KINETIC INVESTMENT MANAGEMENT, INC.

KINETIC INVESTMENT MANAGEMENT, INC. 633 W. 5TH STREET, SUITE 1050 LOS ANGELES, CA 90017 (800) 711-4818 INFO@KINETICINVESTMENT.COM WWW.KINETICINVESTMENT.COM Firm Brochure Form ADV Part 2A This brochure provides information about the qualifications and business practices of Kinetic Investment Management, Inc. If you have any questions about the contents of this brochure, please contact us at (800) 711- 4818 or by email at: info@KineticInvestment.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Kinetic Investment Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Kinetic Investment Management, Inc.’s CRD number is: 283034. Kinetic Investment Management, Inc. is a registered investment adviser. Registration does not imply a certain level of skill or training. Revision Date: September 10, 2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Kinetic Investment Management, Inc. on 03/10/2025 are described below. Material changes relate to Kinetic Investment Management, Inc.’s policies, practices or conflicts of interests. • Kinetic Investment Management, Inc. updated Item 9.B. to remove reference to a previous disciplinary disclosure. • Gary Joseph Preisser Jr. is no longer associated with Kinetic Investment Management, Inc. (Item 10.C) • Kinetic Investment Management, Inc. updated Item 10.C. to add reference to possible conflicts of interest. ii  Item 3: Table of Contents Item 2: Material Changes ....................................................................................................................................... ii Item 3:Table of Contents ...................................................................................................................................... iii Item 4:Advisory Business ..................................................................................................................................... 5 A. Description of the Advisory Firm .................................................................................................................. 5 B. Types of Advisory Services .......................................................................................................................... 5 Portfolio Management Services ..................................................................................................................... 5 Sub-Advisory Investment Management Services............................................................................................ 5 Financial Planning ........................................................................................................................................ 6 Educational seminars/workshops ................................................................................................................... 6 Services Limited to Specific Types of Investments ........................................................................................ 6 Written Acknowledgement of Fiduciary Status .............................................................................................. 6 C. Client Tailored Services and Client Imposed Restrictions .............................................................................. 7 D. Wrap Fee Programs ..................................................................................................................................... 7 E. Assets Under Management ........................................................................................................................... 7 Item 5: Fees and Compensation ............................................................................................................................ 7 A. Fee Schedule ............................................................................................................................................... 8 Portfolio Management Fees ........................................................................................................................... 8 Sub-Advisory Fees ....................................................................................................................................... 8 Financial Planning Fees ................................................................................................................................ 8 B. Payment of Fees ......................................................................................................................................... 11 Payment of Portfolio Management Fees....................................................................................................... 11 Payment of Sub-Advisory Fees ................................................................................................................... 11 Payment of Financial Planning Fees ............................................................................................................ 11 C. Client Responsibility for Third-Party Fees .................................................................................................. 11 D. Prepayment of Fees.................................................................................................................................... 11 E. Outside Compensation for the Sale of Securities to Clients .......................................................................... 12 Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................... 12 Item 7: Types of Clients ..................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................... 13 A. Methods of Analysis and Investment Strategies .......................................................................................... 13 Methods of Analysis ................................................................................................................................... 13 Investment Strategies .................................................................................................................................. 13 Investing in securities involves a risk of loss that you, as a client, should be prepared to bear......................... 13 B. Material Risks Involved ............................................................................................................................. 13 Methods of Analysis ................................................................................................................................... 13 Investment Strategies .................................................................................................................................. 14 Investing in securities involves a risk of loss that you, as a client, should be prepared to bear......................... 14 3  C. Risks of Specific Securities Utilized ........................................................................................................... 14 Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear ................................................................................................................ 15 Item 9: Disciplinary Information ......................................................................................................................... 