Part 2A Items 10 and 12.
ITEM 6: SUPERVISION
Carly Sipe is supervised through a compliance program designed to prevent and detect federal and state
securities law violations. This compliance program is overseen by Martin Juergens, the Chief Compliance Officer
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05.2026 | PAGE 45 OF 46
of KJWM. As Chief Compliance Officer, Martin Juergens reviews those policies and procedures annually for their
adequacy and the effectiveness of their implementation. All policies and procedures of the firm are followed.
Martin Juergens can be reached at (360) 350-4747 or info@kj-wm.com
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