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. 1 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. 2 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 3 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 4 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. 5 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 6 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 7 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. 8 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. 10 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 11 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. 12 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 13 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. 14 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 15 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 16 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 17 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 18 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. 19