Overview
Assets Under Management: $341 million
Headquarters: PEORIA, AZ
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Educational Seminars
Clients
Total Client Accounts: 2,954
Discretionary Accounts: 2,954
Regulatory Filings
CRD Number: 155676
Filing ID: 1945880
Last Filing Date: 2025-03-25 16:49:00
Website: https://kbc.team
Form ADV Documents
Primary Brochure: KINGDOM PART 2A BROCHURE (2025-09-08)
View Document Text
Item 1 - Cover Page
Kingdom Financial Group, LLC
14155 North 83rd Avenue, Suite 144
Peoria, Arizona 85381
(623) 974-0300
September 8, 2025
This brochure provides information about the qualifications and business practices of Kingdom Financial
Group, LLC. If you have any questions about the contents of this brochure, please contact us at (623) 974-
0300. 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 Kingdom Financial Group, LLC is also available on the Internet at
www.adviserinfo.sec.gov. You can view information on this website by searching for Kingdom Financial
Group, LLC’s name or by using its CRD number: 155676.
*Registration as an investment advisor does not imply a certain level of skill or training.
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Item 2 – Material Changes
The following changes have occurred since our last annual amendment dated March 25, 2025:
• Dustin Meza has replaced Brett Pohl as Chief Compliance Officer
We will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures
within 120 days after our firm’s fiscal year ends. Our firm’s fiscal year ends on December 31, so you will receive
the summary of material changes no later than April 30 each year. At that time, we will also offer or provide a copy
of the most current disclosure brochure. We may also provide other ongoing disclosure information about material
changes as necessary.
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Item 3 – Table of Contents
Item 1 - Cover Page ................................................................................................................................................ 1
Item 2 – Material Changes .................................................................................................................................. 2
Item 3 – Table of Contents .................................................................................................................................. 3
Item 4 – Advisory Business ................................................................................................................................. 5
Ownership ........................................................................................................................................................... 5
General Description of Primary Advisory Services ............................................................................................. 5
Financial Planning Services (Plans and Consulting) ...................................................................................... 5
Use of Third-Party Money Managers .............................................................................................................. 5
Newsletters ..................................................................................................................................................... 5
Seminars and Workshops ............................................................................................................................... 5
Specialization .................................................................................................................................................. 5
Limits Advice to Certain Types of Investments. .............................................................................................. 6
Written Acknowledgement of Fiduciary Status ................................................................................................... 6
Tailor Advisor Services to Individual Needs of Clients ........................................................................................ 6
Wrap-Fee Program versus Portfolio Management Program............................................................................... 6
Client Assets Managed by Advisor ..................................................................................................................... 7
Item 5 – Fees and Compensation ....................................................................................................................... 7
Newsletters ......................................................................................................................................................... 7
Seminars ............................................................................................................................................................. 7
Financial Planning Services ................................................................................................................................ 7
Consultation Services ......................................................................................................................................... 9
Referrals to Third Party Money Managers .......................................................................................................... 9
Additional Compensation .................................................................................................................................. 11
Comparable Services ........................................................................................................................................ 11
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Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 11
Item 7 – Types of Clients .................................................................................................................................. 11
Minimum Investment Amounts Required .......................................................................................................... 11
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis........................... 11
Investment Strategies ....................................................................................................................................... 12
Risk of Loss ....................................................................................................................................................... 12
Item 9 – Disciplinary Information ....................................................................................................................... 14
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 15
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ...................................... 17
Item 12 – Brokerage Practices .......................................................................................................................... 17
Item 13 – Review of Accounts .......................................................................................................................... 17
Account Reviews ............................................................................................................................................... 17
Account Reports ................................................................................................................................................ 18
Item 14 – Client Referrals and Other Compensation ........................................................................................ 18
Client Referrals ................................................................................................................................................. 18
Other Compensation ......................................................................................................................................... 18
Item 15 – Custody ............................................................................................................................................. 19
Item 16 – Investment Discretion........................................................................................................................ 19
Item 17 – Voting Client Proxies ......................................................................................................................... 19
Item 18 – Financial Information ......................................................................................................................... 19
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Item 4 – Advisory Business
Ownership
Kingdom Financial Group, LLC (sometimes referred to as “Advisor” or “we”) are an investment advisor
registered with the United States Securities and Exchange Commission since July 2, 2018. Kingdom
Financial Group, LLC was previously registered at the state level since January 26, 2011. We are an
S Corp formed under the laws of the State of Arizona. The principal owners are Steven D. Fullerton
and Stephanie E. Fullerton. When offering our services, we may use the doing business name IQ
Wealth Advisory, LLC.
General Description of Primary Advisory Services
We offer personalized investment advisory services including financial plans and consultations, seminars,
newsletters, and referrals to third party money managers. The following are brief descriptions of our
primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients
and prospective clients (sometimes referred to as “you”) can review the services and description of fees
more thoroughly.
Financial Planning Services (Plans and Consulting)
Financial planning can be described as helping individuals determine and set their long-term financial
goals through investments, tax planning, asset allocation, risk management, retirement planning and other
areas. The role of a financial planner is to find ways to help clients understand their overall financial
situation and help them set financial objectives.
We provide advisory services in the form of comprehensive and modular financial plans. These
services do not involve the active management of client accounts. Instead, comprehensive planning
services focus on a client’s overall financial situation. Modular planning services focus on specific areas
of client concern and may not take other important issues into consideration.
We also provide consulting services to clients wanting advice on a specific area or concern.
