Overview

Assets Under Management: $150 million
Headquarters: WHITE BEAR TOWNSHIP, MN
High-Net-Worth Clients: 68
Average Client Assets: $2 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (KOOB WEALTH MANAGEMENT ADV PART 2A APPENDIX 1)

MinMaxMarginal Fee Rate
$0 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $100,000 1.00%
$50 million $500,000 1.00%
$100 million $1,000,000 1.00%

Clients

Number of High-Net-Worth Clients: 68
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 90.50
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 320
Non-Discretionary Accounts: 320

Regulatory Filings

CRD Number: 154830
Last Filing Date: 2025-01-29 00:00:00
Website: https://lpl.com

Form ADV Documents

Additional Brochure: KOOB WEALTH MANAGEMENT ADV PART 2A AND 2B (2025-09-09)

View Document Text
Item 1 – Cover Page Koob Wealth Management, LLC 4517 Allendale Drive White Bear Township, MN 55127 651-330-4996 Date of Disclosure Brochure: September 2025 This disclosure brochure provides information about the qualifications and business practices of Koob Wealth Management, LLC (also referred to as I, me and Koob Wealth Management throughout this disclosure brochure). If you have any questions about the contents of this disclosure brochure, please contact Michael P. Koob at 651-330-4996 or michael.koob@lpl.com. The information in this disclosure brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Koob Wealth Management is also available on the Internet at www.adviserinfo.sec.gov. You can view my firm’s information on this website by searching for Koob Wealth Management, LLC or my firm’s CRD number 154830. *Registration as an investment adviser does not imply a certain level of skill or training. **Although Koob Wealth Management is referred to as I or me throughout this brochure for your convenience, please understand that any engagement described under this brochure will be made with the legal entity of Koob Wealth Management, LLC. Item 2 – Material Changes Since our last ADV Annual Amendment was filed in January 2025 the following material changes have been made to this disclosure brochure: • In July 2025 the firm amended the description of our advisory services. Please refer to Item 4- Advisor Business for more specific information. • In September 2025 the firm added a discretionary trading option to our Asset management Services. Please refer to Item 16 – Investment Discretion for more specific information. I will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after my firm’s fiscal year ends. My firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time I will also offer or provide a copy of the most current disclosure brochure. I may also provide other ongoing disclosure information about material changes as necessary. Item 3 – Table of Contents Item 1 – Cover Page ..................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 5 Introduction ............................................................................................................................................... 5 Description of Advisory Services .............................................................................................................. 5 Koob Asset Management Program ............................................................................................................... 6 Newsletters ................................................................................................................................................... 7 Limits Advice to Certain Types of Investments ......................................................................................... 7 Participation in Wrap Fee Programs ......................................................................................................... 8 Tailor Advisory Services to Individual Needs of Clients ........................................................................... 8 Client Assets Managed by Koob Wealth Management ............................................................................ 8 Item 5 – Fees and Compensation ................................................................................................................. 8 Asset Management Services .................................................................................................................... 9 Koob Asset Management Program ............................................................................................................. 10 Financial Planning & Consulting Services .............................................................................................. 11 Fees for Financial Planning Services ..................................................................................................... 11 Fees for Consulting Services .................................................................................................................. 11 Other Fee Terms for Financial Planning & Consulting Services ............................................................ 12 Newsletters ............................................................................................................................................. 13 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 13 Item 7 – Types of Clients ............................................................................................................................ 14 Minimum Investment Amounts Required ................................................................................................ 14 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 14 Methods of Analysis ................................................................................................................................ 14 Investment Strategies ............................................................................................................................. 15 Primarily Recommend One Type of Security ......................................................................................... 15 Risk of Loss ............................................................................................................................................ 15 Item 9 – Disciplinary Information ................................................................................................................. 16 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 16 Registered Representative of a Broker-Dealer ....................................................................................... 17 Insurance Agent ...................................................................................................................................... 17 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 17 Code of Ethics Summary ........................................................................................................................ 17 Affiliate and Employee Personal Securities Transactions Disclosure .................................................... 18 Item 12 – Brokerage Practices .................................................................................................................... 18 Directed Brokerage ................................................................................................................................. 19 Broker/Dealer Affiliation (LPL Financial) ................................................................................................. 19 Soft Dollar Benefits ................................................................................................................................. 20 Handling Trade Errors ............................................................................................................................ 20 Block Trading Policy ............................................................................................................................... 21 Agency Cross Transactions .................................................................................................................... 21 Item 13 – Review of Accounts .................................................................................................................... 21 Account Reviews and Reviewers ........................................................................................................... 21 Statements and Reports ......................................................................................................................... 21 Item 14 – Client Referrals and Other Compensation .................................................................................. 22 Item 15 – Custody ....................................................................................................................................... 22 Item 16 – Investment Discretion ................................................................................................................. 22 Item 17 – Voting Client Securities ............................................................................................................... 23 Class Action Lawsuits ................................................................................................................................. 23 Item 18 – Financial Information ................................................................................................................... 23 Customer Privacy Policy Notice .................................................................................................................. 24 FORM ADV PART 2B BROCHURE SUPPLEMENT – Michael P. Koob ................................................... 