Overview
- Headquarters
- St. Paul, MN
- Total Firm Assets
- $145 million
- Average High-Net-Worth Client Portfolio Size
- $2.0 million
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.75% |
| $3,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,875 | 1.19% |
| $5 million | $36,875 | 0.74% |
| $10 million | $61,875 | 0.62% |
| $50 million | $261,875 | 0.52% |
| $100 million | $511,875 | 0.51% |
Clients
- High-Net-Worth Share of Firm Assets
- 64.32%
- Number of High-Net-Worth Clients
- 46
- Total Client Accounts
- 758
- Discretionary Accounts
- 674
- Non-Discretionary Accounts
- 84
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 289094
Primary Brochure: FORM ADV PART 2A (2026-07-28)
View Document Text
Part 2A of Form ADV: Firm Brochure
Item 1 Cover Page
KNOX AVENUE FINANCIAL CORP.
380 St. Peter Street, Ste. 742
St. Paul, MN 55102
Tel: 952-426-4352
July 28, 2026
FORM ADV PART 2
FIRM BROCHURE
This brochure provides information about the qualifications and business practices of Knox
Avenue Financial Corp. If you have any questions about the contents of this brochure, please
contact us at 952-426-4352. 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 Knox Avenue Financial Corp. is also available on the SEC’s website
at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Knox Avenue Financial Corp.
is 289094.
Knox Avenue Financial Corp. is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
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Item 2 Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April
30th. We will further provide you with our most recent brochure at any time at your request,
without charge. You may request a brochure by contacting us at (612) 378-7600.
Material Changes Since the Last Update
Knox Avenue Financial Corp. was established as a new Registered Investment Advisor in
August 2017 under the State of Minnesota rules and regulations. The firm filed as an advisor
with the Securities and Exchange Commission in April 2025. Since the initial SEC filing on
February 25, 2026, Knox Avenue Financial Corp. has had the following material changes:
• None
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Item 3 Table of Contents
Item 1 Cover Page.................................................................................... 1
Item 2 Material Changes .......................................................................... 2
Item 3 Table of Contents ......................................................................... 3
Item 4 Advisory Business ....................................................................... 4
Item 5 Fees and Compensation .............................................................. 5
Item 6 Performance-Based Fees and Side-By-Side Management ....... 10
Item 7 Types of Clients ............................................................................ 10
Item 8 Methods of Analysis, Investment Strategies, and Risk of
Loss………10
Item 9 Disciplinary Information………………………………..……………………………11
Item 10 Other Financial Industry Activities and Affiliations ................. 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading……………………………………………………………… 11
Item 12 Brokerage Practices ................................................................... 12
Item 13 Review of Accounts ................................................................... 13
Item 14 Client Referrals and Other Compensation ............................... 14
Item 15 Custody ....................................................................................... 14
Item 16 Investment Discretion ................................................................ 15
Item 17 Voting Client Securities ............................................................. 15
Item 18 Financial Information ................................................................. 15
Item 19 Requirements for State-Registered Advisers .......................... 15
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Item 4 Advisory Business
Knox Avenue Financial Corp. is a Registered Investment Adviser based in St. Paul, Minnesota,
and incorporated under the laws of the State of Minnesota. Knox Avenue Financial Corp. is
owned by Joseph Brill. Knox Avenue Financial Corp. is registered with the Securities and
Exchange Commission (SEC) and is subject to its rules and regulations. Founded in May 2017,
Knox Avenue Financial Corp. provides investment advisory services, which may include, but
are not limited to, the review of client investment objectives and goals, recommending asset
allocation strategies of managed assets among investment products such as cash, stocks,
mutual funds and bonds, annuities, and/or preparing written investment strategies. Our
investment advice is tailored to meet our clients’ needs and investment objectives. Clients may
impose restrictions on investing in certain securities or types of securities (such as a product
type, specific companies, specific sectors, etc.) by providing a signed and dated written
notification, of which an e-mail is also an acceptable form of notification. Knox Avenue
Financial Corp. also provides financial planning consulting services including, but not limited
to, risk assessment/management, investment planning, estate planning, financial organization,
or financial decision making/negotiation.
Knox Avenue Financial Corp. provides investment advisory and other financial services
through its Investment Advisory Representatives ("IAR") to accounts opened with Knox
Avenue Financial Corp. Managed Accounts are available to individuals and small businesses.
Knox Avenue Financial Corp. provides discretionary and non-discretionary investment
advisory services to some of its clients through various managed account programs. Knox
Avenue Financial Corp. will assist clients in determining the suitability of the Managed
Account Programs for the client. The IAR is compensated through a comprehensive single fee
and the account may be assessed other charges associated with conducting a brokerage
business. Knox Avenue Financial Corp. and its IAR, as appropriate, will be responsible for the
following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
Knox Avenue Financial Corp. may recommend a Wrap Fee Program for the client’s account(s).
A “wrap fee program” for purposes of the SEC is a program under which investment advisory
and brokerage execution services are provided for a single “wrapped” fee that is not based on the
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transactions in a client account. Knox Avenue Financial Corp. provides discretionary investment
advisory services to some of its clients through a managed account program (“the Wrap Fee
Program”). Knox Avenue Financial Corp. will assist clients in determining the suitability of the
Wrap Fee Program for the client. Wrap Fee Program accounts recommended by Knox Avenue
Financial Corp. are not managed differently from non-Wrap Fee Program accounts, and the fee
schedule below applies to Wrap Fee Program accounts. Because brokerage execution costs are
included in the client’s overall advisory fee, the client’s fee may be greater than those that have
accounts in non-Wrap Fee Program accounts, however fees will not exceed the fee schedule
below. Clients with Wrap Fee Program accounts will be provided with Knox Avenue Financial
Corp’s Wrap Fee Brochure.