These consultations can last for one meeting or several meetings, depending upon the client’s
needs and requested services.
Use of Third-Party Money Managers
We offer advisory services by referring clients to outside, or unaffiliated, money managers that are
registered or exempt from registration as investment advisors. Third-party money managers are
responsible for continuously monitoring client accounts and making trades to client accounts when
necessary.
Newsletters
We offer informative and educational newsletters to clients on a complementary basis.
Seminars and Workshops
We hold seminars and workshops to educate the public on different types of investments and the different
services we offer. The seminars are educational in nature and no specific investment or individual tax advice
is given. We do not charge a fee for attendance for these seminars.
Specialization
We do not specialize in any of our offered services.
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Limits Advice to Certain Types of Investments.
We limit our investment advice to the following types of investments:
Foreign issues
o Exchange-listed securities
o Securities traded over-the-counter
o
o Warrants
o Corporate debt securities (other than commercial paper)
o Commercial paper
o Certificates of deposit
o Municipal securities
o United States government securities
o Option contracts on securities
o Option contracts on commodities
o Futures contracts on tangibles
o Futures contracts on intangibles
o Variable life insurance
o Variable annuities
o Mutual fund shares
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:
o Meet a professional standard of care when making investment recommendations (give prudent
advice);
o Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
o Avoid misleading statements about conflicts of interest, fees, and investments;
o Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
o Charge no more than is reasonable for our services; and
o Give you basic information about conflicts of interest.
Tailor Advisor Services to Individual Needs of Clients
Our services are always provided based on the specific needs of the individual client. Clients are given
the ability to impose restrictions on their accounts, including specific investment selections and sectors.
However, we will not enter into an investment advisor relationship with anyone whose investment
objectives may be considered incompatible with our investment philosophy or strategies or where the
prospective client seeks to impose unduly restrictive investment guidelines.
Wrap-Fee Program versus Portfolio Management Program
In traditional management programs, advisory services are provided for a fee, but transaction services
are billed separately on a per-transaction basis. A wrap fee program is a program under which the client
pays a single fee that covers both receipt of investment advice and the execution of securities
transactions. We serve as portfolio manager to a wrap fee program sponsored by AEWM, which is also
available to our clients. In the AEWM program, the advisory fee paid by the client includes custody,
trades, management expertise and reporting in a bundled format. A client's total cost of each of the
services provided through wrap fee programs could be different if purchased separately. Cost factors may
include the client's ability to:
1. Obtain the services provided within the programs separately from any of the mutual fund sponsors,
2. Invest and rebalance the selected mutual funds without the payment of a transaction charge, and
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3. Obtain performance reporting comparable to those provided within each program.
When comparing costs, the combination of multiple mutual fund investments, advisory services, custodial
and brokerage services available through each program may not be available separately. Clients may be
required to have multiple accounts, sign numerous documents and incur various fees. If an account is not
actively traded or the client qualifies for reduced sales charges, the fees in these programs may be more
expensive than if utilized separately.
We believe the charges and fees offered within each fee-based program are competitive and reasonable
when compared to alternative programs available through other firms and/or investment sources.
However, we make no guarantee that the aggregate cost of a particular program is lower than that which
may be available elsewhere.
If you participate in a third-party wrap program, it will be on a discretionary basis. The strategies
implemented are based on clients' individual investment objectives. For complete details regarding the
AE Wealth wrap fee program, please refer to the AE Wealth Wrap Fee Program Brochure (Form ADV,
Part 2A Appendix) which can be found by accessing AE Wealth’s Disclosure Documents at
https://aewealthmanagement.com/disclosures. All other disclosure documentation made available by AE
Wealth will be available there as well.
Client Assets Managed by Advisor
As of December 31, 2024, the firm has a total of $340,595,756 in discretionary assets under
management. The firm did not have any non-discretionary assets under management.
Item 5 – Fees and Compensation
In addition to the information provided in Item 4, Advisory Business, this section provides details
regarding our services along with descriptions of each service’s fees and compensation arrangements.
Newsletters
We offer monthly and/or quarterly newsletters to clients at no charge. These newsletters are delivered
by both U.S. mail and e-mail and are informational and educational in nature. No specific investment
advice or recommendations are given. Prospective clients can also request to receive the newsletters.
Seminars
We offer seminars that are educational and informational in nature. No specific investment advice
or recommendations are given to participants. There is no charge to attend these seminars.
Financial Planning Services
We offer comprehensive and modular financial planning services. Comprehensive services can
include, but are not limited to:
o Personal planning (family records, budgets, personal liability, etc.)
Cash flow and management
o
o Retirement planning
o Business planning
o Estate planning
o Education planning
o Tax planning
o Risk management
o
Insurance analysis
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Investment analysis
o
o Benefit plans
o Disability and long-term care
o
Stock option analysis
You can also elect to focus on a more specific area of concern. However, focusing on one or more
specific areas may not take other important issues into consideration that could impact our analysis and
recommendations as well as your objectives.
Our investment advisor representatives (referred to as “representatives”) meet with you to gather the
information and documents needed to perform an analysis and review of your situation as well as your
objectives and goals. One or more meetings may be needed to gather all needed information and
determine the services best suited to help meet your needs. We rely on the information you provide to
us. Therefore, it is very important that the information you provide is complete and accurate. We are
not responsible for verifying the information you supply.
Our services do not include legal or tax advice. You are urged to work closely with an
attorney, accountant, or other professionals regarding your financial and personal situation.