25 Item 4 – Advisory Business Koob Wealth Management is an investment adviser registered with the State of Minnesota and is a limited liability company (LLC) formed under the laws of the State of Minnesota. • Leslee Koob is a Member and Owner of Koob Wealth Management. Leslee Koob owns 50.00% of Koob Wealth Management. Full details of my education and business background are provided at Item 19 of this Disclosure Brochure. • Michael P. Koob is the Managing Member, Chief Compliance Officer (CCO) and Investment Advisor Representative of Koob Wealth Management. Michael Koob owns 50.00% of Koob Wealth Management. Full details of my education and business background are provided at Item 19 of this Disclosure Brochure. • Koob Wealth Management has been registered as an investment adviser since November 2010. Introduction The investment advisory services of Koob Wealth Management are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Koob Wealth Management (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of Koob Wealth Management. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Koob Wealth Management before I can provide you the services described below. Asset Management Services – Koob Wealth Management offers asset management services, which involves Koob Wealth Management providing you with continuous and ongoing supervision over your specified accounts. You must appoint my firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by me based on your financial situation, investment objectives and risk tolerance. I actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. I will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying me of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, I will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. I am always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct me not to purchase certain securities. It is important that you understand that I manage investments for other clients and may give them advice or take actions for them or for my personal accounts that is different from the advice I provide to you or actions taken for you. I am not obligated to buy, sell or recommend to you any security or other investment that I may buy, sell or recommend for any other clients or for my own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that I manage. I strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by my firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to my attention will be allocated in any particular manner. If I obtain material, non-public information about a security or its issuer that I may not lawfully use or disclose, I have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Koob Asset Management Program I am the sponsor of the Koob Asset Management Program (“KAMP Program”), a wrap fee asset management program developed through an arrangement using LPL Financial Corporation’s (“LPL”) Strategic Wealth Management platform. Through the KAMP Program, I provide investment management services, including providing continuous investment advice to and making investments for you based on your individual needs. Through this service, I offer a customized and individualized investment program. A specific asset allocation strategy and suitability profile is crafted to focus on your specific goals and objectives. The IPS defines your risk tolerance and investment objective. Your information should be updated regularly, but at a minimum every 2 years. KAMP Program accounts are custodied at LPL in its capacity as a registered broker/dealer, member FINRA/SIPC. LPL is also an investment advisor registered with the SEC, but does not serve as an investment advisor for you through the KAMP Program. LPL provides clearing, custody and other brokerage services for accounts established through the KAMP Program. Therefore, you are required to establish a brokerage account(s) through LPL’s Strategic Wealth Management platform. Separate accounts are maintained for you, and you retain all rights of ownership of you accounts (e. g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). KAMP Program accounts allow you to authorize me to purchase and sell, on either a discretionary or a non-discretionary basis, portfolios consisting of securities and investments. I may limit my discretion with respect to your account and the securities eligible to be purchased for your account. (See, Limits Advice to Certain Types of Investments under Item 4 - Advisory Business, relative to possible securities and investments utilized. See Item 16 - Investment Discretion, for information concerning discretionary authority.) With discretionary authority, I make all decisions to buy, sell or hold securities, cash or other investments in the managed account in my sole discretion without consulting with you before implementing any transactions. You must provide me with written authorization to exercise this discretionary authority. Discretionary authority is limited. I do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to me by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to me so long as the limitations are specifically set forth or included as an attachment to the client agreement. (Please see Item 16, Investment Discretion, in the separate Koob Wealth Management, LLC Disclosure Brochure for additional information concerning discretionary authority.) During any month that there is activity in the KAMP Program account, you receive a monthly account statement from LPL showing account activity as well as positions held in the account at month end. Additionally, you receive a confirmation of each transaction that occurs within the KAMP Program account unless the transaction is the result of a systematic purchase, redemption or exchange. You also receive a detailed quarterly report showing performance, positions, and activity. All account data and statements are also available on-line through the account view portal through LPL. Financial Planning & Consulting Services - Koob Wealth Management offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. I provide full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios Review, and Asset Allocation. When providing financial planning and consulting services, my role is to find ways to help you understand your overall financial situation and help you set financial objectives. Written financial plans prepared by me do not include specific recommendations of individual securities. I also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. I offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. I also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking my advice or consultation on. My financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement my financial planning and consulting recommendations. To the extent that you would like to implement any of my investment recommendations through Koob Wealth Management or retain Koob Wealth Management to actively monitor and manage your investments, you must execute a separate written agreement with Koob Wealth Management for our asset management services. Newsletters Koob Wealth Management occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Limits Advice to Certain Types of Investments Koob Wealth Management provides investment advice on the following types of investments: • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Securities Traded Over-the-Counter Although I generally provide advice only on the products previously listed, I reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not my typical investment strategy to attempt to time the market, but I may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. I may modify my investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Participation in Wrap Fee Programs Koob Wealth Management offer services exclusively through a wrap fee program. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), I will receive all or a portion of the fee charged. Tailor Advisory Services to Individual Needs of Clients Koob Wealth Management’s advisory services are always provided based on your individual needs. This means, for example, that when I provide asset management services, you are given the ability to impose restrictions on the accounts I manage for you, including specific investment selections and sectors. I work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. My financial planning and consulting services are always provided based on your individual needs. When providing financial planning and consulting services, I work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. I will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with my investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Koob Wealth Management The amount of clients’ assets managed by Koob Wealth Management totaled $150,348,339 as of January 31, 2024. $0 are managed on a discretionary basis and $150,348,339 are managed on a non- discretionary basis. Item 5 – Fees and Compensation In addition to the information provided in Item 4 – Advisory Business, this section provides additional details regarding my firm’s services along with descriptions of each service’s fees and compensation arrangements. It should be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between you and Koob Wealth Management. Asset Management Services Fees charged for my asset management services are charged based on a percentage of assets under management, billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is billed. The asset management services continue in effect until terminated by either party (i.e., Koob Wealth Management or you) by providing written notice of termination to the other party. Any prepaid, unearned fees will be promptly refunded by Koob Wealth Management to you. Fee refunds will be determined on a pro rata basis using the number of days services are actually provided during the final period. Fees charged for my asset management services are negotiable based on the type of client, the complexity of the client's situation, the composition of the client's account (i.e., equities versus mutual funds), the potential for additional account deposits, the relationship of the client with the investment adviser representative, and the total amount of assets under management for the client. The annual fee for asset management services will be between 0.20% and 1.00% There is a minimum account size of $15,000. Koob Wealth Management believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, my annual investment advisory fee may be higher than that charged by other investment advisers offering similar services/programs. In addition to my compensation, you may also incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). You can choose how to pay your investment advisory fees. The investment advisory fees can be deducted from your account and paid directly to my firm by the qualified custodian(s) of your account or you can pay my firm upon receipt of a billing notice sent directly to you. If you choose to have the investment advisory fees deducted from your account, you must authorize the qualified custodian(s) of your account to deduct fees from your account and pay such fees directly to Koob Wealth Management. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Koob Wealth Management does not receive any portion of such commissions or fees from you or the qualified custodian. In addition, you may incur certain charges imposed by third parties other than Koob Wealth Management in connection with investments made through your account including, but not limited to, mutual fund sales loads, 12(b)-1 fees and surrender charges, variable annuity fees and surrender charges, IRA and qualified retirement plan fees, and charges imposed by the qualified custodian(s) of your account. Management fees charged by Koob Wealth Management are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. Koob Asset Management Program The annual investment advisory fee charged will vary up to a maximum of 1.00% of the assets held in the account and is negotiable depending on the market value of the account, asset types, complexity of your portfolio, your financial situation and trading activity. The annual fee is divided and paid quarterly in advance through a direct debit to your account. LPL is responsible for calculating and debiting all fees from your accounts. You must provide LPL with written authorization to debit advisory fees from your accounts and pay the fees to Koob Wealth Management. Fees are based on the account's asset value as of the last business day of the prior calendar quarter. Fees for accounts opened at any time other than the beginning of a quarter are prorated based on the number of days remaining in the initial quarter. Prior to engaging Koob Wealth Management to provide investment management services, you are required to enter into a formal investment advisory agreement with me setting forth the terms and conditions, including the amount of investment advisory fees, under which I manage your assets and a also separate custodial/clearing agreement with LPL. A KAMP Program account is a wrap account, meaning you do not pay transaction charges associated with trade execution. The minimum account size to open any KAMP Program account is $15,000, although exceptions may be granted upon request. Factors considered when granting an exception include the total value of the overall engagement, the types of assets in the account, the time and resources expended on the services and the relationship between the adviser providing services and the client. You may incur certain charges imposed by third parties other than Koob Wealth Management in connection with investments made through the account including, but not limited to, 12b-1 fees and surrender charges, and IRA and qualified retirement plan fees. My management fees (which include transaction and execution fees charged by LPL are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. I, in my separate capacity as registered representatives of LPL, may retain a portion of the commissions charged to you. These commissions may include 12b-1 fees, surrender charges and IRA and qualified retirement plan fees. The KAMP Program may cost you more or less than if the assets were held in a traditional brokerage account. In a brokerage account, you are charged commissions for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If you plan to follow a buy and hold investment strategy for the account or do not wish to purchase ongoing investment advice or management services, you should consider opening a brokerage account rather than a KAMP Program account. Either party may terminate the agreement for services at any time. If services are terminated within five business days of executing the agreement, services are terminated without penalty and a full refund of all fees paid in advance is provided. If services are terminated after the initial five day period, I provide you with a prorated refund of fees paid in advance. The refund is based on the number of days service is actually provided during the final billing period. Termination is effective from the time the other party receives written notification or such other time as may be mutually agreed upon, subject to the settlement of transactions in progress and the final refund of advisory fees. There is no penalty charge on termination. Financial Planning & Consulting Services Fees charged for my financial planning and consulting services are negotiable based upon the type of client, the services requested, the complexity of the client's situation, the composition of the client's account, other advisory services provided and the relationship of the client and the investment adviser representative. The following are the fee arrangements available for financial planning and consulting services offered by Koob Wealth Management. Fees for Financial Planning Services Koob Wealth Management provides financial planning services under a fixed fee arrangement. A mutually agreed upon fixed fee is charged for financial planning services under this arrangement. There is a range in the amount of the fixed fee charged by Koob Wealth Management for financial planning services. The minimum fixed fee is generally $1,000, and the maximum fixed fee is generally no more than $10,000. The amount of the fixed fee for your engagement is specified in your financial planning agreement with Koob Wealth Management. Upon completion and delivery of the financial plan, the fixed fee is considered earned by Koob Wealth Management and any unpaid amount is immediately due. To the extent Koob Wealth Management provides you with general investment recommendations as part of the financial planning services and you implement such investment recommendations through Koob Wealth Management, I may offer in my agreement with you to waive or reduce the fees for financial planning services. The financial planning services terminate upon delivery of the written financial plan or upon either party providing the other party with written notice of termination. You may terminate the financial planning services within five (5) business days of entering into an agreement with Koob Wealth Management without penalty or fees due. If you terminate the financial planning services after five (5) business days of entering into an agreement, you will be responsible for immediate payment of any financial planning services performed by Koob Wealth Management prior to the receipt by Koob Wealth Management of your notice. For financial planning services performed by Koob Wealth Management under a fixed fee arrangement, you will pay Koob Wealth Management a pro- rated fixed fee equivalent to the percentage of work completed by Koob Wealth Management as determined by Koob Wealth Management. In the event that there is a remaining balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be refunded by Koob Wealth Management to you. Fees for Consulting Services Koob Wealth Management provides consulting services under a fixed fee arrangement. A mutually agreed upon fixed fee is charged for consulting services under this arrangement. There is a range in the amount of the fixed fee charged by Koob Wealth Management for consulting services. The minimum fixed fee for consulting services will be $1,000, and maximum fixed fee for consulting services will be generally no more than $15,000. The amount of the fixed fee for your engagement is specified in your consulting agreement with Koob Wealth Management. At my sole discretion, you may be required to pay in advance one-half of the fixed fee at the time you execute an agreement with Koob Wealth Management. At no time will Koob Wealth Management require payment of more than $500 in fees more than six months in advance. The fixed fee will be considered earned by Koob Wealth Management and any unpaid amount immediately due from Client upon the completion of the consulting services. The fixed fee will be considered earned by Koob Wealth Management and immediately due from Client upon completion of the consulting services. To the extent Koob Wealth Management provides you with general investment