Kmg Fiduciary Partners, LLC

Disclosure Brochure March 19, 2026 KMG FIDUCIARY PARTNERS, LLC a Registered Investment Adviser 7530 Kings Pointe Road Toledo, OH 43617 (419) 517-8040 www.kmgfiduciarypartners.com This brochure provides information about the qualifications and business practices of KMG Fiduciary Partners, LLC (hereinafter “KMG Fiduciary Partners” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.  Disclosure Brochure KMG Fiduciary Partners, LLC Item 2. Material Changes In this Item, KMG Fiduciary Partners is required to discuss any material changes that have been made to the brochure since the last annual amendment on March 4, 2025. The Firm has no changes to disclose in relation to this Item. Page | 2 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 3. Table of Contents Item 2. Material Changes .............................................................................................................................................. 2 Item 3. Table of Contents ............................................................................................................................................. 3 Item 4. Advisory Business ............................................................................................................................................ 4 Item 5. Fees and Compensation .................................................................................................................................... 7 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................ 9 Item 7. Types of Clients ............................................................................................................................................... 9 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 9 Item 9. Disciplinary Information ................................................................................................................................ 11 Item 10. Other Financial Industry Activities and Affiliations .................................................................................... 11 Item 11. Code of Ethics .............................................................................................................................................. 12 Item 12. Brokerage Practices ...................................................................................................................................... 13 Item 13. Review of Accounts ..................................................................................................................................... 16 Item 14. Client Referrals and Other Compensation .................................................................................................... 16 Item 15. Custody......................................................................................................................................................... 17 Item 16. Investment Discretion ................................................................................................................................... 17 Item 17. Voting Client Securities ............................................................................................................................... 18 Item 18. Financial Information ................................................................................................................................... 18 Page | 3 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 4. Advisory Business KMG Fiduciary Partners offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to KMG Fiduciary Partners rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with KMG Fiduciary Partners setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). KMG Fiduciary Partners filed for registration as an investment adviser in August 2018 and is owned by David Kaser, Richard Kaser, and Aaron Mechling as of September 21, 2018. As of January 30, 206, KMG Fiduciary Partners had $1,672,631,724 assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of KMG Fiduciary Partners, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on KMG Fiduciary Partners’ behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services KMG Fiduciary Partners offers clients a broad range of financial planning and consulting services, which includes any or all of the following functions: Retirement Planning Business Planning • • Risk Management Cash Flow Forecasting • • Charitable Giving Trust and Estate Planning • • Distribution Planning Financial Reporting • • Tax Planning Investment Consulting • • Insurance Planning • Manager Due Diligence • These services are rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, KMG Fiduciary Partners is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. KMG Fiduciary Partners recommends certain clients engage the Firm for additional related services and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage KMG Fiduciary Partners or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and Page | 4 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC are under no obligation to act upon any of the recommendations made by KMG Fiduciary Partners under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising KMG Fiduciary Partners’ recommendations and/or services. Wealth Management Services KMG Fiduciary Partners provides clients with wealth management services which includes a broad range of comprehensive financial planning and consulting services as well as discretionary management of investment portfolios. The Firm will agree to provide non-discretionary management services in limited circumstances. KMG Fiduciary Partners primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with their stated investment objectives. The Firm also recommends independent investment managers (“Independent Managers”). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage KMG Fiduciary Partners to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, KMG Fiduciary Partners directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. KMG Fiduciary Partners tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. KMG Fiduciary Partners consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify KMG Fiduciary Partners if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if KMG Fiduciary Partners determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, KMG Fiduciary Partners selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That Page | 5 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. KMG Fiduciary Partners evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. KMG Fiduciary Partners also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. KMG Fiduciary Partners continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. KMG Fiduciary Partners seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Retirement Plan Consulting Services KMG