Our estate planning service representative has restricted access to client information and
only requires limited client information to perform the services unless contracted separately to
do so.
After gathering the needed information and documents, our representatives do a suitability analysis.
This means they look at your willingness and ability to take on certain levels of risk when making an
investment or using one or more types of investment products or asset allocation strategies. We
want your investments to work both sensibly and prudently toward your financial goals and
objectives.
Once the suitability study is completed, our representatives then forward all information to AE Wealth
Management (AEWM) an unaffiliated investment adviser registered with the Securities and Exchange
Commission1. We may also send them suggestions about suitable areas of investment recommendations
or allocations. AEWM prepares the requested analysis and then sends it back to us. We review it,
present it to you in either an oral or a written format and discuss the analyses and recommendations with
you. You will generally receive the plan within one week once we have received all the required
information and documentation from you.
If you request a comprehensive plan, it will focus on your overall financial situation and cover several or
all the areas previously noted, as may be needed by you. If you request a modular (segmented) plan, it
will focus only on one or more specific area(s) of concern to you. If you request a modular (segmented)
plan, you should be aware that other important issues may not be taken into consideration when
developing the analyses and recommendations.
If you also elect to contract with us for advisory services provided through referrals to third party money
managers, there is no charge for the requested financial plan. However, if you do not also contract to
create a referred account, then there is a fixed fee charged for the requested plan that ranges from $250
to $5,000. The fixed fee is negotiable based upon the actual services you request us to provide and the
complexity of your personal and financial situation. There is a retainer due at the time you sign the
agreement for services equal to one-quarter (25%) of the quoted fixed fee. The remainder of the fee is
due at the time we present the plan to you. We provide you with a detailed billing invoice.
You have sole discretion about whether or not to contract for our services. In addition, you have sole
discretion about whether or not to implement any financial planning recommendations made by our
representatives. If you do decide to implement the recommendations, you are responsible for taking
any actions or implementing any transactions required. You are free to select any broker/dealer and/or
insurance agent to implement our recommendations. You should be aware that some of our
representatives may also be independently licensed insurance agents. If you elect to follow our
1 Registration does not imply a certain level of skill or training.
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recommendations regarding insurance products and select one of our representatives to implement the
recommendations, he or she could receive commissions. This is a potential conflict of interest since the
representative could earn advisory fees in his or her capacity as an investment advisor representative
and could also earn commissions on insurance products sold in his or her capacity as an independently
licensed insurance agent. Please see Item 10, Other Financial Activities and Affiliations, for
additional discussion on this conflict of interest.
Either you or we can terminate advisory services at any time by providing written notice to the other party.
Termination is effective upon receiving that notice. If services are terminated within five business days of
signing the client agreement, we will return all your prepaid fees. If services are terminated after five
business days have passed but before presentation of the plan, we will retain all your prepaid fees.
Depending upon the percentage of the plan that has already been prepared at the time of termination, you
may also owe additional, prorated fees. We will send you a billing invoice detailing the fees charged and
any amounts that may be due. No fees will be refunded after the plan has been presented.
Consultation Services
You can also request advice on one or more specific areas of concern, and these consultations can be a
one-time event or involve several meetings. If you also elect to contract with us for advisory services
provided through referrals to third party money managers, there is no charge for the requested
consultations. However, if you do not also contract to create a referred account, then there is an hourly
charge for these consultations of $250 per hour. This rate is negotiable based upon the actual services
you ask us to provide and the complexity of your situation. We will provide you with an estimate of the
time we believe will be needed to complete the requested services. If the time needed exceeds our
estimate, we will request permission from you to continue. You have the final determination when the
consultations are completed. There is a retainer due at the time you sign the agreement for services.
This retainer is equal to two hours of time at the quoted hourly rate. The remainder of the fee is due at
the time the consultations are completed. We provide you with a detailed billing invoice.
You have sole discretion about whether or not to contract for our services. In addition, you have sole
discretion about whether or not to implement any recommendations made or advice given by our
representatives. If you do decide to implement, you are responsible for taking any actions or
implementing any transactions required. You are free to select any broker/dealer and/or insurance agent
to implement our recommendations and advice. You should be aware that some of our representatives
may also be independently licensed insurance agents. If you elect to follow our recommendations
regarding insurance products and select one of our representatives to implement the recommendations,
he or she could receive commissions. This is a potential conflict of interest since the representative
could earn advisory fees in his or her capacity as an investment advisor representative and could also
earn commissions on insurance products sold in his or her capacity as an independently licensed
insurance agent. Please see Item 10, Other Financial Activities and Affiliations, for additional
discussion on this conflict of interest.
Services terminate upon completion of the investment consultations contracted for. Either you or we
can terminate advisory services at any time by providing written notice to the other party. Termination is
effective upon receiving that notice. If services are terminated within five business days of signing the
client agreement, we will return all your prepaid fees. If services are terminated after five business days
have passed but before estimated time of completion, we will retain all your prepaid fees and additional
fees may be due depending upon the additional time spent on the consultations. We will send you a
billing invoice detailing the fees charged and any amounts that may be due.
Referrals to Third Party Money Managers
We act as solicitor and refer clients to unaffiliated third-party investment advisors offering asset
management and other investment advisory services. We perform due diligence when selecting the
third-party money managers recommended. Each solicitation arrangement is performed pursuant to a
written solicitation agreement and is in compliance with SEC Rule 206(4)-3 and applicable state
securities rules and regulations.