recommendations as part of my consulting services and you implement such investment recommendations through us, Koob Wealth Management at my discretion may offer to waive or reduce the fee for certain consulting services. The one-time consulting services will terminate upon completion of the consultation or either party providing the other party with written notice. The “as-needed” consulting services will terminate upon either you or Koob Wealth Management providing written notice of termination to the other party. You may terminate the consulting services within five (5) business days of entering into an agreement with Koob Wealth Management without penalty or fees due. If you terminate the consulting services after five (5) business days of entering into an agreement with Koob Wealth Management, you will be responsible for immediate payment of any consulting work performed by Koob Wealth Management prior to the receipt by Koob Wealth Management of your notice. For consulting services performed by Koob Wealth Management under a fixed fee arrangement, you will pay Koob Wealth Management a pro-rated fixed fee equivalent to the percentage of work completed by Koob Wealth Management as determined by Koob Wealth Management. In the event that there is a remaining balance of any fees paid in advance after the deduction of fees from the final invoice, those remaining proceeds will be refunded by Koob Wealth Management to you. Other Fee Terms for Financial Planning & Consulting Services You may pay the investment advisory fees owed for the financial planning services by submitting payment directly (for example, by check) or having the fee deducted from an existing investment account. If you elect to pay by automatic deduction from an existing investment account, you will provide written authorization to Koob Wealth Management for such charge. You should notify Koob Wealth Management within ten (10) days of receipt of an invoice if you have questions about or dispute any billing entry. To the extent Koob Wealth Management engages an outside professional (i.e. attorney, independent investment adviser or accountant) while providing financial planning and consulting services to you, Koob Wealth Management will be responsible for the payment of the fees for the services of such an outside professional, and you will not be required to reimburse Koob Wealth Management for such payments. To the extent that you personally engage such an outside professional, you will be responsible for the payment of the fees for the services of such an outside professional, and Koob Wealth Management will not be required to reimburse Client for such payments. Fees for the services of an outside professional (i.e. attorney, independent investment adviser or accountant) will be in addition to and separate from the fees charged by Koob Wealth Management, and you will be responsible for the payment of the fees for the services of such an outside professional. In no event will the services of an outside professional be engaged without your express approval. All fees paid to Koob Wealth Management for services are separate and distinct from the commissions, fees and expenses charged by insurance companies associated with any disability insurance, life insurance and annuities subsequently acquired by you. If you sell or liquidate certain existing securities positions to acquire any insurance or annuity, you may also pay a commission and/or deferred sales charges in addition to the financial planning and consulting fees paid to Koob Wealth Management and any commissions, fees and expenses charged by the insurance company for subsequently acquired insurance and/or annuities. All fees paid to Koob Wealth Management for advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each mutual fund’s prospectus. These fees will generally include a management fee, other fund expenses and a possible distribution fee. If the fund also imposes sales charges, you may pay an initial or deferred sales charge. If you retain Koob Wealth Management to implement the recommendations provided under this service, Koob Wealth Management may recommend load or no-load mutual funds that charge you 12(b)-1 fees. Your investment adviser representative may receive a portion of these 12(b)-1 fees in his or her separate capacity as a registered representative of a securities broker-dealer. The receipt of 12(b)-1 fees could represent an incentive for Koob Wealth Management or your investment adviser representative to recommend mutual funds with 12(b)-1 fees or higher 12(b)-1 fees over mutual funds with no 12(b)-1 fees or lower 12(b)-1 fees and therefore creates a conflict of interest. All fees paid to Koob Wealth Management for financial planning and consulting services are separate and distinct from the commissions charged by a broker-dealer or asset management fees charged by an investment adviser to implement such recommendations. If you elect to implement the recommendations of Koob Wealth Management through our other investment advisory programs, Koob Wealth Management may waive or reduce a portion of the investment advisory fees for such investment advisory program(s). Any reduction will be at the discretion of your investment adviser representative and disclosed to you prior to contracting for additional investment advisory services. It should be noted that lower fees for comparable services may be available from other sources. Newsletters Newsletters are provided to clients and prospective clients free of charge. Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Item 6 is not applicable to this Disclosure Brochure because I do not charge or accept performance-based fees. Item 7 – Types of Clients Koob Wealth Management generally provides investment advice to the following types of clients: • Individuals • High net worth individuals • Trusts, estates, or charitable organizations You are required to execute a written agreement with Koob Wealth Management specifying the particular advisory services in order to establish a client arrangement with Koob Wealth Management. Minimum Investment Amounts Required The minimum account size to open any KAMP Program account is $15,000, although exceptions may be granted upon request. Factors considered when granting an exception include the total value of the overall engagement, the types of assets in the account, the time and resources expended on the services and the relationship between the adviser providing services and the client. The minimum fixed fee generally charged for financial planning services on a fixed fee basis is $1,000. The minimum fixed fee generally charged for consulting services is $1,000. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Koob Wealth Management uses the following methods of analysis in formulating investment advice: Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. There are risks involved in using any analysis method. To conduct analysis, Koob Wealth Management gathers information from financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses and filings with the SEC, and company press releases. Investment Strategies Koob Wealth Management uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases. Investments held at least a year. Short term purchases. Investments sold within a year. Primarily Recommend One Type of Security I do not primarily recommend one type of security to clients. Instead, I recommend any product that may be suitable for each client relative to that client’s specific circumstances and needs. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, my firm is unable to represent, guarantee, or even imply that my services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through my investment management program, as described below: • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • ETF and Mutual Fund Risk – When investing in a an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with my firm varies with the success and failure of my investment strategies, research, analysis and determination of portfolio securities. If my investment strategies do not produce the expected returns, the value of the investment will decrease. Item 9 – Disciplinary Information Item 9 is not applicable to this Disclosure Brochure because there are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of my business or integrity. Item 10 – Other Financial Industry Activities and Affiliations Koob Wealth Management is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. I am an independent registered investment registered adviser and only provide investment advisory services. I am not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while I do not sell products or services other than investment advice, our representatives may sell other products or provide services outside of their role as investment adviser representatives with us. Registered Representative of a Broker-Dealer Our representatives are also registered representatives of LPL Financial, a securities broker-dealer. You may work with your investment adviser representative in his or her separate capacity as a registered representative of LPL Financial. When acting in his or her separate capacity as a registered representative, your investment adviser representative may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, your investment adviser representative may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of our representatives in this separate capacity or to use LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you select our representatives to implement securities transactions in their separate capacity as registered representatives, they must use LPL Financial. Prior to effecting any such transactions, you are required to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may be higher or lower than those charged by other broker/dealers. In addition, the registered representatives may also receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that you maintain the mutual fund investment. Insurance Agent You may work with your investment adviser representative in his or her separate capacity as an insurance agent. When acting in his or her separate capacity as an insurance agent, the investment adviser representative may sell, for commissions, general disability insurance, life insurance, annuities, and other insurance products to you. As such, your investment adviser representative in his or her separate capacity as an insurance agent, may suggest that you implement recommendations of Koob Wealth Management by purchasing disability insurance, life insurance, annuities, or other insurance products. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Summary An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Koob Wealth Management has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. Koob Wealth Management’s Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Koob Wealth Management requires its supervised persons to consistently act in your best interest in all advisory activities. Koob Wealth Management imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. This section is intended to provide a summary description of the Code of Ethics of Koob Wealth Management. If you wish to review the Code of Ethics in its entirety, you should send me a written request and upon receipt of your request, I will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Koob Wealth Management or associated persons of the firm may buy or sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Koob Wealth Management that all persons associated in any manner with my firm must place clients’ interests ahead of their own when implementing personal investments. Koob Wealth Management and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with my firm unless the information is also available to the investing public upon reasonable inquiry. I am now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, I have developed written supervisory procedures that include personal investment and trading policies for my representatives, employees and their immediate family members (collectively, associated persons): • Associated persons cannot prefer their own interests to that of the client. • Associated persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Associated persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. • Associated persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. • Associated persons are discouraged from conducting frequent personal trading. • Associated persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of Koob Wealth Management. Any associated person not observing our policies is subject to sanctions up to and including termination. Item 12 – Brokerage Practices Clients are under no obligation to act on the financial planning recommendations of Koob Wealth Management. If the firm assists in the implementation of any recommendations, I am responsible to ensure that the client receives the best execution possible. Best execution does not necessarily mean that clients receive the lowest possible commission costs but that the qualitative execution is best. In other words, all conditions considered, the transaction execution is in your best interest. When considering best execution, I look at a number of factors besides prices and rates including, but not limited to: • Execution capabilities (e.g., market expertise, ease/reliability/timeliness of execution, responsiveness, integration with my existing systems, ease of monitoring investments) • Products and services offered (e.g., investment programs, back office services, technology, regulatory compliance assistance, research and analytic services) • Financial strength, stability and responsibility • Reputation and integrity • Ability to maintain confidentiality I exercise reasonable due diligence to make certain that best execution is obtained for all clients when implementing any transaction by considering the back office services, technology and pricing of services offered. Directed Brokerage Clients should understand that not all investment advisors require the use of a particular broker/dealer or custodian. Some investment advisors allow their clients to select whichever broker/dealer the client decides. By requiring clients to use a particular broker/dealer, Koob Wealth Management may not achieve the most favorable execution of client transactions and the practice requiring the use of specific broker/dealers may cost clients more money than if the client used a different broker/dealer or custodian. However, for compliance and operational efficiencies, Koob Wealth Management has decided to require my clients to use broker/dealers and other qualified custodians determined by Koob Wealth Management. Broker/Dealer Affiliation (LPL Financial) If you wish to implement my advice you are free to select any broker you wish. If you wish to have me implement the advice in my separate capacity as a registered representative, LPL is used. I am a registered representative of LPL and I am required to use the services of LPL when acting in this capacity. LPL has a wide range of approved securities products for which it performs due diligence prior to selection. LPL’s registered representatives are required to adhere to these products when implementing securities transactions through LPL. Commissions charged for these products may be higher or lower than commissions clients may be able to obtain if transactions were implemented through another broker/dealer. Because I am also a registered representative of LPL, LPL provides compliance support to me. LPL also provides me with back-office operational, technology and other administrative support. If you wish to implement my advice through any of the programs described in this Disclosure Brochure, LPL will be used as the broker/dealer and/or custodian. LPL will be the primary broker/dealer and custodian recommended due to the relationship I have with LPL. I recommend broker/dealers and custodians that I feel provide services in a manner and at a cost that will allow me to meet my duty of best execution. However, I may be limited in the broker/dealer or custodians that I am allowed to use due to my relationship with LPL. LPL may limit or restrict the broker/dealer or custodial platforms for its registered representatives that are also independently licensed due to its duty to supervise the transactions implemented by these individuals. While there is no direct linkage between the investment advice given to you and my recommendation of LPL, economic benefits may be provided to me by LPL that are not provided if you select another broker/dealer or account custodian. These benefits may include: • Negotiated costs for transaction implementation • A dedicated trade desk that services LPL Financial participants exclusively • A dedicated service group and an account services manager dedicated to our accounts • Access to a real-time order matching system • Electronic download of trades, balances and position information • Access, for a fee, to an electronic interface with the account custodian’s software • Duplicate and batched client statements, confirmations and year-end reports Please also see Item 5, Fees and Compensation, for additional information about advisory services and implementing recommendations. Soft Dollar Benefits An investment adviser receives soft dollar benefits from a broker-dealer when the investment adviser receives research or other products and services in exchange for client securities transactions or maintaining an account balance with the broker-dealer. Koob Wealth Management does not have a soft dollar agreement with a broker-dealer or a third-party. Handling Trade Errors Koob Wealth Management has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot always be avoided. Consistent with its fiduciary duty, it is the policy of Koob Wealth Management to correct trade errors in a manner that is in the best interest of the client. In cases where the client causes the trade error, the client is responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the client may not be able to receive any gains generated as a result of the error correction. In all situations where the client does not cause the trade error, the client is made whole and any loss resulting from the trade error is absorbed by Koob Wealth Management if the error is caused by Koob Wealth Management. If the error is caused by the broker-dealer, the broker-dealer is responsible for handling the trade error. If an investment gain results from the correcting trade, the gain remains in the client’s account unless the same error involved other client account(s) that should also receive the gains. It is not permissible for all clients to retain the gain. Koob Wealth Management may also confer with a client to determine if the client should forego the gain (e.g., due to tax reasons). Koob Wealth Management will never benefit or profit from trade errors. Block Trading Policy Investment advisors may elect to purchase or sell the same securities for several clients at approximately the same time when they believe such action may prove advantageous to clients. This process is referred to as aggregating orders, batch trading or block trading. Koob Wealth Management does not engage in block trading. It should be noted that implementing trades on a block or aggregate basis may be less expensive for client accounts; however, it is my trading policy is to implement all client orders on an individual basis. Therefore, I do not aggregate or “block” client transactions. Considering the types of investments I hold in advisory client accounts, I do not believe clients are hindered in any way because I trade accounts individually. This is because I develop individualized investment strategies for clients and holdings will vary. My strategies are primarily developed for the long-term and minor differences in price execution are not material to our overall investment strategy. Agency Cross Transactions My associated persons are prohibited from engaging in agency cross transactions, meaning I cannot act as brokers for both the sale and purchase of a single security between two different clients and cannot receive compensation in the form of an agency cross commission or principal mark-up for the trades. Item 13 – Review of Accounts Account Reviews and Reviewers Managed accounts are reviewed at least quarterly. While the calendar is the main triggering factor, reviews can also be conducted at your request. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by Michael Koob, with reviews performed in accordance with your investment goals and objectives. Our financial planning services terminate upon the presentation of the written plan. Our financial planning and consulting services do not include monitoring the investments of your account(s), and therefore, there is no ongoing review of your account(s) under such services. Statements and Reports For my asset management services, you are provided with transaction confirmation notices and regular quarterly account statements directly from the qualified custodian. Whether reports by an outside money manager are provided to you will depend upon the outside money manager. Financial planning clients do not receive any report other than the written plan originally contracted for and provided by Koob Wealth Management. You are encouraged to always compare any reports or statements provided by me or sub-adviser against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact my firm and the qualified custodian preparing the statement. Item 14 – Client Referrals and Other Compensation Koob Wealth Management does not directly or indirectly compensate any person for client referrals. The only compensation received from advisory services is the fees charged for providing investment advisory services as described in Item 5 of this Disclosure Brochure. Koob Wealth Management receives no other forms of compensation in connection with providing investment advice. Please see Item 5, Fees and Compensation, Item 10, Other Financial Industry Activities and Affiliations and Item 12, Brokerage Practices, for additional discussion concerning other compensation. Item 15 – Custody Koob Wealth Management does not have custody of client funds. LPL Financial will serve as the custodian of client assets on behalf of the Koob Wealth Management. Koob Wealth Management may also provide advisory services on assets held at different third party custodians. Koob Wealth Management urges you to carefully review the statements provided by the custodian and compare such official custodial records to the account statements that may be provided by Koob Wealth Management. LPL Financial as the custodian sends statements at least quarterly to clients showing all disbursements in account including the amount of the advisory fees paid to advisor, the value of client assets upon which advisor’s fee was based, and the specific manner in which advisor’s fee was calculated. Clients provide authorization to LPL Financial permitting advisory fees to be deducted from client advisory account. LPL Financial calculates the advisory fees and deducts them from client’s account every quarter. Item 16 – Investment Discretion When providing asset management services, Koob Wealth Management maintains trading authorization over your Account and can provide management services on either a discretionary basis or non- discretionary basis. When discretionary authority is granted, I will have the authority to determine the type of securities and the amount of securities that can be bought or sold for your portfolio without obtaining your consent for each transaction. However, it is the policy of Koob Wealth Management to consult with you prior to making significant changes in the account even when discretionary trading authority is granted. If you decide to grant trading authorization on a non-discretionary basis, I will be required to contact you prior to implementing changes in your account. Therefore, you will be contacted and required to accept or reject our investment recommendations including: • The security being recommended • The number of shares or units • Whether to buy or sell Once the above factors are agreed upon, I will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, you need to know that if I am not able to reach you or you are slow to respond to my request, it can have an adverse impact on the timing of trade implementations and I may not achieve the optimal trading price. You will have the ability to place reasonable restrictions on the types of investments that may be purchased in your Account. You may also place reasonable limitations on the discretionary power granted to Koob Wealth Management so long as the limitations are specifically set forth or included as an attachment to the client agreement. Item 17 – Voting Client Securities Proxy Voting Koob Wealth Management does not vote proxies on behalf of Clients. I have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; I will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Class Action Lawsuits You retain the right under applicable securities laws to initiate individually a lawsuit or join a class-action lawsuit against the issuer of a security that was held, purchased or sold by or for you. Koob Wealth Management does not initiate such a legal proceeding on behalf of clients and does not provide legal advice to clients regarding potential causes of action against such a security issuer and whether the client should join a class-action lawsuit. I recommend that you seek legal counsel prior to making a decision regarding whether to participate in such a class-action lawsuit. Upon your specific instruction, I may provide assistance to you regarding an investment history related to the security underlying the individual, or class-action, lawsuit and may provide assistance with the completion of this portion of certain class- action paperwork. At no time should such assistance be deemed as a substitute for consulting with legal counsel. Item 18 – Financial Information This Item 18 is not applicable to this brochure. Koob Wealth Management does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. Therefore, I am not required to include a balance sheet for the most recent fiscal year. I am not subject to a financial condition that is reasonably likely to impair my ability to meet contractual commitments to clients. Finally, Koob Wealth Management has not been the subject of a bankruptcy petition at any time. Customer Privacy Policy Notice In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non- affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. Advisor does not share or disclose customer information to non- affiliated third parties except as permitted or required by law or as required by broker/dealer firms with supervisory obligations over certain of Advisor’s activities. Advisor is committed to safeguarding the confidential information of its clients. Advisor holds all personal information provided by clients in the strictest confidence and it is the objective of Advisor to protect the privacy of all clients. Except as permitted or required by law, or as required by broker/dealer firms with supervisory obligations, Advisor does not share confidential information about clients with non-affiliated parties. In the event that there were to be a change in this policy, Advisor will provide clients with written notice and clients will be provided an opportunity to direct Advisor as to whether such disclosure is permissible. To conduct regular business, Advisor may collect personal information from sources such as: • Information reported by the client on applications or other forms the client provides to Advisor • Information about the client’s transactions implemented by others • Information developed as part of financial consultations and analyses To provide related services for client accounts, it is necessary for Advisor to provide access to customer information within the firm and to non-affiliated companies with whom Advisor has entered into agreements. To provide the utmost service, Advisor may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on behalf of Advisor: • • • Information Advisor receives from the client on applications (name, social security number, address, assets, etc.) Information about the client’s transactions with others (account information, payment history, parties to transactions, etc.) Information about a client’s financial products and services transaction with Advisor Since Advisor shares non-public information solely to service its client, Advisor does not disclose any non-public personal information about its customers or former customers to anyone, except