Fiduciary Partners provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: Plan Fee and Cost Analysis Plan Design and Strategy • • Plan Committee Consultation Plan Review and Evaluation • • Fiduciary and Compliance Executive Planning & Benefits • • Participant Education Investment Selection • • As disclosed in the Advisory Agreement, certain of the foregoing services are provided by KMG Fiduciary Partners as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of KMG Fiduciary Partners’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Page | 6 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 5. Fees and Compensation KMG Fiduciary Partners offers services for a fee based upon assets under management. This management fee varies in accordance with the following fee schedule: PORTFOLIO VALUE BASE FEE Up to $249,999 $250,000 - $499,999 $500,000 - $1,999,999 $2,000,000 - $4,999,999 $5,000,000 and Above 1.50% 1.25% 1.00% 0.75% 0.50% The annual fee is prorated and charged monthly, in arrears, based upon the average daily balance of the assets being managed by KMG Fiduciary Partners during that month. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. The Firm offsets fees charged by Independent Managers, if any from its annual fee. The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm may, in its sole discretion, not include cash in determining the fee, especially where a client has a high percentage of cash for reasons other than the Firm's investment management decision. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), KMG Fiduciary Partners may negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage KMG Fiduciary Partners for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Retirement Plan Consulting Fees Each retirement plan consulting engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary based on the scope of the services to be rendered including the amount of assets to be managed. Fee Discretion KMG Fiduciary Partners may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of Page | 7 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. Additional Fees and Expenses In addition to the advisory fees paid to KMG Fiduciary Partners, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length in Item 12, below. Direct Fee Debit Clients provide KMG Fiduciary Partners and certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to KMG Fiduciary Partners. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to KMG Fiduciary Partners’ right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to KMG Fiduciary Partners, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long- term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. KMG Fiduciary Partners may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page | 8 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 6. Performance-Based Fees and Side-by-Side Management KMG Fiduciary Partners does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients KMG Fiduciary Partners offers services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and business entities. Minimum Account Requirements KMG Fiduciary Partners does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship. Certain Independent Managers may, however, impose more restrictive account requirements and billing practices from the Firm. In these instances, KMG Fiduciary Partners may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies KMG Fiduciary Partners adheres to a long-term investment strategy built upon a financial planning approach. KMG Fiduciary Partners utilizes a strategic investment approach with a tactical overlay to manage client portfolios. The Firm uses a top down approach by first determining the proper asset allocation based upon the goals and objectives for each client. KMG Fiduciary Partners then uses a bottom up approach to select the individual investments that are in the Firm’s investment universe and then build and manage portfolios. KMG Fiduciary Partners seeks to reduce risk through asset allocation and diversification. KMG Fiduciary Partners believes that it can best control yield, manage tax consequences and reduce expenses by investing in individual equities and individual bonds when appropriate. Individual equities and individual bonds may be subject to additional business, management and other unforeseeable risks. In cases where KMG Fiduciary Partners believes it cannot achieve proper diversification within an asset category or that investing in individual companies or individual bonds would expose the portfolio to excess business risk, the Firm then utilizes low cost ETFs or institutional mutual funds to build its portfolios. Page | 9 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC The KMG Fiduciary Partners Investment Committee meets at least twice per year to review the firm’s investment policy guidelines. KMG Fiduciary Partners utilizes publications as well as independent third party research to analyze investments and to evaluate the tactical component of its portfolio management. Risk of Loss Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of KMG Fiduciary Partners’ recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that KMG Fiduciary Partners will be able to predict those price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Page | 10 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, KMG Fiduciary Partners selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, KMG Fiduciary Partners continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, KMG Fiduciary Partners does not have the ability to supervise the Independent Managers on a day-to-day basis Currency Risks An advisory account that holds investments denominated in currencies other than the currency in which the advisory account is denominated may be adversely affected by the volatility of currency exchange rates. Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Item 9. Disciplinary Information KMG Fiduciary Partners has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. The Firm does not have any other financial industry activities or affiliations that need to be disclosed. Page | 11 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 11. Code of Ethics KMG Fiduciary Partners has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. KMG Fiduciary Partners’ Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of KMG Fiduciary Partners’ personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients may contact KMG Fiduciary Partners to request a copy of its Code of Ethics. Page | 12 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions KMG Fiduciary Partners recommends that clients utilize the custody, brokerage and clearing services of National Financial Services LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity”) and Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab” and together with Fidelity “Custodian”) for investment management accounts. The final decision to custody assets with Custodian is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. KMG Fiduciary Partners is independently owned and operated and not affiliated with Custodian. Custodian provides KMG Fiduciary Partners with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which KMG Fiduciary Partners considers in recommending Custodian or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Custodian enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Custodian may be higher or lower than those charged by other Financial Institutions. The commissions paid by KMG Fiduciary Partners’ clients to Custodian comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where KMG Fiduciary Partners determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. KMG Fiduciary Partners seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services which assist KMG Fiduciary Partners in its investment decision-making process. Such research will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because KMG Fiduciary Partners does not have to produce or pay for the products or services. KMG Fiduciary Partners periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Page | 13 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Software and Support Provided by Financial Institutions KMG Fiduciary Partners receives without cost from Custodian administrative support, computer software, related systems support, as well as other third party support as further described below (together "Support") which allow KMG Fiduciary Partners to better monitor client accounts maintained at Custodian and otherwise conduct its business. KMG Fiduciary Partners receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Custodian. The Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The Support benefits KMG Fiduciary Partners, but not its clients directly. Clients should be aware that KMG Fiduciary Partners’ receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits may influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, KMG Fiduciary Partners endeavors at all times to put the interests of its clients first and has determined that the recommendation of Custodian is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, KMG Fiduciary Partners receives the following benefits from Custodian: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. Custodian also makes available to the Firm, at no additional charge, certain research, brokerage and other services from Custodian. This includes research services obtained by Custodian directly from independent research companies, as selected by KMG Fiduciary Partners (within specified parameters), as well as other services including marketing support, compliance support and other business support. The research and brokerage services are used by the Firm to manage accounts for which it has investment discretion. Without the Custodian arrangement, the Firm might be compelled to purchase the same or similar services at its own expense. Brokerage for Client Referrals KMG Fiduciary Partners does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct KMG Fiduciary Partners in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Page | 14 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Institutions with orders for other accounts managed by KMG Fiduciary Partners (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, KMG Fiduciary Partners may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client will be effected independently, unless KMG Fiduciary Partners decides to purchase or sell the same securities for several clients at approximately the same time. KMG Fiduciary Partners may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among KMG Fiduciary Partners’ clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which KMG Fiduciary Partners’ Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. KMG Fiduciary Partners does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Page | 15 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Item 13. Review of Accounts Account Reviews KMG Fiduciary Partners monitors client portfolios on a continuous and ongoing basis while regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with KMG Fiduciary Partners and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients periodically to review its previous services and/or recommendations and discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from KMG Fiduciary Partners and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from KMG Fiduciary Partners or an outside service provider. Item 14. Client Referrals and Other Compensation Client Referrals In the event a client is introduced to KMG Fiduciary Partners by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable securities laws. Unless otherwise disclosed, any such referral fee is paid solely from KMG Fiduciary Partners’ investment management fee and does not result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the client will receive a solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement and any conflicts of interest. Any affiliated solicitor of KMG Fiduciary Partners is required to disclose the nature of his or her relationship to prospective clients at the time of the solicitation. Page | 16 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC Other Compensation The Firm receives economic benefits from Custodian. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody The Advisory Agreement and/or the separate agreement with any Financial Institution authorize KMG Fiduciary Partners to debit client accounts for payment of the Firm’s fees and to directly remit that those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to KMG Fiduciary Partners. In addition, as discussed in Item 13, KMG Fiduciary Partners will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from KMG Fiduciary Partners. Standing Letters of Authorization KMG Fiduciary Partners has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16. Investment Discretion KMG Fiduciary Partners is given the authority to exercise discretion on behalf of clients. KMG Fiduciary Partners is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. KMG Fiduciary Partners is given this Page | 17 © MarketCounsel 2026  Disclosure Brochure KMG Fiduciary Partners, LLC authority through a power-of-attorney included in the agreement between KMG Fiduciary Partners and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). KMG Fiduciary Partners takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities KMG Fiduciary Partners does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 18. Financial Information KMG Fiduciary Partners is not required to disclose any financial information due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 18 © MarketCounsel 2026