15 A. Criminal or Civil Actions ........................................................................................................................... 15 B. Administrative Proceedings ........................................................................................................................ 15 C. Self-Regulatory Organization (SRO) Proceedings ....................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations ............................................................................... 15 A. Registration as a Broker-Dealer or Broker-Dealer Representative ................................................................ 15 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor .......................................................................................................................................................... 16 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ................. 16 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ........ 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................. 16 A. Code of Ethics ........................................................................................................................................... 16 B. Recommendations Involving Material Financial Interests ............................................................................ 17 C. Investing Personal Money in the Same Securities as Clients ........................................................................ 17 D. Trading Securities At/Around the Same Time as Clients’ Securities ............................................................. 17 Item 12: Brokerage Practices .............................................................................................................................. 17 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................................ 17 1. Research and Other Soft-Dollar Benefits .............................................................................................. 18 2. Brokerage for Client Referrals ............................................................................................................. 18 3. Clients Directing Which Broker-Dealer/Custodian to Use ............................................................................18 B. Aggregating (Block) Trading for Multiple Client Accounts ......................................................................... 18 Item 13: Review of Accounts .............................................................................................................................. 18 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................... 18 B. Factors That Will Trigger a Non-Periodic Review of Client ......................................................................... 18 C. Content and Frequency of Regular Reports Provided to Clients ................................................................... 18 Item 14: Client Referrals and Other Compensation .............................................................................................. 19 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .................................................................................................................................................. 19 B. Compensation to Non–Advisory Personnel for Client Referrals ................................................................... 19 Item 15: Custody ................................................................................................................................................ 19 Item 16: Investment Discretion ........................................................................................................................... 19 Item 17: Voting Client Securities (Proxy Voting) ..........................................................................................................20 Item 18: Financial Information ........................................................................................................................... 20 A. Balance Sheet ............................................................................................................................................ 20 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ........20 C. Bankruptcy Petitions in Previous Ten Years ................................................................................................ 20 4  Item 4: Advisory Business A. Description of the Advisory Firm Kinetic Investment Management, Inc. (hereinafter “Kinetic Investment Management”) is a corporation organized in the State of California. The firm was formed in January 2016, and the principal owner is Ali Hashemian. B. Types of Advisory Services Portfolio Management Services Kinetic Investment Management offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. We create an Investment Policy Statement for you which outlines your current situation (income and risk tolerance levels) and then we construct a plan to aid in the selection of a portfolio that matches your specific situation. Portfolio management services include but are not limited to the following: Investment strategy • • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring We evaluate your current investments with respect to your risk tolerance level and time horizon. We will request discretionary authority from you to select securities and execute transactions without permission from you prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement which is given to each client. We seek to provide investment decisions that are made in accordance with the fiduciary duties owed to our clients’ accounts and without consideration of our economic, investment, or other financial interests. To meet our fiduciary obligations, we attempt to avoid, among other things, investment or trading practices that systematically advantage or disadvantage individual client portfolios. Thus accordingly, our policy is to seek fair and equitable allocation of investment opportunities/transactions among our clients to avoid favoring one client over another. It is our policy to allocate investment opportunities and transactions we identify as being appropriate and prudent among our clients on a fair and equitable basis. We may direct our clients to third-party investment advisers. Before selecting other investment advisers for clients, we will verify that all recommended advisers are properly licensed, notice filed or exempt in the states where we are recommending the adviser. Sub-Advisory Investment Management Services Kinetic Investment Management provides sub-advisory investment management services to unaffiliated registered investment advisers, RIA firms. Unaffiliated RIA firms may access third-party investment advisers through us for investment management of some or all their clients’ assets. 