Through this service, we assist you in identifying your risk tolerance and investment objectives and then
9
recommend money managers relative to those objectives and tolerances. You select a recommended
third-party investment advisor based on your needs and enter into an agreement directly with the selected
advisor. That advisor provides the asset management services. Advisor’s representatives are available
to answer questions regarding your account. Our representatives also act as the communication conduit
between you and the third-party investment advisor selected. At least annually, we contact you to see if
you have any changes to your instructions, account restrictions, investment goals, financial
circumstances, or investment limitations/risk tolerances.
Third party managed programs generally have account minimum requirements and these minimum
requirements vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts. A complete description of the third-party
investment advisor’s services, fee schedules and account minimums are disclosed in the third-party
investment advisor’s Disclosure Brochure that is provided to you at the time you sign an agreement for
services and establish an account. The type and frequency of reports you receive will also depend on
the third-party investment advisor you select.
Third-party investment advisers may take discretionary authority to determine the securities to be
purchased and sold for your account. We have discretionary authority and are responsible for
selecting investments or implementing trades in your accounts.
When we refer you to a third-party money manager, we receive a portion of the fee (a
solicitor/referral fee) charged and collected by the third-party investment advisor. The actual fee
charged to you varies depending on the third-party investment advisor selected. However, the
third-party money manager takes our solicitor/referral fee into consideration when determining
the total fee it charges you. The third- party money manager also considers other factors when
determining the fee, such as the amount of assets you have under management and the number
of your accounts. You do not pay us directly for referring you to the third-party money manager.
All fees are calculated and collected by the selected third-party investment advisor and that
investment advisor is responsible for paying us our portion of the total fee charged to you.
You may incur additional charges including but not limited to, mutual fund sales loads, 12b-1 fees and
surrender charges and IRA and qualified retirement plan fees. We do not receive any portion of such
commissions or fees. We are only compensated by the solicitor/referral fees described above, and do
not receive any other compensation in connection with your account.
As stated in Item 4, Kingdom utilizes a Sub-Advisor to assist with back-office / operations functions. This
relationship includes certain economic benefits. Kingdom obtains investment research for its own model
portfolios, technology, account billing, trading, and client service support through its Sub-Advisor
contracts. Based upon the total client assets under management that Kingdom brings to a Sub-Advisor,
Kingdom is provided with certain additional economic benefit for doing so. With specific regard to
AEWM, Kingdom may receive various services from other investment managers retained or otherwise
made available by the Sub-Advisor and the cost of such services may be paid by the Sub-Advisor, thus
creating an incentive for Kingdom to use the Sub-Advisor.
Services provided through AEWM’s managed account program are offered through a wrap fee program.
Through the wrap fee program, you will only pay fees based on assets under management and you will
not pay a separate commission, ticket charge, or custodian fee, for the execution of transactions in your
account. AEWM and our firm will receive a portion of the fee as compensation for services.
Any third-party investment advisers we recommended must be registered or exempt from registration in
the state where you reside. Our representatives may have a conflict of interest by only offering those
third-party investment advisors that have agreed to pay us a portion of their advisory fee. There may be
other third-party managed programs that may be suitable to you and that may be more or less costly.
No guarantees can be made that your financial goals or objectives will be achieved. Further, no
guarantees of performance can be offered. Investments involve risk, including the possible loss of
principal.
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Additional Compensation
Our representatives may also be independently licensed insurance agents and sell insurance products to
any client. They can earn commissions when selling these products. This is a potential conflict
because they may recommend the purchase of an insurance product resulting in a commission being
paid to them in addition to advisory fees being paid to us.
Comparable Services
We believe our fees for advisory services are reasonable with respect to the services provided and the
fees charged by other investment advisors offering similar services. However, lower fees for
comparable services may be available from other sources.
Item 6 – Performance-Based Fees and Side-By-Side Management
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. We do not receive performance-based fees.
Item 7 – Types of Clients
We generally provide investment advice to the following types of clients.
o
Individuals including high net worth individuals
Minimum Investment Amounts Required
If you contract for financial planning and/or consultation services without also contracting for referrals to
third party money manager services, you are charged a fee. For financial plans, there is a minimum
fee of $250. For consultations, there is a minimum 2-hour charge at the quoted rate.
We also require clients to have a minimum of $25,000 to establish an account when they are referred to a
third-party money manager. However, we may grant an exception to this minimum, considering your
specific needs, our current relationship with you and anticipated future services or accounts.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Advisors generally use one or more of the following methods of analysis when considering a client’s
situation and developing recommendations:
o Charting: a technical analysis that charts the pattern of stocks, bonds, and commodities
to help determine buy and sell recommendations. Analysts using charting believe that
recurring patterns of trading can help them forecast future price movements.
o Fundamental: a method of evaluating stocks based on fundamental factors such as
revenues, earnings, future growth, return on equity, profit margin, etc. to determine a
company’s underlying value and potential for future growth.
o Technical: a method of evaluating securities by analyzing a stock’s market activity—
generally the price and volume. Technical analysts use charts or computer programs to
identify and project price trends. Most analysis is done on a short or intermediate term, but
some analysts also predict long- term cycles based on charts or other data. Technical
analysis is not concerned with the financial position of a company.
o Cyclical: an analysis of recurring periods of expansion and contraction that can impact a
company’s profitability and cash flow. Cyclical stocks tend to rise quickly when the economy
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turns up and fall quickly when the economy turns down (i.e., housing, automobiles,
telecommunications, paper, etc.) Non-cyclical industries (i.e., food, insurance, drugs,
health care, etc.) are not as directly impacted by economic changes.