The firm has the following assets under management as of December 31, 2025:
Discretionary: $127,942,082
Non-Discretionary: $16,783,072
Item 5 Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged in advance and are based primarily on asset size and the
level of complexity of the services provided. In individual cases, Knox Avenue Financial Corp.
has the sole discretion to negotiate fees that are lower than the standard fee shown or to waive
fees. Fees are not based on the share of capital gains or capital appreciation of the funds or any
portion of the funds. Comparable services for lower fees may be available from other sources.
Fees for the initial quarter will be prorated based upon the number of calendar days in the
calendar quarter that the advisory agreement is in effect. Fees are based on the market value of
the assets on the last business day of the previous quarter. Annual fees range from .50% - 1.50%
depending on the amount of assets under management (“AUM”) – See chart below. Assets
deposited into, or withdrawn from, your account between billing cycles may result in additional
or less management fees being billed to you. Therefore, a pro-rata fee based upon the number of
days remaining in the current quarterly period may be assessed to you, or deducted. Consulting
services are included in these fees for asset management services with the exception of unique
circumstances that may require a separate agreement for financial planning/consulting services
(description and fees are discussed below). If the situation warrants separate financial planning
fees, it will be discussed upfront and a separate agreement will be negotiated.
Blended Fee Schedule for Asset Management:
· 0 - $250,000: 1.50%
· $250,000 – $500,000: 1.25%
· $500,000 - $1,000,000: 1.00%
· $1,000,000 - $3,000,000: 0.75%
· $3,000,000 and above: 0.50%
* There may be an annual account fee charged by us in the amount of $25.00.
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As authorized in the client agreement, the account custodian withdraws Knox Avenue Financial
Corp.’s advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to Knox
Avenue Financial Corp. for advisory services. You should carefully review the statement from
your custodian/broker-dealer’s statement and verify the calculation of fees. Your
custodian/broker-dealer does not verify the accuracy of fee calculations.
Fees are charged in advance on a quarterly basis, meaning that advisory fees for a quarter are
charged on the first day of the quarter. Clients may terminate investment advisory services
obtained from Knox Avenue Financial Corp., without penalty, upon written notice within five (5)
business days after entering into the advisory agreement with Knox Avenue Financial Corp.
The client is responsible for any fees and charges incurred by the client from third parties as a
result of maintaining the account such as transaction fees for any securities transactions executed
and account maintenance or custodial fees. Thereafter, the client may terminate advisory
services upon written notice delivered to and received by Knox Avenue Financial Corp. Clients
who terminate investment advisory services during a quarter are charged a prorated advisory fee
based on the date of Knox Avenue Financial Corp.’s receipt of client’s written notice to
terminate. Any earned but unpaid fees are immediately due and payable.
Financial Planning – Financial planning services are charged in advance through a fixed fee as
agreed upon between the client and Knox Avenue Financial Corp. There will never be an
instance where $500 or more in fees is charged six or more months in advance. Fees are
negotiable and vary depending upon the complexity of the client situation and services to be
provided. Fixed fees for financial planning/consulting projects range from $250 to $10,000 per
project.
Clients who wish to terminate the planning process prior to completion may do so with written
notice. The client may obtain a refund of a pre-paid fee if the advisory contract is terminated
before the end of the project by contacting Joseph Brill at 952-426-4352. Upon receipt of
written notification, any earned fee will immediately become due and payable. A client may
terminate an advisory agreement without being assessed any fees or expenses within five (5)
days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to Knox Avenue Financial Corp. as explained above, clients
may pay custodial service, account maintenance, transaction, and other fees associated with
maintaining the account. These fees vary by broker and/or custodian. Clients should ask Knox
Avenue Financial Corp. for details on transaction fees or other custodial fees specific to their
account, as these fees are not included in the annual advisory fee. Knox Avenue Financial Corp.
does not share any portion of such fees. Additionally, for any mutual funds purchased, the client
may pay their proportionate share of the funds’ distribution, internal management, investment
advisory and administrative fees. Such fees are not shared with Knox Avenue Financial Corp.
and are compensation to the fund manager. Clients are urged to read the mutual fund prospectus
prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
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prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Mutual funds purchased or sold in broker-dealer accounts may generate transaction fees
that would not exist if the purchase or sale were made directly with the mutual fund
company.
Mutual funds held in broker-dealer accounts also charge management fees. These mutual
fund management fees may be more or less than the mutual fund management fees charged if
the client held the mutual fund directly with the mutual fund company.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of Knox Avenue Financial Corp. or
paying the advisory fee on such shares (but subject to any applicable sales charges). Certain
mutual funds are offered to the public without a sales charge. In the case of mutual funds
offered with a sales charge, the prevailing sales charge (as described in the mutual fund
prospectus) may be more or less than the applicable advisory fee. However, clients would not
receive Knox Avenue Financial Corp.’s assistance in developing an investment strategy,
selecting securities, monitoring performance of the account, and making changes as necessary.
Please refer to Item 12 “Brokerage Practices” of this brochure for additional information.
Item 6 Performance-Based Fees and Side-By-Side Management
Knox Avenue Financial Corp. does not charge performance-based fees or participate in side-by-
side management. Side-by-side management refers to the practice of managing accounts that are
charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital
gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and
Compensation section above, and are not charged on the basis of performance of your advisory
account.
Item 7 Types of Clients
Knox Avenue Financial Corp. offers investment advisory services to individuals and
small businesses. There is no minimum account size to open and maintain an advisory
account.
