KINETIC WEALTH INVESTMENT ADVISORS, LLC

Kinetic Wealth Investment Advisors, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Kinetic Wealth Investment Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (440) 250-9500 or by email at: richard.packer@kinetic-wealth.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 Wealth Investment Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Kinetic Wealth Investment Advisors, LLC’s CRD number is: 311536. 28045 Clemens Rd Suite D Westlake, OH 44145 (440) 250-9500 7441 Center Street Mentor, OH 44060 440-534-1875 richard.packer@kinetic-wealth.com https://kinetic-wealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 01/27/2026 i  Item 2: Material Changes The material changes since our last annual updating amendment filing dated February 6, 2024, are described below. • Kinetic Wealth Investment Advisors, LLC has updated its Assets Under Management. (Item 4.E.) • Kinetic Wealth Investment Advisors, LLC has added an outside business activity for Richard Packer. (Item 10) • Kinetic Wealth Investment Advisors, LLC has added secondary office location. (Cover Page) We urge you to carefully review any notice of material amendments to this Disclosure Brochure in the future as it will contain important information that may pertain to, among other things, changes to our advisory services, fee structures, business practices, conflicts of interest, or disciplinary history. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................4 Item 5: Fees and Compensation .............................................................................................................................7 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................10 Item 7: Types of Clients ........................................................................................................................................10 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .............................................................10 Item 9: Disciplinary Information .........................................................................................................................14 Item 10: Other Financial Industry Activities and Affiliations .........................................................................15 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............16 Item 12: Brokerage Practices ................................................................................................................................17 Item 13: Review of Accounts ................................................................................................................................18 Item 14: Client Referrals and Other Compensation ..........................................................................................19 Item 15: Custody ....................................................................................................................................................20 Item 16: Investment Discretion ............................................................................................................................20 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................20 Item 18: Financial Information .............................................................................................................................21 iii  Item 4: Advisory Business A. Description of the Advisory Firm Kinetic Wealth Investment Advisors, LLC (hereinafter “KWIA”) is a Limited Liability Company organized in the State of Ohio. The firm was formed in October 2020, and the principal owner is Richard M. Packer. B. Types of Advisory Services Portfolio Management Services KWIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. KWIA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring KWIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. KWIA will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. KWIA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KWIA’s economic, investment or other financial interests. To meet its fiduciary obligations, KWIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, KWIA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is KWIA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Small Market Solutions (SMS) Program KWIA may direct clients to the Small Market Solutions Program offered by LPL Financial, LLC. Under SMS, LPL Research (a team of investment professionals within LPL) creates and maintains a series of different investment menus (“Investment Menus”) consisting of 4  a mix of different asset classes and investment vehicles (“investment options”) for clients that sponsor and maintain participant-directed defined contribution plans (“Plan Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it believes is appropriate based on the demographics and other characteristics of the Plan and its participants. LPL Research is responsible for the selection and monitoring of the investment options made available through Investment Menus. The investment options that are offered through SMS are limited to the specific investments available through the record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an Investment Menu in its entirety and does not have the option to remove or substitute an investment option. In addition to the services described above, Plan Sponsor may also select from a number of consulting services available under SMS that are provided by KWIA. These consulting services may include, but are not limited to: general education, and support regarding the Plan and the investment options selected by Plan Sponsor; assistance regarding the selection of, and ongoing relationship management for, record keepers and other third-party vendors; Plan participant enrollment support; and participant-level education regarding investment in the Plan. These consulting services do not include any individualized investment advice to the Plan Sponsor or Plan participants with respect to Plan assets. Financial Planning Financial plans and financial planning may include, but are not limited to: retirement planning, education planning, estate planning, cash flow/budget planning, risk management planning, personal wealth planning, tax planning, business planning, investment planning/asset allocation, or such other financial planning or consulting services. The scope of services is determined between KWIA and client and will be outlined in the client financial planning agreement. Consulting Services KWIA provides consulting services to registered investment advisers concerning investment strategies and counseling on financial planning advice to clients of those investment advisers. Our consulting services will be limited to investment strategies involving mutual funds, ETFs and insurance products, when appropriate. Services Limited to Specific Types of Investments KWIA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs and non-U.S. securities, although KWIA primarily recommends U.S. stocks, ETFs, and mutual funds. KWIA 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 5  individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions KWIA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by