We do not use any specific method of analysis when analyzing a client’s financial situation. Rather,
we outsource our financial planning services to AE Wealth Management (AEWM) and rely on their
research and analytical methods when developing recommendations. In addition, we refer clients to
AE Wealth Management (AEWM) and rely on them for asset management services and investment
product selection.
Investment Strategies
Advisors generally use one or more of the following investment strategies when implementing investment
advice to clients:
o Long term purchases (investments held at least a year)
o Short term purchases (investments sold within a year)
o Trading (investments sold within 30 days)
o Short sales (borrowing securities in anticipation of a price decline and returning an equal
number of securities at some future time)
o Margin transactions (Investor pays for part of the purchase and borrows the rest from a
brokerage firm, e.g., investor buys $5,000 worth of stock in a margin account by paying for
$2,500 and borrowing $2500 from a brokerage firm. Clients cannot borrow stock from
Advisor)
o Option writing (including covered options, uncovered options or spreading strategies)
(Note: options are contracts giving the purchaser the right to buy or sell a security,
such as stocks, at a fixed price within a specific period of time)
Non-Traded securities / Private placements
Under certain circumstances, we may recommend an allocation to select private placements or other
non-traded investment vehicles (vehicles), where the investments inside the vehicle are managed by a
third-party. The third-party manager may charge fees which are discrete from those agreed to
between the client and Kingdom Financial. Furthermore, the private placement or non-traded
investment vehicle may have little to no liquidity such that an investor may be required to maintain
their investment until such time that the manager of the investment liquidates the fund/vehicle and
returns capital to investors. These types of investments may not be suitable for all clients.
Risk of Loss
Investing in securities involves a risk of loss that you should be prepared to bear, including the loss of
your original principal. You should also be aware that past performance of any security is not
necessarily indicative of future results. Therefore, do not assume that future performance of any specific
investment or investment strategy will be profitable. We do not provide any representation or guarantee
that client goals will be achieved.
Investing in securities involves risk of loss. Further, depending on the different types of
investments, there may be varying degrees of risk:
o Risk of Loss. Securities investments are not guaranteed, and clients may lose money on
investments. As with any investment , our investment recommendations are subject to
market risk—the possibility that security prices will decline over short or extended periods
of time. As a result, the value of client accounts will fluctuate with the market, and clients
could lose money over short or long periods of time. Clients should recognize whenever
they determine to invest in the securities markets, the entire investment is at risk. Clients
should not invest money if they are unable to bear the risk of total loss of their
investments.
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o Economic Risk. The prevailing economic environment is important to the health of all
businesses and security markets. Some companies, however, are more sensitive to
changes in the domestic or global economy than others. These types of companies are
often referred to as cyclical businesses. Countries in which a large portion of businesses
are in cyclical industries are thus also very economically sensitive and carry a higher
amount of economic risk. If an security issuer is located in a country that experiences
wide economic swings, or in situations where certain elements of an investment
instrument interact with such countries, the investment instrument will generally be
subject to a higher level of economic risk.
o Financial Risk. Financial risk represents internal disruptions within an investment or the
issuer that can lead to unfavorable performance of the investment. Examples of financial
risk can be found in cases like Enron or many of the “dot com” companies that had weak
balance sheets despite initial strong market performance..
o Market Risk. The value of a client’s portfolio may decrease if the value of an individual
company or multiple companies in the portfolio decreases. Further, regardless of how well
individual companies perform, the value of a client’s portfolio could also decrease if there
are deteriorating economic or market conditions. It is important to understand that the value
of clients’ investments may fall, potentially sharply, in response to changes in the market,
and clients could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g., earnings disappointment or
downgrade in the rating of a bond) or general market risk (e.g., such as a “bear” market
when stock values fall in general). For fixed-income securities, a period of rising interest
rates could cause security prices to fall. .
o Political & Regulatory Risks – Investments may be subject to risks resulting from a particular
political party or regulatory agency. For example, Exploration and Production companies may
face additional government and or regulatory oversight that either restricts their ability to develop
resources or makes the future development of resources uneconomical.
o Equity (Stock) Market Risk. Common stocks are susceptible to fluctuations and to volatile
increases/decreases in value as their issuers’ confidence in or perceptions of the market
change. Investors holding common stock (or common stock equivalents) of any issuer
are generally exposed to greater risk than if they hold preferred stock or debt obligations
of the issuer.
o Company Risk. There is always a certain level of company or industry specific risk when
investing in stock positions. This is referred to as unsystematic risk and can be reduced
through appropriate diversification. There is the risk that a company may perform poorly or
that its value may be reduced based on factors specific to it or its industry (e.g., employee
strike, unfavorable media attention).
o Options Risk. Options on securities may be subject to greater fluctuations in value than
investing in the underlying securities. Purchasing and writing put or call options (the right
to sell or buy a specified amount of an underlying asset at a set price within a set time)
are highly specialized activities and involve greater than ordinary investment risk.
o Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the
bond and be unable to make payments. In addition, individuals depending on set amounts
of periodically paid income face the risk that inflation will erode their spending power.
Fixed-income investors receive set, regular payments that face the same inflation risk.
o ETF and Mutual Fund Risk. ETF and mutual fund investments bear additional
expenses based on a pro-rata share of operating expenses, including potential
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duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities held by the ETF or mutual fund.