Item 8 Methods of Analysis, Investment Strategies, and Risk of
Loss
Knox Avenue Financial Corp.’s methods of analysis and investment strategies incorporate the
client’s needs and investment objectives, time horizon, and risk tolerance. Knox Avenue
Financial Corp. is not bound to a specific investment strategy for the management of
investment portfolios, but rather consider the risk tolerance levels pre-determined gathered at
the account opening, as well as on an on-going basis. Examples of methodologies that our
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investment strategies may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a
mix of asset classes and the efficient allocation of capital to those assets by matching rates of
return to a specified and quantifiable tolerance for risk.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar
amount of securities at regularly scheduled intervals, regardless of the price per share. This
will gradually, over time, decrease the average share price of the security. Dollar-cost
averaging lessens the risk of investing a large amount in a single investment at the wrong time.
Technical Analysis – involves studying past price patterns and trends in the financial markets
to predict the direction of both the overall market and specific stocks.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the
securities’ short term price fluctuations.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances,
there can be no guarantee that our efforts will be successful. You should be prepared to bear the
risk of loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. These risks include market risk, interest rate risk, issuer risk, and general
economic risk. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. Knox Avenue Financial Corp.’s investment approach may fail to produce
the intended results. If our perception of the performance of a specific asset class or underlying
fund is not realized in the expected time frame, the overall performance of client’s portfolio
may suffer.
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Equity Risk. Equity securities tend to be more volatile than other investment choices. The
value of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and
may be affected by adverse political, legislative and tax changes, as well as by financial
developments that affect the municipal issuers. Because many municipal obligations are issued
to finance similar projects by municipalities (e.g., housing, healthcare, water and sewer projects,
etc.), conditions in the sector related to the project can affect the overall municipal market.
Payment of municipal obligations may depend on an issuer’s general unrestricted revenues,
revenue generated by a specific project, the operator of the project, or government appropriation
or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an
investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be
halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed
from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large
decreases in stock prices) halts stock trading generally. Knox Avenue Financial Corp. has no
control over the risks taken by the underlying funds.
Artificial Intelligence and Machine Learning Risk - Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
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service providers have appropriate controls in place to protect our clients’ information and to limit
data inaccuracies when artificial intelligence is used by the service provider.
Item 9 Disciplinary Information
Knox Avenue Financial Corp. or its Principal Executive Officers have not had any reportable
disclosable events in the past ten years.
Item 10 Other Financial Industry Activities and Affiliations
Joseph Brill, owner of Knox Avenue Financial Corp., is not currently registered with any
broker dealer.
Neither Knox Avenue Financial Corp. nor its representatives are registered as a Futures
Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.
Joseph Brill is also a licensed insurance agent. From time to time, he will offer clients advice or
products from those activities. Clients should be aware that these services pay a commission and
involve a possible conflict of interest, as commissionable products can conflict with the
fiduciary duties of a registered investment adviser. Knox Avenue Financial Corp. always acts in
the best interest of the client; including the sale of commissionable products to advisory clients.
Clients are in no way required to implement the plan through any representative of Knox
Avenue Financial Corp. in their capacity as an insurance agent.
Item 11 Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Knox Avenue Financial Corp.’s Code of Ethics includes guidelines for professional standards of
conduct for our Associated Persons. Our goal is to protect client interests at all times and to
demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of
Knox Avenue Financial Corp.’s Associated Persons are expected to strictly adhere to these
guidelines. Persons associated with Knox Avenue Financial Corp. are also required to report any
violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information
about our clients or client accounts by persons associated with our firm.
Knox Avenue Financial Corp. and its employees may buy or sell securities that are also held by
clients. It is the expressed policy of the advisor that no person employed by our firm purchase or
sell any security prior to the transaction being implemented for an advisory account; therefore,
preventing such employees from benefiting from transactions placed on behalf of the advisory
clients.
The advisor may have an interest or position in a certain security, which may also be recommended
to the client. As these situations may present a conflict of interest, the advisor has established the
following restrictions in order to ensure its fiduciary responsibilities:
1. A director, officer or employee of the advisor shall not buy or sell a security for their
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personal portfolio(s) where their decision is substantially derived, in whole or part, by
reason of his or her employment, unless the information is also available to the investing
public. No owner/employee of Knox Avenue Financial Corp. shall prefer their own interest
to that of the client.
2. The advisor maintains a list of all securities held by the company and all directors, officers,
and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3. The advisor requires that all employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisors.
4. The advisor will not block personal trades with those of clients to ensure that clients
are not at a disadvantage.
Knox Avenue Financial Corp.’s Code of Ethics is available to you upon request. You may
obtain a copy of our Code of Ethics by contacting Joseph Brill at 952-426-4352.
Item 12 Brokerage Practices
In order for Knox Avenue Financial Corp. to provide asset management services, we request
you utilize the brokerage and custodial services of Charles Schwab & Co., Inc., Member
FINRA/SIPC, for which we have an existing relationship. In considering which independent
qualified custodian is the best fit for Knox Avenue Financial Corp.’s business model, we
evaluated the following factors, which is not an all-inclusive list:
➢ Financial strength
➢ Reputation
➢ Reporting capabilities
➢ Execution capabilities
➢ Pricing, and
➢ Types and quality of research
While you are free to choose any broker-dealer or other service provider, we recommend that
you establish an account with a brokerage firm with which we have an existing relationship.
Such relationships may include benefits provided to our firm, including, but not limited to
research, market information, and administrative services that help our firm manage your
account(s). We believe that recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best
execution. We also consider the quality of the brokerage services provided by the
recommended broker-dealers, including the value of research provided, the firm’s reputation,
execution capabilities, commission rates, and responsiveness to our clients and our firm.
You may direct us in writing to use a particular broker-dealer to execute some or all of the
transactions for your account. If you do so, you are responsible for negotiating the terms and
arrangements for the account with that broker-dealer. We may not be able to negotiate
commissions, obtain volume discounts, or best execution. In addition, under these
circumstances a difference in commission charges may exist between the commissions charged
to clients who direct us to use a particular broker or dealer and other clients who do not direct us
to use a particular broker or dealer.