as permitted by law. However, Advisor may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. FORM ADV PART 2B BROCHURE SUPPLEMENT – Michael P. Koob Item 1 – Cover Page Michael P. Koob Koob Wealth Management, LLC 4517 Allendale Drive White Bear Township, MN 55127 (651)330-4996 Date of Supplement: September 2025 This brochure supplement provides information about Michael P. Koob that supplements the Koob Wealth Management, LLC. disclosure brochure. You should have received a copy of that brochure. Please contact Michael P. Koob at (651)330-4996 or at michael.koob@lpl.com if you did not receive Koob Wealth Management’s brochure or if you have any questions about the contents of this supplement. Additional information about Michael P. Koob is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2 – Educational Background and Business Experience Michael P. Koob Born 1967, CRD # 2156408 Post-Secondary Educational Background: University of St. Thomas, BA, Business: 1991 Business Background: Koob Wealth Management, Managing Member, Investment Advisor Representative, 09/2010 to Present; LPL Financial Corporation, Registered Representative, 09/2010 to Present UBS Financial Services, Inc, Registered Representative, 08/2006 to 09/2010 Piper Jaffray, Inc, Registered Representative, Investment Advisor Representative, 01/2001 to 08/2006 Item 3 – Disciplinary Information Michael P. Koob has no legal or disciplinary events to report. Item 4 – Other Business Activities Registered Representative of a Broker-Dealer Michael P. Koob is also a registered representative of LPL Financial, a securities broker-dealer. You may work with Michael P. Koob in his separate capacity as a registered representative of LPL Financial. When acting in his separate capacity as a registered representative, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, he may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which Michael P. Koob will receive a commission in his separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use the services of Michael P. Koob in this separate capacity or to use LPL Financial and can select any broker/dealer you wish to implement securities transactions. If you select him to implement securities transactions in his separate capacity as a registered representative, he must use LPL Financial. Prior to effecting any such transactions, you are required to enter into a new account agreement with LPL Financial. The commissions charged by LPL Financial may be higher or lower than those charged by other broker/dealers. In addition, he may also receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that you maintain the mutual fund investment. Insurance Agent Michael P. Koob is independently licensed to sell insurance and annuity products through various insurance companies. When acting in this capacity, Michael P. Koob will receive commissions for selling insurance and annuity products. Michael P. Koob may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect the judgment of Michael P. Koob when recommending products to its clients. While Michael P. Koob endeavors at all times to put the interest of his clients first as a part of AIM Capital’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect Michael P. Koob’ decision making process when making recommendations. Clients are never obligated or required to purchase insurance products from or through Michael P. Koob and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale. Item 5 – Additional Compensation In addition to the description of additional compensation provided in Item 4, Michael P. Koob may receive additional benefits. Although Koob Wealth Management and Michael P. Koob endeavor at all times to put the interest of its clients ahead of its own or those of its officers, directors, or representatives (“affiliated persons”), these arrangements could affect the judgment of Michael P. Koob when recommending investment products. These situations present a conflict of interest that may affect the judgment of affiliated persons including Michael P. Koob. Item 6 – Supervision Michael P. Koob is the Chief Compliance Officer of Koob Wealth Management. He is responsible for overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives. Michael P. Koob can be contacted at (651)330-4996.

Additional Brochure: KOOB WEALTH MANAGEMENT ADV PART 2A APPENDIX 1 (2025-09-09)

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Item 1 – Cover Page Part 2A Appendix 1 Wrap Fee Program Brochure Koob Wealth Management, LLC 4517 Allendale Drive White Bear Township, MN 55127 (651)330-4996 Date of Disclosure Brochure: September 2025 This Wrap Fee Program Brochure provides information about the qualifications and business practices of Koob Wealth Management, LLC (also referred to as I, me and Koob Wealth Management throughout this disclosure brochure). If you have any questions about the contents of this brochure, please contact Michael Koob at 651-330-4996 or michael.koob@lpl.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Koob Wealth Management is also available on the Internet at www.adviserinfo.sec.gov. You can view my firm’s information on this website by searching for Koob Wealth Management, LLC or my firm’s CRD number 154830. *Registration as an investment adviser does not imply a certain level of skill or training. **Although Koob Wealth Management is referred to as I or me throughout this brochure for your convenience, please understand that any engagement described under this brochure will be made with the legal entity of Koob Wealth Management, LLC. 1 Item 2 – Material Changes Since our last ADV Annual Amendment was filed in January 2025, the material changes made to our documents are: • In July 2025 the firm amended the description of our advisory services. Please refer to Item 4- Services Fees and Compensation for more specific information. • In September 2025 the firm added a discretionary trading option to our Asset management Services. Please refer to Item 4 – Services, Fees and Compensation for more specific information. I will ensure that you receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after my firm’s fiscal year ends. My firm’s fiscal year ends on December 31, so you will receive the summary of material changes no later than April 30 each year. At that time, I will also offer or provide a copy of the most current disclosure brochure. I may also provide other ongoing disclosure information about material changes as necessary. 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 – Table of Contents ....................................................................................................................... 3 Item 4 – Services, Fees and Compensation ................................................................................................. 4 Koob Asset Management Program .......................................................................................................... 4 Additional Compensation, Economic and Non-Economic Benefits .......................................................... 6 Item 5 – Account Requirements and Types of Clients .................................................................................. 6 Types of Accounts .................................................................................................................................... 6 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................... 7 Other Advisory Services ........................................................................................................................... 7 Limits Advice to Certain Types of Investments ......................................................................................... 7 Tailor Advisory Services to Individual Needs of Clients ........................................................................... 7 Performance-Based Fees and Side-By-Side Management ..................................................................... 8 Methods of Analysis .................................................................................................................................. 8 Investment Strategies ............................................................................................................................... 8 Risk of Loss .............................................................................................................................................. 9 Voting Client Securities ............................................................................................................................. 9 Item 7 – Client Information Provided to Portfolio Managers ....................................................................... 10 Item 8 - Client Contact with Portfolio Managers ......................................................................................... 10 Item 9 - Additional Information .................................................................................................................... 10 Other Financial Industry Activities and Affiliations .................................................................................. 10 Registered Representative of a Broker-Dealer ....................................................................................... 11 Insurance Agent ...................................................................................................................................... 11 Interest in Client Transactions and Code of Ethics ................................................................................. 