5  We provide back-office services including but not limited to processing investment management requests and processing custodial relationship applications for the RIA firms in return for fees deducted from the advisor fee. The advisor fee is itemized on the third-party adviser’s platform on the statement of investment selection. Kinetic Investment Management is shown as the adviser/sub-adviser. Financial Planning include but are not limited to investment planning, tax planning, retirement Financial plans may planning, insurance planning, business consulting, and estate planning. Investment planning includes but is not limited to risk management, portfolio performance, asset allocation, and diversification. Tax planning includes but is not limited to tax forecasting, tax efficiency, and tax-advantaged strategies. Retirement planning includes but is not limited to income/distribution maximization, budgeting, inflation, and taxes. Insurance planning includes but is not limited to life insurance, long-term care insurance, health insurance, car insurance, and homeowner’s insurance. Estate planning includes but is not limited to trust strategies, incorporation strategies, and charitable/gifting strategies. Financial planning services are offered to all our clients, and it is anticipated that each of these services will take approximately 2-4 hours of planning. The final fee structure for these services is based on hourly rates and is documented in Exhibit II of the Financial Planning Agreement. Educational seminars/workshops Kinetic Investment Management may provide educational seminars/workshops/presentations for free to ongoing or prospective clients. These services include presentations to individuals or groups about various aspects of wealth management. These seminars/workshops/presentations will be offered on an ad hoc basis. We do not charge for these educational seminars/workshops/ presentations. Services Limited to Specific Types of Investments We generally limit our investment advice to equity investments, fixed income investments, exchange traded fund (ETF) investments, real estate investments, commodities investments, international investments, and mutual fund investments. We may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give 6  • • • • • prudent advice). Never put our financial interests ahead of yours when making recommendations (give loyal advice). Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we give advice that is in your best interest. Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions Kinetic Investment Management will tailor a program for each client. This will include an interview session to get to know your specific needs and requirements as well as a plan that will be executed by us on your behalf. We may use “model portfolios” together with a specific set of recommendations for you based on your personal restrictions, needs, and targets. In addition to risk tolerance, we will use other quantitative factors such as investment goals, time horizon, lifestyle needs, retirement plans, and legacy concerns. We will also look at your entire portfolio (even the portions not managed by us) to align your risk tolerance in aggregate. You may impose restrictions on investing in certain securities or types of securities in accordance with your values or beliefs. However, if the restrictions prevent us from properly servicing your account or if the restrictions require us to deviate from our standard suite of services, we reserve the right to terminate the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where you pay one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Kinetic Investment Management may recommend various third-party money managers that manage a wrap fee program. E. Assets Under Management As of December 31, 2024, Kinetic Investment Management had $348,218,341 in assets under management, of which $312,064,335 in assets under management we manage on a discretionary basis, and $36,154,006 in assets under management on a non-discretionary basis. Additionally, Kinetic Investment Management had $53,847,811 in assets under administration. While we provide administrative services, we are not currently providing continuous investment management services regarding these assets under administration. Consequently, we have total assets of $402,066,152. Item 5: Fees and Compensation Lower fees for comparable services may be available from other sources. A. Fee Schedule Portfolio Management Fees These fees are negotiable depending upon your needs and the complexity of the situation. The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Lower fees for comparable 7  services may be available from other sources. You may terminate the agreement without penalty for a full refund of our fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract upon written notice. Kinetic Investment Management may direct clients to third-party investment advisers. All fees are collected by the third-party investment advisers and are then shared with Kinetic Investment Management who receives its fee paid directly from the third-party adviser. The notice of termination requirement and payment of fees for third-party investment advisers will depend on the specific third- party advisers selected. Sub-Advisory Fees Kinetic Investment Management receives pre-negotiated fees from advisors for providing back-office investment management services and access to third-party investment advisers. Our fees are deducted from the advisor fee. The advisor fee is itemized on the third-party adviser’s platform on the statement of investment selection. Kinetic Investment Management is shown as the adviser/sub-adviser. Financial Planning Fees The negotiated fixed rate for creating a financial plan for a client is between $1,000 and $10,000. Fixed fees relate to financial plans and financial planning that may include without limitation: investment planning, tax planning, retirement planning, insurance planning, and estate planning. Fixed Fees Tier one - $1,000 Client Services • • • Annual meetings Review performance of accounts held at Kinetic Investment Management Portfolio allocation change recommendations Written Reports • • Progress report for accounts held at Kinetic Investment Management Quarterly account statements Tier Two - $3,000 Client Services • • • • Annual meetings Review performance of accounts held at Kinetic Investment Management Portfolio allocation change recommendations Information on new and different options available 8  Written Reports • • • Progress report for accounts held at Kinetic Investment Management Quarterly account statements Asset allocation analysis and recommendations Tier Three - $5,000 Client Services • • • • • Annual meetings Review performance of accounts held at Kinetic Investment Management Portfolio allocation change recommendations Information on new and different options available Insurance and protection planning analysis and recommendations Written Reports • • • • Progress report for accounts held at Kinetic Investment Management Quarterly account statements Asset allocation analysis and recommendations Financial goals analysis and current strategy comparison Tier Four - $8,000 Client Services • • • • • • • Quarterly meetings Review performance of all investment accounts Portfolio allocation change recommendations Information on new and different options available Insurance and