Clients also incur brokerage costs when purchasing ETFs.
o Management Risk. Client investments also vary with the success and failure of
Advisor’s investment strategies, research, analysis, and determination of portfolio
securities. If Advisor’s strategies do not produce the expected returns, the value of a
client’s investments will decrease.
o Cybersecurity Risk. Kingdom Financial’s information and technology systems could
become vulnerable to damage or interruption from computer viruses, network failures,
computer and telecommunication failures, infiltrations by unauthorized persons and
security breaches, spyware, usage errors by its professionals, power outages and
catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes.
Although Kingdom Financial has implemented various measures to manage these
risks, including, but not limited to, creating redundant systems at all times, if these
systems are compromised, become inoperable for extended periods of time, or cease
to function properly, Kingdom Financial could potentially have to make a significant
investment to fix or replace them. The failure of these systems and/or disaster
recovery plans for any reason could cause significant interruptions in our operations
and result in a failure to maintain the security, confidentiality, or privacy of sensitive
data, including personal information relating to clients. Such a failure could harm
Kingdom Financial’s reputation or subject us to legal claims and otherwise affect our
business and financial performance. Kingdom Financial has taken steps to mitigate
these risks by retaining the services of cybersecurity specialists who are experts at
monitoring, managing, and mitigating the risks of cyberattacks. This monitoring is
implemented seven days a week, 24 hours a day and 365 days a year.
o Liquidity Risk. Privately held real estate, private equity investments, individual fixed
income securities, thinly- traded equity securities, non-traded securities, and other
alternative investment products often entail accepting liquidity risk. Liquidity risk is the
inability to liquidate/exit an investment and/or liquidation in a timely manner without
potentially incurring a significant monetary penalty in order to access their funds.
Past performance is not a guarantee of future returns. Investing in securities and other
investments involve a risk of loss that each Client should understand and be willing to bear.
Clients are reminded to discuss these risks with the Advisor.
Item 9 – Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's
evaluation of our advisory business or the integrity of our management.
On June 20, 2024, while neither admitting or denying the findings of fact and conclusions of law, Kingdom
Financial entered into a consent order with the Securities Division of the Arizona Corporation Commission settling
an administrative action . In this matter, the Arizona Corporation Commission found that Kingdom Financial
violated A.R.S. § 44-3201(A)(6). In particular, the Arizona Corporation Commission found that Kingdom Financial
had 3 investment adviser representatives (IAR’s), that were formally licensed as IAR’s prior to joining Kingdom
Financial, performed investment advisory services while their IAR application for Kingdom Financial was pending.
Kingdom Financial consented to cease and desist from committing or causing future violations, to an
administrative penalty of $3,000.Our firm and our management personnel have no reportable legal or disciplinary
events to disclose.
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Item 10 – Other Financial Industry Activities and Affiliations
We do not have a related person that is:
o A broker/dealer, municipal securities dealer or government securities dealer or broker
o An investment company or other pooled investment vehicle (including a mutual fund,
closed-end investment company, unit investment trust, private investment company or
“hedge fund,” and offshore fund)
o A investment adviser or financial planner
o A futures commission merchant, commodity pool operator or commodity trading
advisor
A pension consultant
o A banking or thrift institution
o A lawyer or law firm Accountant or accounting firm
o
o A real estate broker or dealer
o A sponsor or syndicator of limited partnerships.
Stephanie Elaine Fullerton is a Shareholder of Fullerton Financial Planning 401k Plan, a defined benefit
pension plan. Stephanie Elaine Fullerton is a Shareholder of Financial planning for Seniors, Inc. DBA
Fullerton Financial Planning, a financial planning company utilizing the DBA of Fullerton Financial Planning.
Kingdom uses Artificial Intelligence to assist with some back-office operations of the Firm. Kingdom uses an
AI platform to assist with note taking. This AI platform will transcribe and summarize meeting notes for
record-keeping and documentation purposes when added to a Firm online meeting.
Kingdom Financial has an affiliated tax preparation service, Fullerton Tax Prep, which Kingdom may refer
clients to for their tax preparation requirements. Any fees for the tax preparation service provided by
Fullerton Tax Prep will be in addition to the fees that are being charged for its advisory services. As a
Kingdom Financial client, you are not required to use Fullerton Tax Prep and are free to use any tax
preparation service.
Insurance Products Sales
Our representatives can sell other products or provide services outside of their role as investment adviser
representatives with us. Due to the firm’s financial planning philosophy, it is common for our financial professionals
to recommend that clients utilize insurance products (for example, a fixed index annuity (“FIA”)) as part of the
client’s overall financial plan in lieu of separately managed accounts (specifically, in lieu of cash and fixed income
asset classes).You should be aware that there are a number of conflicts of interests that are present due to our
planning philosophy and recommendations to utilize insurance products in this nature.
As an estimate, our financial professionals that are registered as investment advisor representatives spend
approximately 50% of their time on insurance sales and services and 50% of their time on investment advisory
services. Please refer to Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other
Compensation for more details.
You may therefore work with your financial professional in both their capacity as an investment adviser
representative of Kingdom Financial Group, as well as in their capacity as an insurance agent. As such, your
Kingdom Financial Group financial professional, in their dual capacity as an IAR and insurance agent, may advise
you to purchase insurance products (general disability insurance, life insurance, annuities, and other insurance
products to you), and then assist you in implementing the recommendations by selling you those same products.
When acting as an insurance agent, in exchange for selling you those products, the financial professional will
typically be paid a commission. This recommendation that a client purchase an insurance product through them as
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an insurance agent presents a conflict of interest, as the receipt of commissions is an incentive to recommend
products that could potentially be based on commissions rather than your personal needs and objectives.