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Knox Avenue Financial Corp. does not have any soft dollar arrangements.
Knox Avenue Financial Corp. does not receive client referrals from broker-dealers in
exchange for cash or other compensation, such as brokerage services or research.
When Knox Avenue Financial Corp. buys or sells the same security for two or more clients
(including our personal accounts), we may place concurrent orders to be executed together as a
single “block” in order to facilitate orderly and efficient execution. Each client account will be
charged or credited with the average price per unit. We receive no additional compensation or
remuneration of any kind because we aggregate client transactions. No client is favored over
any other client. If an order is not completely filled, it is allocated pro-rata based on an
allocation statement prepared by Knox Avenue Financial Corp. prior to placing the order.
Because of an order’s aggregation, some clients may pay higher transaction costs, or greater
spreads, or receive less favorable net prices on transactions than would otherwise be the case if
the order had not been aggregated. Knox Avenue Financial Corp. may choose to aggregate
orders for its proprietary or personnel’s accounts with those of its clients. Knox Avenue
Financial Corp. will receive no additional compensation or remuneration resulting from the
aggregation of client transactions.
Item 13 Review of Accounts
Client accounts are reviewed at least quarterly by Joseph Brill, Principal Executive Officer of
the firm. Joseph Brill reviews clients’ accounts with regards to their investment policies and risk
tolerance levels. All accounts at Knox Avenue Financial Corp. are assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by
Joseph Brill, Principal Executive Officer of the firm. There is only one level of review and that is
the total review conducted to create the financial plan.
Reviews may be triggered by material market, economic or political events, or by changes in
client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
Item 14 Client Referrals and Other Compensation
Knox Avenue Financial Corp. does not compensate any individual or firm for client referrals.
Knox Avenue Financial Corp. also does not receive compensation from any firm or entity for
referring professional services.
Knox Avenue Financial Corp. does receive compensation from Mutual Securities for
providing consultation on annuities.
Item 15 Custody
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Knox Avenue Financial Corp. does not have physical custody of any client funds and/or
securities and does not take custody of client accounts at any time. Client funds and securities
will be held with a bank, broker dealer, or other independent qualified custodian. However, by
granting Knox Avenue Financial Corp. written authorization to automatically deduct fees from
client accounts, Knox Avenue Financial Corp. is deemed to have limited custody. You will
receive account statements from the independent, qualified custodian holding your funds at least
quarterly. The account statement from your custodian will indicate the amount of advisory fees
deducted from your account(s) each billing cycle. Clients should carefully review statements
received from the custodian. Knox Avenue Financial Corp. also sends quarterly invoices
detailing the manner and amount of advisory fees to all clients.
Some clients may execute limited powers of attorney or other standing letters of authorization
that permit the firm to transfer money from their account with the client’s independent qualified
Custodian to third-parties. This authorization to direct the Custodian may be deemed to cause
our firm to exercise limited custody over your funds or securities and for regulatory reporting
purposes, we are required to keep track of the number of clients and accounts for which we may
have this ability. We do not have physical custody of any of your funds and/or securities. Your
funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s)
holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate any transfers that may have taken place within your account(s) each
billing period. You should carefully review account statements for accuracy.
Item 16 Investment Discretion
Before Knox Avenue Financial Corp. can buy or sell securities on your behalf, you must first
sign our discretionary management agreement, a limited power of attorney, and/or trading
authorization forms. By choosing to do so, you may grant the firm discretion over the selection
and amount of securities to be purchased or sold for your account(s) without obtaining your
consent or approval prior to each transaction. Clients may impose limitations on discretionary
authority for investing in certain securities or types of securities (such as a product type, specific
companies, specific sectors, etc.), as well as other limitations as expressed by the client.
Limitations on discretionary authority are required to be provided to the IAR in writing.
Please refer to the “Advisory Business” section of this Brochure for more information on our
discretionary management services.
Item 17 Voting Client Securities
We do not vote proxies on behalf of your advisory accounts. At your request, we may offer you
advice regarding corporate actions and the exercise of your proxy voting rights. If you own
shares of common stock or mutual funds, you are responsible for exercising your right to vote
as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However,
in the event we were to receive any written or electronic proxy materials, we would forward
them directly to you by mail, unless you have authorized our firm to contact you by electronic
mail, in which case, we would forward any electronic solicitation to vote proxies.
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Item 18 Financial Information
Knox Avenue Financial Corp. is not required to provide financial information to our clients
because we do not require or solicit the prepayment of more than $500 six or more months
in advance.
Item 19 Requirements for State-Registered Advisers
Knox Avenue Financial Corp. is SEC registered, therefore there is nothing to be disclosed in this
section.
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Additional Brochure: WRAP FEE BROCHURE (2026-07-28)
View Document Text
Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure
Item 1 Cover Page
KNOX AVENUE FINANCIAL CORP.
380 St. Peter Street, Ste. 742
St. Paul, MN 55102
Tel: (952) 426-4352
July 28, 2026
FORM ADV PART 2A APPENDIX 1
WRAP FEE PROGRAM BROCHURE
This brochure provides information about the qualifications and business practices of Knox
Avenue Financial Corp. If you have any questions about the contents of this brochure, please
contact us at (952) 426-4352. 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 Knox Avenue Financial Corp. is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Knox Avenue
Financial Corp. is 289094.
Knox Avenue Financial Corp. is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a
certain level of skill or training.
1
Item 2 Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure. Each year, we will ensure that
you receive a summary of any material changes to this and subsequent brochures by April
30th. We will further provide you with our most recent brochure at any time at your request,
without charge. You may request a brochure by contacting us at (612) 378-7600.