protection planning analysis and recommendations Employer sponsored retirement plan review Unlimited access to advice via phone and email Written Reports • • • • • Progress report for all accounts Quarterly account statements Asset allocation analysis and recommendations Financial goals analysis and current strategy comparison Financial status including net worth and cash flow analysis Tier Five - $10,000 Client Services • • Quarterly meetings Review performance of all investment accounts 9  • • • • • • • Portfolio allocation change recommendations Information on new and different products available Insurance and protection planning analysis and recommendations Employer sponsored retirement plan review Discuss economic and market conditions Tax planning analysis and recommendations Unlimited access to advice via phone and email Written Reports • • • • • • • Progress report for all accounts Quarterly account statements Asset allocation analysis and recommendations Financial goals analysis and current strategy comparison Financial status including net worth and cash flow analysis Estate planning and analysis Charitable planning It is anticipated that each financial planning service listed above will take approximately 2-4 hours of financial planning and therefore the time to complete a financial plan will depend on the services required by the client. For example, the financial plan for a client requiring investment planning, retirement planning, and insurance planning will usually require 6-12 hours. The fees are negotiable, and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Kinetic Investment Management and you will ultimately determine the negotiated fixed fee depending on the specific financial planning services that you require, the need to consider dependents or other individuals, the diversity of your assets to be addressed by the financial plan, and conversations with the you. Fixed fees are offered to all clients. You may terminate the agreement without penalty for a full refund of our fees within five business days of signing the Financial Planning Agreement. Thereafter, you may terminate the Financial Planning Agreement upon written notice. We will not take an excess of $1,200 per client or six months or more in advance (whichever is lower) with the remainder due upon presentation of the plan. Hourly Fees The negotiated hourly fee for these services is between $100 and $500. You may terminate the agreement without penalty for a full refund of our fees within five business days of signing the Financial Planning Agreement. Thereafter, you may terminate the Financial Planning Agreement upon written notice. We will not take an excess of $1,200 per client or six months or more in advance (whichever is lower) with the remainder due upon presentation of the plan. B. Payment of Fees Payment of Portfolio Management Fees Advisory fees are paid monthly or quarterly in advance. Fees are normally withdrawn directly from your accounts with written authorization from you but may instead be invoiced and billed directly at 10  your election. The timing, frequency, and method of paying fees for the elected third-party managers will depend on the specific third-party adviser selected and will be disclosed to you prior to your entering into a relationship with the third-party adviser. For advisory fees that are paid quarterly in advance, we use the value of the account as of the last business day of the prior billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. For advisory fees that are paid monthly in advance, we use the value of the account as of the last business day of the prior billing period, prorated for account opening and closing, for purposes of determining the market value of the assets upon which the advisory fee is based. Payment of Sub-Advisory Fees Sub-Advisory fees are paid monthly or quarterly in advance or monthly in arrears. The timing, frequency, and method of paying fees for the elected third-party managers will depend on the specific third- party adviser selected and will be disclosed to the client prior to entering into a relationship with the third-party adviser. All fees are collected by the third-party investment advisers and are then shared with us. After we receive our negotiated fee, we will then pay the RIA firm the remainder of the advisory fee. Payment of Financial Planning Fees Financial planning fees are paid via check. Fixed financial planning fees are paid in advance, and we will not take an excess of $1,200 per client and six months or more in advance (whichever is lower) with the remainder due upon presentation of the plan. Hourly financial planning fees are paid in advance, and we will not take an excess of $1,200 per client and six months or more in advance (whichever is lower) with the remainder due upon presentation of the plan. C. Client Responsibility for Third-Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by us. Please see Item 12 of this brochure regarding broker-dealer/custodian information. D. Prepayment of Fees Kinetic Investment Management collects some fees in advance. Refunds for fees paid in advance will be processed within fourteen (14) days to you via check or return deposit back into your account(s), however, in some circumstances that may be out of our control, it can take up to thirty (30) days. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate times the number of days elapsed in the billing period up to and including the day of termination. The daily rate is calculated by dividing the annual asset-based fee rate by the number of days in that calendar year. Fixed fees that are collected in advance will be refunded based on the prorated amount of work 11  completed at the point of termination. Hourly fees that are collected in advance will be refunded based on the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed at the point of termination. E. Outside Compensation for the Sale of Securities to Clients Supervised persons of Kinetic Investment Management receive commissions for the sale of insurance products to our clients via Kinetic Financial & Insurance Solutions, Inc. Commissions from insurance products are a significant source of compensation and are paid in addition to advisory fees. When determining the asset based advisory fees, the assets that are allocated into the insurance products are not subject to the advisory fee. You should be aware that receipt of commissions presents a conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Kinetic Investment Management always acts in your best interest; including the sale of commissionable products to advisory clients. You are in no way required to implement a recommended plan through any representative of ours in their capacity as a licensed insurance agent. You always have the option to purchase recommended products through other brokers or agents that are not affiliated with Kinetic Financial & Insurance Solutions, Inc. Please see additional disclosures about this conflict in Item 10C of this brochure. Item 6: Performance-Based Fees and Side-By-Side Management Kinetic Investment Management does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation on the assets of a client. Item 7: Types of Clients We generally provide advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Pension and Profit-Sharing Plans ❖ Business Entities There is no account minimum for any of our services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies 12  Methods of Analysis Kinetic Investment Management’s methods of analysis include but are not limited to technical analysis, fundamental analysis, quantitative analysis, qualitative analysis, charting analysis, and cyclical analysis. Technical analysis involves the analysis of past market data to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial data to search for patterns used to help predict favorable conditions for buying and/or selling a security. Quantitative analysis involves the analysis of mathematical measurements and statistical modeling to search for patterns used to help predict favorable conditions for buying and/or selling a security. Qualitative analysis involves the analysis of non-measurable data to search for patterns used to help predict favorable conditions for buying and/or selling a security. Charting analysis involves the analysis of performance charts to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to search for patterns used to help predict favorable conditions for buying and/or selling a security. Investment Strategies Kinetic Investment Management may recommend unusually risky investments to clients, in that we consider any investment that has a high possibility (not probability) of losing some if not all principal as a “risky” investment. Typical examples of these risky investments are non-traded REITs and Oil & Gas Master Limited Partnerships. There are times when you will be invested in a risky investment for the potential of higher gains on a fraction of your assets depending on your overall portfolio of assets. We primarily use long-term trading. Investing in securities involves a risk of loss that you, as the client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Technical analysis attempts to predict price or direction based on market trends. The assumption is that the market follows discernible patterns, and if these patterns can be identified, then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not account for new patterns that emerge over time. Fundamental analysis concentrates on factors that determine a company’s financial value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis focuses on mathematical and statistical modeling. The risk involved in these models 13  includes the fact that performance may be different than expected due to the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Qualitative analysis implements the analysis of non-numeric information. The risk involved in using this type of analysis is the fact that there is no financial or mathematical data used and, by nature, this type of analysis is more subjective. Charting analysis involves using and comparing various charts to predict long-term and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Investment Strategies Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long- term investment strategy can expose you to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, geopolitical risk, currency risk, and regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized You should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any government agency. Equity investments generally refer to buying shares of company stock in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions, the general economic environment, and other risks not mentioned here. Fixed income investments generally refer to a loan in return for receiving a periodic income which is paid at regular intervals and at reasonably predictive levels. The value of fixed income securities may fluctuate in response to interest rates, credit/default risk, inflation, call risk, and other risks not mentioned here. Exchange Traded Fund (ETF) investments generally refer to a marketable security that tracks an index or a basket of securities (equities, fixed income, commodities, etc.). The value of exchange traded funds may fluctuate in response to market conditions, underlying holdings, the general economic environment, and other risks not mentioned here. Real estate investments generally refer to assets tied to physical properties and/or land. The value of real estate investments may fluctuate in response to local property values, interest rates available on 14  loans, natural disasters, socioeconomic conditions, and other risks not mentioned here. Commodities investments generally refer to tangible assets used to manufacture and produce goods or services. The value of commodity prices may fluctuate in response to disease, storage capacity, supply/demand, delivery constraints, weather, and other risks not mentioned here. International investments generally refer to allocations concentrated outside the United States of America. The value of international investments may fluctuate in response to exchange rates, government regulation, geopolitical risk, differences in accounting procedures, and other risks not mentioned here. Mutual Fund investments generally refer to a marketable security of a pooled investment that includes various underlying holdings (equities, fixed income, real estate, commodities, international, etc.). The value of mutual funds may fluctuate in response to market conditions, underlying holdings, the general economic environment, and other risks not mentioned here. Past performance is not indicative of future results. Investing in securities involves a risk of loss that the client should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or Broker-Dealer Representative Neither Kinetic Investment Management nor our representatives are registered as, or have pending applications to become a broker-dealer or a representative of a broker-dealer. 15  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Kinetic Investment Management nor our representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interest Certain individuals of Kinetic Investment Management are also licensed insurance agents. From time to time, these individuals will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. We always act in your best interest; including the sale of commissionable products to advisory clients. You are in no way required to implement any recommendations through any of our representatives in their capacity as a licensed insurance agent. Mark Biggs, Jamale Carothers and Jackson Sowell are accountants. From time to time, they will offer clients advice or products from this activity. Kinetic Investment Management, Inc. always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of Kinetic Investment Management, Inc. in their capacity as accountants. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Kinetic Investment Management may direct clients to third-party investment advisers. You will pay us our standard fee in addition to the standard fee for the third-party investment advisers to which we direct those clients. We always act in your best interest, including when determining which third-party investment adviser to recommend to you. We will verify that all recommended advisers are properly licensed, notice filed or exempt in the states where we are recommending the adviser to you. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Kinetic Investment Management has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Kinetic Investment Management's Code of Ethics is available free upon request to any client or prospective client. 16  B. Recommendations Involving Material Financial Interests Kinetic Investment Management does not make recommendations to clients to buy or sell any security in which a related person to us has a material financial interest. C. Investing Personal Money in the Same Securities as Clients Representatives of Kinetic Investment Management may buy or sell securities for themselves that they may also recommend to you. This may provide an opportunity for our representatives to buy or sell the same securities before or after recommending the same securities to clients, resulting in the representatives profiting off the recommendations they provided to clients. Such transactions may create a conflict of interest. We will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates your disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities Representatives of Kinetic Investment Management may buy or sell securities for themselves at or around the same time as you. This may provide an opportunity for our representatives to buy or sell securities before or after recommending securities to clients, resulting in the representatives profiting from the recommendations they provided to clients. Such transactions may create a conflict of interest. We will never engage in trading that operates to your disadvantage if our representatives buy or sell securities at or around the same time as you. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Custodians/broker-dealers will be recommended based on Kinetic Investment Management’s duty to seek “best execution” (which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances). You will not necessarily pay the lowest commission or commission equivalent. We may also consider the market expertise and research access provided by the broker-dealer/custodian (including but not limited to access to written research, oral communication with analysts, admittance to research conferences, and other resources provided by the broker-dealer/custodian that may aid in our research efforts). We will never charge a premium or commission on transactions beyond the actual cost imposed by the broker-dealer/custodian. We will recommend that clients use Fidelity Investments. 1. Research and Other Soft-Dollar Benefits Kinetic Investment Management receives no research, product, or services other than execution from broker-dealers or custodians in connection with client securities transactions (“soft dollar benefits”). 17  2. Brokerage for Client Referrals Kinetic Investment Management receives no referrals from a broker-dealer, custodian, or third- party in exchange for using that broker-dealer, custodian, or third-party. 3. Clients Directing Which Broker-Dealer/Custodian to Use Kinetic Investment Management will require clients to use a specific custodian to execute transactions. Not all advisers require clients to use a particular custodian. B. Aggregating (Block) Trading for Multiple Client Accounts Kinetic Investment Management does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices (particularly for illiquid securities or during volatile market conditions). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for Kinetic Investment Management's advisory services are managed by third-party advisers and are continually monitored on a macro basis. We additionally review your accounts individually, at least annually, with regards to your respective investment policies and risk tolerance level. B. Factors That Will Trigger a Non-Periodic Review of Client Reviews may be triggered by material market, economic, social, or political events or by changes to your financial situations (such as retirement, termination of employment, physical move, inheritance, divorce, disability, etc.). With respect to financial plans, our services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of Kinetic Investment Management's advisory services will receive a quarterly report detailing the client’s account (including asset allocation, asset value, account registration, calculation of fees, and transaction history). This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 18  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Kinetic Investment Management does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our clients. B. Compensation to Non–Advisory Personnel for Client Referrals Kinetic Investment Management does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at the client's custodian, Kinetic Investment Management will be deemed to have limited custody of client's assets and will: A. Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. B. Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account and verify that the qualified custodian sends invoices to the client. You will receive all account statements directly from the custodian and you are urged to carefully review those statements for accuracy. Item 16: Investment Discretion Kinetic Investment Management provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where we do not have discretionary authority to place trade orders, we will secure client permission prior to effecting securities transactions for your account. Clients with discretionary accounts will execute a limited power of attorney to evidence discretionary authority. When investment discretion has been granted, we generally manage your account and makes investment decisions without consultation with the you as to when the securities are to be bought/sold for the account, the total amount of the securities to be bought/sold, what securities to buy/sell, or the price per share. In some instances, our discretionary authority in making these determinations may be limited by conditions you impose. We will also have discretionary authority to determine the custodian to be used for the purchase or sale of securities for your account. 19  Item 17: Voting Client Securities (Proxy Voting) Kinetic Investment Management will neither ask for nor accept voting authority for client securities. You will receive proxies directly from the issuer of the security or the custodian. You should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet Kinetic Investment Management neither requires nor solicits prepayment of more than $1,200 in fees per client or six months or more in advance, and, therefore, is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Kinetic Investment Management nor our management has any financial condition that is likely to reasonably impair our management’s ability to meet contractual commitments to our clients. C. Bankruptcy Petitions in Previous Ten Years Kinetic Investment Management has not been the subject of a bankruptcy petition in the last ten years. 20