Furthermore, commissions may vary by product, and each individual product may have different commission rates,
encouraging the financial professional to recommend products that may pay higher commissions over the products
that make the most sense for you.
In addition, insurance products may also have different payment schedules depending on the nature of the
product, and the timing of the payments likely differ from that of the advisory options offered by Kingdom Financial
Group. This timing difference has the potential to create a conflict of interest since some financial professionals
may have the incentive to recommend a product that pays commissions now, over an advisory product that pays
fees over a relatively longer period. As an example, all other variables held equal, a 5% commission paid by an
insurance company upon sale of a $100,000 annuity product, may be more attractive to a financial professional
than a one percent (1%) advisory fee charged on a $100,000 account paid over a period of five (5) years, despite
the overall pre-tax compensation paid to the financial professional being equal.
There could be other conflicts present as well. Kingdom Financial Group utilizes the services of Advisors Excel, a
third-party insurance marketing organization ("IMO") to select the appropriate product for our clients. The purpose
of the IMO is to assist us in finding the insurance product that best fits the client’s situation, although the IMO and
insurance carrier may also offer special bonus or incentive compensation to our firm and our investment adviser
representatives when they act in their separate capacities as insurance agents when they meet certain overall
sales goals by placing annuities and/or other insurance products through the IMO. This could create a conflict of
interest for Kingdom Financial Group and our financial professionals to utilize the products recommended by the
IMO.
In addition, each of the individual insurance carriers that our financial professionals work with may also separately
provide incentive-based bonuses or awards in exchange for sales-related production over specific periods of time,
which is a conflict of interest. They may also provide indirect compensation by providing marketing assistance,
business development tools, technology, back office/operations support, business succession planning, business
conferences, and incentive trips. These incentive programs do not directly affect fees paid by the client. Although
some of these services can benefit a client, other services obtained by our IARs such as marketing assistance,
business development, and incentive trips, will not benefit an existing client and is a conflict of interest.
At times, our financial professionals receive expense reimbursement for travel and/or marketing expenses from
distributors of investment and/or insurance products. Travel expense reimbursements are a result of attendance at
due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements
are the result of informal expense sharing arrangements in which product sponsors will underwrite costs incurred
for marketing, such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt
of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product
sponsor reimbursements are made by those sponsors for which sales have been made or for which it is
anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain
products and investments based on the receipt of this compensation instead of what is in the best interest of
clients.
Advisors Excel is also a related company of AE Wealth Management. Advisors Excel provides affiliate members
such as our firm, Kingdom Financial Group, with marketing assistance and business development tools to acquire
new clients, technology with the goal of improving the client experience and our firm’s efficiency, back office and
operations support to assist in the processing of our insurance (through Advisors Excel) and investment advisory
services (through AE Wealth Management) for clients, and business succession planning for our firm. Although
some of these services may directly benefit a client, other services obtained by us from Advisors Excel such as
marketing assistance and business development may not benefit an existing client. There could be a conflict of
interest when we use the sub- adviser and financial planning services of AE Wealth Management because we may
be influenced to use AE Wealth Management based upon our relationship and services provided and support of
Advisors Excel.
We have taken a number of steps to manage these types of conflict of interests. We attempt to control for these
sales-related conflicts by always basing investment decisions on the individual needs of clients. As a fiduciary, we
expect and require that each investment adviser representative only recommend insurance and annuities when in
the best interest of the client. If you have any questions or concerns about annuity recommendations made during
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the financial planning process, we encourage you to immediately bring it to the attention either the Compliance
Officer or the CCO.
Finally, you should be aware that there are other insurance products that are offered by other insurance agents
other than those recommended by our financial professionals. You are under no obligation to implement any
insurance or annuity transaction through Kingdom Financial Group.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
According to the Investment Advisers Act of 1940, an investment advisor is considered a fiduciary. As a
fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts.
In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each
of its clients. Both we and our representatives have a fiduciary duty to all clients. We have established
a Code of Ethics which all associated persons must read. They must then execute an acknowledgment
stating that they understand and agree to comply with our Code of Ethics. Our fiduciary duty to clients and
the fiduciary duty of our representatives to clients are considered the core underlying principle for our
Code of Ethics and represent the expected basis for all dealings with clients. We have the responsibility
to make sure that the interests of clients are placed ahead of us or our associated persons’ own
investment interests. All associated persons will conduct business in an honest, ethical, and fair manner.
All associated persons will always comply with all federal and state securities laws. Full disclosure of all
material facts and potential conflicts of interest will be provided to clients prior to services being
conducted.
All associated persons have a responsibility to avoid circumstances that might negatively affect or appear
to affect their duty of complete loyalty to clients. This section is only intended to provide current clients
and potential clients with a description of our Code of Ethics. If current clients or potential clients wish to
review our Code of Ethics in its entirety, a copy may be requested from any of our associated persons
and a copy will be provided promptly.
We do not recommend investment products. However, both we and our representatives may buy or sell
investment products for our personal accounts. Some of these products may be identical to products
recommended by AE Wealth Management (AEWM) or Sterling Capital when we refer clients to that
investment adviser as a result of the existing solicitor arrangement or as a result of outsourcing our
financial planning services to that investment advisor. We do not buy or sell securities for our personal
accounts where our decision is derived, in whole or in part, by information obtained as a result of our
employment unless the information is also available to the investing public upon reasonable inquiry. We
are now and will continue to be in compliance with The Insider Trading and Securities Fraud Enforcement
Act of 1988.