Material Changes Since the Last Update
Knox Avenue Financial Corp. was established as a new Registered Investment Advisor in
August 2017 under the State of Minnesota rules and regulations. The firm filed as an advisor
with the Securities and Exchange Commission in April 2025. Since the initial SEC filing on
February 25, 2026, Knox Avenue Financial Corp. has had the following material changes:
• None.
2
Item 3 Table of Contents
Item 1 Cover Page.................................................................................... .1
Item 2 Material Changes .......................................................................... .2
Item 3 Table of Contents ......................................................................... .3
Item 4 Services, Fees and Compensation… ........................................... 4
Item 5 Account Requirements and Types of Clients ............................. 9
Item 6 Portfolio Manager Selection and Evaluation… ........................... 9
Item 7 Client Information Provided to Portfolio Managers .................. 13
Item 8 Client Contact with Portfolio Managers ..................................... 13
Item 9 Additional Information. ............................................................... 13
Item 10 Requirements for State Registered Advisors………………….15
3
Item 4 Services, Fees and Compensation
Knox Avenue Financial Corp. is an SEC Registered Investment Adviser based in St. Paul,
Minnesota, and incorporated under the laws of the State of Minnesota. Knox Avenue
Financial Corp. is owned by Joseph Brill. Knox Avenue Financial Corp. is registered with the
Securities and Exchange Commission (SEC) and is subject to its rules and regulations.
Founded in May 2017, Knox Avenue Financial Corp. provides investment advisory services,
which may include, but are not limited to, the review of client investment objectives and goals,
recommending asset allocation strategies of managed assets among investment products such
as Cash, Stocks, Mutual Funds and Bonds, Exchange-Traded Funds, and/or preparing written
investment strategies. Our investment advice is tailored to meet our clients’ needs and
investment objectives. Clients may impose restrictions on investing in certain securities or
types of securities (such as a product type, specific companies, specific sectors, etc.) by
providing a signed and dated written notification, of which an e-mail is also an acceptable
form of notification. Knox Avenue Financial Corp. also provides financial planning consulting
services including, but not limited to, risk assessment/management, investment planning,
estate planning, financial organization, or financial decision making/negotiation.
A “wrap fee program” for purposes of the SEC is a program under which investment advisory
and brokerage execution services are provided for a single “wrapped” fee that is not based on
the transactions in a client account. Knox Avenue Financial Corp. provides discretionary
investment advisory services to some of its clients through a managed account program (“the
Wrap Fee Program”). Knox Avenue Financial Corp. will assist clients in determining the
suitability of the Wrap Fee Program for the client.
Knox Avenue Financial Corp. offers a clearing platform to execute securities business for
investment advisory services, including Wrap Fee Program services, through Charles
Schwab & Co., Inc. Member FINRA/SIPC (“Schwab”).
WRAP FEE PROGRAM
Knox Avenue Financial Corp.’s Wrap Fee Program is offered as a part of the Asset
Management Services described below. Knox Avenue Financial Corp. provides portfolio
management services for this program based on the Client’s investment goals and
objectives. Managed Accounts are available to primarily individuals.
Fees and Compensation
The following types of fees will be assessed:
Asset Management – Fees are charged in advance and are based primarily on asset size and the
level of complexity of the services provided. For example, if the client’s situation warrants
additional monitoring or frequent meeting updates, the fee may be higher than other client
situations that do not require as much attention. There will never be an instance when the fees
are greater than stated below. In individual cases, Knox Avenue Financial Corp. has the sole
discretion to negotiate fees that are lower than the standard fee shown or to waive fees. The fees
below for asset management are not based on the share of capital gains or capital appreciation
4
of the funds or any portion of the funds. Comparable services for lower fees may be available
from other sources. Fees for the initial quarter will be prorated based upon the number of
calendar days in the calendar quarter that the advisory agreement is in effect. Fees are based on
the market value of the assets on the last business day of the previous quarter. Annual fees
range from 1.50% - .50% depending on the amount of assets under management (“AUM”) –
See chart below. Fees for asset management services of certain accounts include broker-dealer
transaction costs, and because of this are considered Wrap accounts. The cost of these programs
to you, if provided separately with the equivalent trading activity in the client account(s), may
cost more or less than purchasing such services separately. Assets deposited into, or withdrawn
from, your account between billing cycles may result in additional or less management fees
being billed to you. Therefore, a pro-rata fee based upon the number of days remaining in the
current quarterly period may be assessed to you or deducted. Consulting services are included
in these fees for asset management services with the exception of unique circumstances that
may require a separate agreement for financial planning services (description and fees are
discussed below). If the situation warrants separate financial planning fees, it will be discussed
upfront and a separate agreement will be negotiated.
Blended Fee Schedule for Asset Management:
· 0 - $250,000: 1.50%
· $250,000 – $500,000: 1.25%
· $500,000 - $1,000,000: 1.00%
· $1,000,000 - $3,000,000: 0.75%
· $3,000,000 and above: 0.50%
* There may be an annual account fee charged by us in the amount of $25.00.
As authorized in the client agreement, the account custodian withdraws Knox Avenue Financial
Corp.’s advisory fees directly from the clients’ accounts according to the custodian’s policies,
practices, and procedures. The custodial statement includes the amount of any fees paid to Knox
Avenue Financial Corp. for advisory services. The fees paid to the custodian are assessed on your
account(s) held with the custodian. We have a conflict of interest because we have a financial
incentive to maximize our compensation by seeking to reduce or minimize the total costs incurred
in your account(s) subject to a wrap fee. You should carefully review the statement from your
custodian/broker-dealer’s statement and verify the calculation of fees. Your custodian/broker-
dealer does not verify the accuracy of fees calculations.
Fees are charged quarterly in advance. Clients may terminate investment advisory services
obtained from Knox Avenue Financial Corp., without penalty, upon written notice within five (5)
business days after entering into the advisory agreement with Knox Avenue Financial Corp.