KWIA on behalf of the client. KWIA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent KWIA from properly servicing the client account, or if the restrictions would require KWIA to deviate from its standard suite of services, KWIA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. KWIA does not participate in wrap fee programs. E. Assets Under Management KWIA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $214,538,913 $0 December 2025 6  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All Assets Up to 2.00% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. The fees charged may be higher or lower than the cost of similar services offered through other registered investment advisors. Clients may be able to obtain similar services for a lesser fee from other advisors. Fees will be charged in advance on a calendar quarterly basis. The initial Account Fee is due at the beginning of the quarter following account inception (account inception is the date a platforms minimum investment has been met) and will include the prorated fee for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. The Account Fee is based on the value of assets in the account, including cash holdings as of the close of business on the last business day of the preceding quarter. Additional deposits and withdrawals will be added or subtracted from portfolio assets on a prorated basis to adjust the Account Fee. Advisory fees for Accounts opened on a day other than the first day of the calendar quarterly period or closed on a day other than the last business day of the calendar quarterly period will be prorated based on the number of days in the quarter. Clients may terminate the agreement without penalty for a full refund of KWIA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Selection of Other Advisers Fees KWIA will receive its standard fee on top of the fee paid to the third party adviser. This relationship will be memorialized in each contract between KWIA and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. Specifically KWIA may direct clients to LPL Financial. These fees are negotiable. 7  Financial Planning Fees Fixed Fees The fixed rate for creating client financial plans is $1,000. This fee is negotiable based upon the complexity of the client’s financial situation and services being provided. Should the cost be greater than estimated, we will notify you prior to completion of the agreed upon services listed above. Our hourly fee thereafter will be $250.00 per hour. Hourly Fees The hourly fee for these services is $250. This fee is negotiable based upon the complexity of the client’s financial situation and services being provided. Clients may terminate the agreement without penalty, for full refund of KWIA’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Consulting Fees Kinetic Wealth is paid on an hourly basis for consulting services to other investment advisers. The hourly rate for these services is $250 per hour. In some instances, Kinetic Wealth may instead be paid a portion of the advisory fee the Investment Adviser client receives from its clients. Kinetic Wealth will continue to receive these fees until the consulting services are terminated. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Selection of Other Advisers Fees Fees for selection of LPL Financial as third-party adviser are withdrawn directly from the client's accounts with client's written authorization. Fees are paid quarterly in advance. Payment of Financial Planning Fees Financial planning fees are paid via check. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. 8  Hourly financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Payment of Consulting Fees Consulting Fees are paid in arrears via check. 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 KWIA. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees KWIA collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. 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 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. E. Outside Compensation For the Sale of Securities to Clients Richard M. Packer is a registered representative of a broker-dealer and an insurance agent and in these roles, accepts compensation for the sale of investment products to KWIA clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, KWIA will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase KWIA-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with KWIA. 9  Commissions are not KWIA’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management KWIA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients KWIA generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Charitable Organizations Corporations or Business Entities Other Investment Advisers There is no account minimum for any of KWIA’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis KWIA’s methods of analysis include Charting analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. KWIA uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. 10  Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies KWIA uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long 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. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Fundamental analysis concentrates on factors that determine a company’s 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. 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, it changes the very cycles these investors are trying to exploit. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more 11  risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, 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. Technical analysis attempts to predict a future stock 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 take into account new patterns that emerge over time. 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 clients 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, and political/regulatory risk. Selection of Other Advisers: Although KWIA will seek to select only money managers who will invest clients' assets with the highest level of integrity, KWIA's selection process cannot ensure that money managers will perform as desired and KWIA will have no control over the day-to-day operations of any of its selected money managers. KWIA would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients 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 other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. 12  Equity investment generally refers to buying shares of stocks 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 and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value 13  in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. 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. 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. 14  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 As a registered representative of LPL Financial, Richard M Packer accepts compensation for the sale of securities. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither KWIA nor its 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 Interests Richard M Packer is a registered representative of LPL Financial and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. KWIA always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of KWIA in such individual’s capacity as a registered representative. Richard M Packer is a licensed insurance agent with LPL Insurance Associates. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of KWIA are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. KWIA addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. KWIA periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. KWIA will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business 15  practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by KWIA’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Richard M Packer is a Member and Manager of North Valley Financial Services LLC, an accounting firm. This firm solicits clients for Kinetic Wealth and receives compensation for this activity. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Kinetic Wealth always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any representative of Kinetic Wealth in such individuals outside capacities D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections KWIA may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay KWIA its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between KWIA and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. KWIA will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. KWIA will ensure that all recommended advisers are licensed or notice filed in the states in which KWIA is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics KWIA 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. KWIA's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests 16  KWIA does not recommend that clients buy or sell any security in which a related person to KWIA or KWIA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of KWIA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of KWIA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. KWIA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of KWIA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of KWIA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, KWIA will never engage in trading that operates to the client’s disadvantage if representatives of KWIA buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on KWIA’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. Clients will not necessarily pay the lowest commission or commission equivalent, and KWIA 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 brokers that may aid in KWIA's research efforts. KWIA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. KWIA will require clients to use LPL Financial (CRD #6413). 17  1. Research and Other Soft-Dollar Benefits KWIA receives no research, product, or services other than execution from broker- dealers or custodians in connection with client securities transactions (“soft dollar benefits”), but does receive additional economic benefits described in Item 14. 2. Brokerage for Client Referrals KWIA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use KWIA will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts KWIA 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 KWIA's advisory services provided on an ongoing basis are reviewed at least annually by Richard M. Packer, Principal, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at KWIA are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Richard M Packer, Principal. Financial planning clients are provided a one- time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). 18  With respect to financial plans, KWIA’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of KWIA's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 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) Our firm may recommend LPL to clients for custody and brokerage services. There is no direct link between our firm’s participation in the program and the investment advice given to clients, although we receive economic benefits through our participation in the program that are typically not available to LPL retail investors. 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 our firm’s participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); 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 to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third party vendors. Some of the products and services made available by LPL through the program may benefit our firm but may not benefit our client accounts. These products or services may assist us in managing and administering client accounts, including accounts not maintained at LPL. Other services made available by LPL are intended to help us manage and further develop our business enterprise. The benefits received by our firm or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to LPL. As part of our fiduciary duties to our clients, we endeavor at all times to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons in and of itself creates a potential conflict of interest and may indirectly influence our firm’s choice of LPL for custody and brokerage services. KWIA may act as a referral agent to, or engage as a co-advisor with, certain third-party asset management firms (TAMPs). In such case, he or she receives compensation from the 19  TAMP either in the form of a referral payment or an advisory fee, and you are provided disclosure about the arrangement and the compensation to be received at the time of the referral or engagement. Your financial advisor may also receive compensation in addition to a referral or advisory fee. For example, some TAMPs pay or reimburse financial advisors for attending conferences or for expenses for workshops, seminars presented to clients or advertising, marketing, or practice management. The eligibility of a financial advisor to receive such payments or reimbursements is often based on the amount of assets referred by the financial advisor to the TAMP. B. Compensation to Non – Advisory Personnel for Client Referrals KWIA may retain third parties to act as solicitors/promoters for KWIA’s investment management services. Compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. KWIA will ensure each solicitor/promoter is properly exempt or registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with the Advisers Act, where applicable. KWIA will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, KWIA will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion KWIA provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, KWIA generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, KWIA’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to KWIA. Item 17: Voting Client Securities (Proxy Voting) 20  KWIA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet KWIA neither requires nor solicits prepayment of more than $1200 in fees per client, 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 KWIA nor its management has any financial condition that is likely to reasonably impair KWIA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years KWIA has not been the subject of a bankruptcy petition in the last ten years. 21