Item 12 – Brokerage Practices
We refer clients to AE Wealth Management, LLC for their asset management services and do not receive
a solicitor/referral fee as a result of this relationship. We do not receive any research, soft dollar benefits
or any other products or services from AE Wealth Management, LLC. Clients are not obligated to
establish an account with AE Wealth Management, LLC and are free to select any broker/dealer or
investment advisor to implement their securities and investment transactions.
Item 13 – Review of Accounts
Account Reviews
Financial planning and consulting accounts terminate upon presentation of the plan or completion of the
consultation. However, we recommend that you have your financial situation reviewed and updated at
least yearly. If you wish to undertake a review and update, a new client agreement will be required, and
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additional fees may be charged.
Accounts at third party money managers are reviewed at least quarterly, usually when we receive copies
of statements from the money manager. Our representatives conduct reviews on their own accounts.
Although the calendar is the main triggering factor, account reviews are also conducted due to:
o Client request
o Change in client circumstances, account holdings or investment objectives
o Unusual economic conditions
o Changes in geopolitical environment.
Absent specific client instruction, accounts are reviewed to be sure portfolio holdings are accurate,
investment products are still suitable and account performance continues to work toward the client’s goals
and objectives.
Account Reports
Financial planning clients do not receive any reports other than the financial plan originally contracted for.
Clients with accounts at third party money managers receive statements from the account custodian at
least quarterly. We do not provide any additional position reports, performance reports or account
statements.
Item 14 – Client Referrals and Other Compensation
Client Referrals
Kingdom Financial has entered into agreements with various parties (Referring Parties) to refer clients to
Kingdom Financial. If a referred client enters into an investment advisory agreement with Kingdom
Financial, a cash referral fee is paid to the referring party, which is based upon a percentage of the client
advisory fees that are generated. The referral agreements between any referring party and Kingdom
Financial will not result in any charges to clients in addition to the normal level of advisory fees charged.
When a client is referred to us by a referring party, the referring party provides the client with a copy of
our Firm Brochure as required by the Investment Advisers Act of 1940. The client will also complete a
Solicitor’s Disclosure Statement document. If the referring party is an unaffiliated registered
investment adviser firm, then the client will also receive a copy of the referring party’s Form ADV Part 2
Firm Brochure. If a referred client enters into an investment advisory agreement with Kingdom Financial,
a referral fee is paid to the referring party. The referral relationship will not result in clients being charged
any fees over and above the normal advisory fees charged for the advisory services provided.
The referral agreements between Kingdom Financial and referring parties are in compliance with state
and federal securities rules regarding paid solicitor arrangements.
Other Compensation
As disclosed under the "Fees and Compensation" section in this Brochure, our financial professionals
providing investment advice on behalf of our firm are licensed insurance agents and earn commission
based compensation for selling insurance products. In addition, these persons receive certain benefits
from AEWM, including sales awards and trips, based on the volume of insurance business referred to
Advisors Excel, an affiliate of AEWM. Our representatives who are licensed insurance agents also
receive certain benefits from insurance carriers.
These practices present conflicts of interest because our representatives who are licensed insurance
agents have an incentive to recommend insurance products, as well as insurance products through
specific carriers, to you based on the receipt of these benefits. For information on how we address the
conflicts associated with the sale of insurance products, please refer to the "Fees and Compensation"
and "Other Financial Industry Activities and Affiliations" sections of this Brochure. For additional
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discussion on other compensation either we or our representatives receive, please refer to Additional
Compensation under Item 5, Fees and Compensation, and Item 10, Other Financial Industry Activities
and Affiliations.
Item 15 – Custody
Custody has been defined as having access or control over client funds and/or securities but does not
include the ability to execute transactions in client accounts. Custody is not limited to physically holding
client funds and securities. If an investment advisor has the ability to access or control client funds or
securities, the investment advisor is deemed to have custody for purposes of the Investment Advisers Act
of 1940 and must ensure proper procedures are implemented. Our procedures do not result in our
maintaining custody of client funds and securities.
Although we do not have custody, we have established procedures to ensure all client funds and
securities are held at a qualified custodian in a separate account for each client under that client’s name.
Clients or an independent representative of the client direct, in writing, the establishment of all accounts
and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or
securities are maintained. Finally, account statements are delivered directly from the qualified custodian
to each client, or the client’s independent representative, at least quarterly. Clients should carefully
review those statements. When clients have questions about their account statements, they should
contact us or the qualified custodian preparing the statement.
Item 16 – Investment Discretion
We provide asset management services and any other advisory services on a discretionary basis. Prior to
accepting discretionary authority over a Client’s account, Client executes and Investment Advisory Agreement,
naming KFG as Client’s attorney in fact, granting KFG full authority to execute buy, sell, or otherwise effect
securities transactions in Client’s name in Client’s discretionary account. KFG may accept any reasonable
limitation or restriction to such authority on the account placed by Client. All limitations and restrictions must be
provided to KFG in writing.
Item 17 – Voting Client Proxies
We do not vote proxies or accept proxy materials on behalf of clients. All proxy materials are sent
directly to clients from the product sponsor, custodian, or transfer agent. Clients have the ultimate
responsibility for making all proxy-voting decisions.
Item 18 – Financial Information
This item is not applicable to our brochure. We do not require or solicit prepayment of more than $1,200
in fees per client, six months or more in advance. Therefore, we are not required to include a balance
sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely
to impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of
a bankruptcy petition at any time.
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