Thereafter, the client may terminate advisory services upon written notice delivered to and
received by Knox Avenue Financial Corp. Clients who terminate investment advisory services
during a quarter are charged a prorated advisory fee based on the date of Knox Avenue Financial
Corp.’s receipt of client’s written notice to terminate. Any earned but unpaid fees are
5
immediately due and payable.
For hourly financial planning, clients will be invoiced monthly for all time spent by Knox
Avenue Financial Corp. as agreed upon by the client or upon delivery of the services if less than
a month. Clients who wish to terminate the planning process prior to completion may do so with
written notice. The client may obtain a refund of a pre-paid fee if the advisory contract is
terminated before the end of the project by contacting us at (952) 426-4352. Upon receipt of
written notification, any earned fee will immediately become due and payable. A client may
terminate an advisory agreement without being assessed any fees or expenses within five (5)
days of its signing.
Additional Fees and Expenses
In addition to advisory fees paid to Knox Avenue Financial Corp. as explained above, clients are
charged custodial service, account maintenance, transaction, and other fees associated with
maintaining the account, however Knox Avenue Financial Corp. pays some or all of these fees
for designated Wrap Accounts. Therefore, these fees are included in the fee schedule above.
These fees vary by broker dealer and/or custodian. Additionally, for any mutual funds
purchased, the client may pay their proportionate share of the funds’ distribution, internal
management, investment advisory and administrative fees. Such fees are not shared with Knox
Avenue Financial Corp. and are compensation to the fund manager. Clients are urged to read the
mutual fund prospectus prior to investing.
Mutual fund companies impose internal fees and expenses on clients. These fees are in addition
to the costs associated with the investment advisory services as described above. Complete
details of such internal expenses are specified and disclosed in each mutual fund company’s
prospectus. Clients are strongly advised to review the prospectus(es) prior to investing in such
securities.
Clients may purchase shares of mutual funds directly from the mutual fund issuer, its principal
underwriter, or a distributor without purchasing the services of Knox Avenue Financial Corp. or
paying the advisory fee on such shares (but subject to any applicable sales charges). Certain
mutual funds are offered to the public without a sales charge. In the case of mutual funds offered
with a sales charge, the prevailing sales charge (as described in the mutual fund prospectus) may
be more or less than the applicable advisory fee. However, clients would not receive Knox
Avenue Financial Corp.’s assistance in developing an investment strategy, selecting securities,
monitoring performance of the account, and making changes as necessary.
Item 5 Account Requirements and Types of Clients
Knox Avenue Financial Corp. provides investment advisory services primarily to individuals.
There is no account minimum required to open and maintain an advisory account.
Item 6 Portfolio Manager Selection and Evaluation
Knox Avenue Financial Corp. is the sponsor and acts as the portfolio manager for its Wrap Fee
Program accounts. There are no conflicts of interest with this arrangement.
6
Advisory Business
Knox Avenue Financial Corp. is a Registered Investment Adviser based in St. Paul, Minnesota,
and incorporated under the laws of the State of Minnesota. Knox Avenue Financial Corp. is
owned by Joseph Brill. Knox Avenue Financial Corp. is registered with the State of Minnesota
and is subject to its rules and regulations. Founded in 2017, Knox Avenue Financial Corp.
provides investment advisory services, which may include, but are not limited to, the review of
client investment objectives and goals, recommending asset allocation strategies of managed
assets among investment products such as Cash, Stocks, Mutual Funds and Bonds, Exchange-
Traded Funds, American Depository Receipts and/or preparing written investment strategies.
Our investment advice is tailored to meet our clients’ needs and investment objectives. Clients
may impose restrictions on investing in certain securities or types of securities (such as a product
type, specific companies, specific sectors, etc.) by providing a signed and dated written
notification, of which an e-mail is also an acceptable form of notification. Knox Avenue
Financial Corp. also provides financial planning consulting services including, but not limited to,
risk assessment/management, investment planning, estate planning, financial organization, or
financial decision making/negotiation.
Knox Avenue Financial Corp. provides investment advisory and other financial services through
its Investment Advisory Representatives ("IAR") to accounts opened with Knox Avenue
Financial Corp. Managed Accounts are available to both retail clients (for example, smaller
accounts of individuals, IRAs, trusts and employee benefit plans) and institutional clients (for
example, corporate pension plans, corporations and foundations).
Asset Management
Knox Avenue Financial Corp. provides discretionary investment advisory services to its clients
through various managed account programs. Knox Avenue Financial Corp. will assist clients in
determining the suitability of the Managed Account Programs for the client. The IAR is
compensated through a comprehensive single fee and the account may be assessed other charges
associated with conducting a brokerage business. Knox Avenue Financial Corp. and its IAR, as
appropriate, will be responsible for the following:
• Performing due diligence
• Recommending strategic asset and style allocations
• Providing research on investment product options, as needed
• Providing client risk profile questionnaire
• Obtaining investment advisory contract from client with required financial, risk tolerance,
suitability and investment vehicle selection information for each new account
• Performing client suitability check on account documentation, review the investment
objectives and evaluate the investment vehicle selections
• Providing Firm Brochure (this document)
Knox Avenue Financial Corp. may recommend a Wrap Fee Program for the client’s account(s).
Wrap Fee Program accounts recommended by Knox Avenue Financial Corp. are not managed
differently from non-Wrap Fee Program accounts, and the fee schedule above applies to Wrap
Fee Program accounts. Because brokerage execution costs are included in the client’s overall
advisory fee, the client’s fee may be greater than those that have accounts in non-Wrap Fee
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Program accounts, however fees will not exceed the fee schedule above. Clients with Wrap Fee
Program accounts will be provided with this document, Knox Avenue Financial Corp.’s Wrap
Fee Brochure.
Financial Planning
Knox Avenue Financial Corp. may provide its Clients with a broad range of comprehensive
financial planning, risk management, pension, estate and trust consulting services (which may
include tax-related and other non-investment related matters.) These services are customized
according to the specific request by the Client. The financial planning consulting services may
include, but are not limited to, risk assessment/management, investment planning, estate
planning, financial organization, or financial decision making/negotiation. These services are
usually not provided on a continual, ongoing basis, and the advice offered by Knox Avenue
Financial Corp. may be limited and may not be comprehensive but limited in scope based on the
Client’s request for services. Once your financial parameters have been identified, we may
prepare a recommended allocation plan that outlines what asset mix is most suitable for your
unique investment expectations and risk tolerance.
The firm has the following assets under management as of December 31, 2025:
Discretionary: $127,942,082
Non-Discretionary: $16,783,072
Performance-Based Fees and Side by Side Management
Knox Avenue Financial Corp. does not charge performance-based fees or participate in side-by-
side management. Side-by-side management refers to the practice of managing accounts that are
charged performance-based fees while at the same time managing accounts that are not charged
performance-based fees. Performance-based fees are fees that are based on a share of capital
gains or appreciation of the assets of a client. Our fees are calculated as described in Fees and
Compensation section above and are not charged on the basis of performance of your advisory
account.
Methods of Analysis, Investment Strategies, and Risk of Loss
Knox Avenue Financial Corp.’s methods of analysis and investment strategies incorporate the
client’s needs and investment objectives, time horizon, and risk tolerance. Knox Avenue
Financial Corp. is not bound to a specific investment strategy for the management of investment
portfolios, but rather consider the risk tolerance range of each portfolio and the risk level of each
level when the account is opened. Examples of methodologies that our investment strategies
may incorporate include:
Asset Allocation – Asset Allocation is a broad term used to define the process of selecting a mix
of asset classes and the efficient allocation of capital to those assets by matching rates of return
to a specified and quantifiable tolerance for risk. Asset Allocation has the potential of all the
risks listed below.
Dollar-Cost Averaging – Dollar-cost averaging is the technique of buying a fixed dollar amount
of securities at regularly scheduled intervals, regardless of the price per share. This will gradually,
over time, decrease the average share price of the security. Dollar-cost averaging lessens the risk
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of investing a large amount in a single investment at the wrong time. Dollar-Cost Averaging has
the potential of all the risks listed below.
Technical Analysis – involves studying past price charts, patterns and trends in the financial
markets to predict the direction of both the overall market and specific stocks. Technical
Analysis has the potential of all the risks listed below.
Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. Long-
Term Purchases have the potential of all the risks listed below.
Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the securities’
short term price fluctuations. Short-term Purchases primarily have the potential of Market Risk,
Business Risk, and Liquidity Risk as listed below.
Our strategies and investments may have unique and significant tax implications. Regardless of
your account size or other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Investing in securities involves risk of loss that clients should be prepared to bear. Although we
manage your portfolio with strategies and in a manner consistent with your risk tolerances, there
can be no guarantee that our efforts will be successful. You should be prepared to bear the risk of
loss.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. Regardless of the methods of analysis or strategies suggested for your particular
investment goals, you should carefully consider these risks, as they all bear risks.
Knox Avenue Financial Corp.’s primary goal for investing is to help the client maintain
purchasing power over the long term. This may result in short term variability and loss of
principal. Time horizon and risk tolerance are key determinates of the proper asset allocation.
Knox Avenue Financial Corp.’s approach focuses on taking appropriate risks for which clients
are compensated (i.e. market risk) and seeking to limit or eliminate risks that do not provide
compensation over the long term (i.e. individual stock risk or lack of portfolio risk).
Below are some more specific risks of investing:
Market Risk. The prices of securities in which clients invest may decline in response to certain
events taking place around the world, including those directly involving the companies whose
securities are owned by the client or an underlying fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors should have a
long-term perspective and be able to tolerate potentially sharp declines in market value.
Management Risk. Knox Avenue Financial Corp.’s investment approach may fail to produce
the intended results. If our perception of the performance of a specific asset class or underlying
fund is not realized in the expected time frame, the overall performance of client’s portfolio may
suffer.
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Equity Risk. Equity securities tend to be more volatile than other investment choices. The value
of an individual mutual fund or ETF can be more volatile than the market as a whole. This
volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are
subject to additional risks. Smaller companies may experience greater volatility, higher failure
rates, more limited markets, product lines, financial resources, and less management experience
than larger companies. Smaller companies may also have a lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in response to
selling pressure than is the case with larger companies.
Fixed Income Risk. The issuer of a fixed income security may not be able to make interest and
principal payments when due. Generally, the lower the credit rating of a security, the greater the
risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower
rating, the value of the debt security will decline because investors will demand a higher rate of
return. As nominal interest rates rise, the value of fixed income securities is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
Municipal Securities Risk. The value of municipal obligations can fluctuate over time, and may
be affected by adverse political, legislative and tax changes, as well as by financial developments
that affect the municipal issuers. Because many municipal obligations are issued to finance
similar projects by municipalities (e.g., housing, healthcare, water and sewer projects, etc.),
conditions in the sector related to the project can affect the overall municipal market. Payment of
municipal obligations may depend on an issuer’s general unrestricted revenues, revenue
generated by a specific project, the operator of the project, or government appropriation or aid.
There is a greater risk if investors can look only to the revenue generated by the project. In
addition, municipal bonds generally are traded in the “over-the-counter” market among dealers
and other large institutional investors. From time to time, liquidity in the municipal bond market
(the ability to buy and sell bonds readily) may be reduced in response to overall economic
conditions and credit tightening.
Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the
client indirectly bears its proportionate share of any fees and expenses payable directly by those
funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In
addition, the client’s overall portfolio may be affected by losses of an underlying fund and the
level of risk arising from the investment practices of an underlying fund (such as the use of
derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a
market price that is above or below their net asset value; (ii) the ETF may employ an investment
strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the
listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases
in stock prices) halts stock trading generally. Knox Avenue Financial Corp. has no control over
the risks taken by the underlying funds.
Artificial Intelligence and Machine Learning Risk - Certain service providers utilized by the
Firm to service client accounts have artificial intelligence components. The use of artificial
intelligence and machine learning includes increased risk of data inaccuracies and security
vulnerabilities. Due to the rapid advancement of machine learning technologies, future risks
related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, the Firm performs periodic due diligence of our service providers for assurance that the
10
service providers have appropriate controls in place to protect our clients’ information and to limit
data inaccuracies when artificial intelligence is used by the service provider.
Voting Client Securities
Knox Avenue Financial Corp. does not vote proxies on behalf of Client advisory accounts. At
the Client’s request, Knox Avenue Financial Corp. may offer the Client advice regarding
corporate actions and the exercise of proxy voting rights. If the Client owns shares of common
stock or mutual funds, the Client is responsible for exercising the right to vote as a shareholder.
In most cases, the Client will receive proxy materials directly from the account custodian.
However, in the event Knox Avenue Financial Corp. receives any written or electronic proxy
materials, we would forward them directly to the Client by mail, unless the Client has authorized
our firm to contact you by electronic mail, in which case, Knox Avenue Financial Corp. would
forward any electronic solicitation to vote proxies.
Item 7 Client Information Provided to Portfolio Managers
Knox Avenue Financial Corp. will directly provide the portfolio management services for the
Wrap Fee Program accounts. As such, Knox Avenue Financial Corp. receives all information
provided by the Client through a formal Needs Analysis and consultation with the Client. Advice
is provided through consultation with the client and may include determination of financial
objectives, identification of financial problems, cash flow management, tax planning, insurance
review, investment management, education funding, retirement planning, and estate planning.
Item 8 Client Contact with Portfolio Managers
There are no restrictions placed on Knox Avenue Financial Corp.’s clients’ ability to contact and
consult with their portfolio managers.
Item 9 Additional Information
Disciplinary Information
Knox Avenue Financial Corp. or its Principal Executive Officers have not had any reportable
disclosable events in the past ten years.
Other Financial Industry Activities and Affiliations
Joseph Brill, owner of Knox Avenue Financial Corp., is not currently registered with any
broker dealer.
Neither Knox Avenue Financial Corp. nor its representatives are registered as a Futures
Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor.
Neither Knox Avenue Financial Corp. nor its representatives have any other outside
business activities.
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Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Knox Avenue Financial Corp.’s Code of Ethics includes guidelines for professional standards of
conduct for our Associated Persons. Our goal is to protect client interests at all times and to
demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing. All of
Knox Avenue Financial Corp.’s Associated Persons are expected to strictly adhere to these
guidelines. Persons associated with Knox Avenue Financial Corp. are also required to report any
violations to the Code of Ethics. Additionally, the firm maintains and enforces written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information
about our clients or client accounts by persons associated with our firm.
Knox Avenue Financial Corp. may buy or sell securities for itself that we also recommend to
clients. In addition, the individual IARs may buy or sell the same securities for their personal
and family accounts that are bought and sold for your account(s).
Knox Avenue Financial Corp. or its IARs may have an interest or position in a certain security,
which may also be recommended to the client. As these situations may present a conflict of
interest, Knox Avenue Financial Corp. has established the following restrictions in order to
ensure its fiduciary responsibilities:
A director, officer or employee of the advisor shall not buy or sell a security for their
The advisor requires that all employees must act in accordance with all applicable
The advisor will monitor any blocking of personal trades with those of clients to ensure
1.
personal portfolio(s) where their decision is substantially derived, in whole or part, by reason of
his or her employment, unless the information is also available to the investing public. No
owner/employee of Knox Avenue Financial Corp. shall prefer their own interest to that of the
client.
2.
The advisor maintains a list of all securities held by the company and all directors,
officers, and employees. These holdings are reviewed on a quarterly basis by the principal of the
firm.
3.
Federal and State regulations governing registered investment advisors.
4.
that clients are not at a disadvantage.
Knox Avenue Financial Corp.’s Code of Ethics is available to you upon request. You may
obtain a copy of our Code of Ethics by contacting Joseph Brill at (952) 426-4352.
Knox Avenue Financial Corp. does not recommend or select other investment advisors to our
clients for which we receive compensation, directly or indirectly, from those advisors, nor do we
have business relationships with any other investment advisors.
Review of Accounts
Client accounts are reviewed at least quarterly by Joseph Brill, Principal Executive Officer of the
firm. Client accounts are reviewed with regard to their investment policies and risk tolerance
levels. All accounts at Knox Avenue Financial Corp. are reviewed by Joseph Brill.
All financial planning accounts are reviewed upon financial plan creation and plan delivery by
Joseph Brill, Principal Executive Officer of the firm. There is only one level of review and that is
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the total review conducted to create the financial plan.
Reviews may also be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical move, or
inheritance).
Each client will receive at least quarterly a written report that details the clients’ account which
may come from the custodian.
Clients are provided a one-time financial plan concerning their financial situation. After the
presentation of the plan, there are no further reports. Clients may request additional plans or
reports for a fee.
Client Referrals and Other Compensation
Knox Avenue Financial Corp. does not compensate any individual or firm for client referrals, nor
does Knox Avenue Financial Corp. receive compensation for referrals made to other professional
service providers.
Financial Information
Knox Avenue Financial Corp. is not required to provide financial information to our clients
because we do not require or solicit the prepayment of more than $500 six or more months in
advance.
Item 10 Requirements for State-Registered Advisers
Knox Avenue Financial Corp. is SEC registered, therefore there is nothing to be disclosed in this
section.
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