11 Affiliate and Employee Personal Securities Transactions Disclosure .................................................... 12 Account Reviews .................................................................................................................................... 12 Account Statements and Reports ........................................................................................................... 12 Client Referrals ....................................................................................................................................... 13 Financial Information .............................................................................................................................. 13 Item 10 –Requirements for State-Registered Advisers .............................................................................. 13 Item 11 - Customer Privacy Policy Notice ................................................................................................... 13 3 Item 4 – Services, Fees and Compensation Koob Wealth Management is an investment adviser registered with the State of Minnesota and is a limited liability company (LLC) formed under the laws of the State of Minnesota. Koob Asset Management Program I am the sponsor of the Koob Asset Management Program (“KAMP Program”), a wrap fee asset management program developed through an arrangement using LPL Financial Corporation’s (“LPL”) Strategic Wealth Management platform. Through the KAMP Program, I provide investment management services, including providing continuous investment advice to and making investments for you based on your individual needs. Through this service, I offer a customized and individualized investment program. A specific asset allocation strategy and suitability profile is crafted to focus on your specific goals and objectives. The IPS defines your risk tolerance and investment objective. Your information should be updated regularly, but at a minimum every 2 years. KAMP Program accounts are custodied at LPL in its capacity as a registered broker/dealer, member FINRA/SIPC. LPL is also an investment advisor registered with the SEC but does not serve as an investment advisor for you through the KAMP Program. LPL provides clearing, custody and other brokerage services for accounts established through the KAMP Program. Therefore, you are required to establish a brokerage account(s) through LPL’s Strategic Wealth Management platform. Separate accounts are maintained for you, and you retain all rights of ownership of you accounts (e. g., the right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). KAMP Program accounts allow you to authorize me to purchase and sell, on either a discretionary or a non-discretionary basis, portfolios consisting of securities and investments. If investment discretion is granted by the client written prior authorization is required. I may limit my discretion with respect to your account and the securities eligible to be purchased for your account. (See, Limits Advice to Certain Types of Investments at Item 6, Portfolio Manager Selection and Evaluation elsewhere in this Disclosure Brochure.) With discretionary authority, I make all decisions to buy, sell or hold securities, cash or other investments in the managed account in my sole discretion without consulting with you before implementing any transactions. You must provide me with written authorization to exercise this discretionary authority. Discretionary authority is limited. I do not have access to your funds and/or securities with the exception of having advisory fees deducted from your account and paid to me by the account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the account custodian. You have the ability to place reasonable restrictions on the types of investments that may be purchased in an account. You may also place reasonable limitations on the discretionary power granted to me so long as the limitations are specifically set forth or included as an attachment to the client agreement. (Please see Item 16, Investment Discretion, in the separate Koob Wealth Management, LLC Disclosure Brochure for additional information concerning discretionary authority.) During any month that there is activity in the KAMP Program account, you receive a monthly account statement from LPL showing account activity as well as positions held in the account at month end. Additionally, you receive a confirmation of each transaction that occurs within the KAMP Program account unless the transaction is the result of a systematic purchase, redemption or exchange. You also receive a 4 detailed quarterly report showing performance, positions, and activity. All account data and statements are also available on-line through the account view portal through LPL. The annual investment advisory fee charged will vary up to a maximum of 1.00% of the assets held in the account and is negotiable depending on the market value of the account, asset types, complexity of your portfolio, your financial situation and trading activity. The annual fee is divided and paid quarterly in advance through a direct debit to your account. LPL is responsible for calculating and debiting all fees from your accounts. You must provide LPL with written authorization to debit advisory fees from your accounts and pay the fees to Koob Wealth Management. Fees are based on the account's asset value as of the last business day of the prior calendar quarter. Fees for accounts opened at any time other than the beginning of a quarter are prorated based on the number of days remaining in the initial quarter. Prior to engaging Koob Wealth Management to provide investment management services, you are required to enter into a formal investment advisory agreement with me setting forth the terms and conditions, including the amount of investment advisory fees, under which I manage your assets and also separate custodial/clearing agreement with LPL. A KAMP Program account is a wrap account. This means you do not pay transaction charges associated with trade execution. The minimum account size to open any KAMP Program account is $15,000, although exceptions may be granted upon request. Factors considered when granting an exception include the total value of the overall engagement, the types of assets in the account, the time and resources expended on the services and the relationship between the adviser providing services and the client. You may incur certain charges imposed by third parties other than Koob Wealth Management in connection with investments made through the account including, but not limited to, 12b-1 fees and surrender charges, and IRA and qualified retirement plan fees. My management fees (which include transaction and execution fees charged by LPL for KAMP Program II accounts) are separate and distinct from the fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses are available in each investment company security’s prospectus. I, in my separate capacity as registered representatives of LPL, may retain a portion of the commissions charged to you. These commissions may include 12b-1 fees, surrender charges and IRA and qualified retirement plan fees. The KAMP Program may cost you more or less than if the assets were held in a traditional brokerage account. In a brokerage account, you are charged commissions for each transaction, and the representative has no duty to provide ongoing advice with respect to the account. If you plan to follow a buy and hold investment strategy for the account or do not wish to purchase ongoing investment advice or management services, you should consider opening a brokerage account rather than a KAMP Program account. When making the determination of whether the advisory program available through Koob Wealth Management is appropriate for your needs, you should bear in mind that fee-based accounts, when compared with commission-based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee-based account arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Factors which affect the total cost include account size, 5 amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax situation. It should also be noted that lower fees for comparable service may be available from other sources. You should discuss the advantages and disadvantages of fee-based and commission-based accounts with your adviser representative. Either party may terminate the agreement for services at any time. If services are terminated within five business days of executing the agreement, services are terminated without penalty and a full refund of all fees paid in advance is provided. If services are terminated after the initial five day period, I provide you with a prorated refund of fees paid in advance. The refund is based on the number of days service is actually provided during the final billing period. Termination is effective from the time the other party receives written notification or such other time as may be mutually agreed upon, subject to the settlement of transactions in progress and the final refund of advisory fees. There is no penalty charge on termination. Additional Compensation, Economic and Non-Economic Benefits I am also a registered representative of LPL, a securities broker-dealer. You may work with me in my separate capacity as a registered representative of LPL. When acting in this separate capacity as a registered representative, I may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, I may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which I will receive a commission in my separate capacity as a registered representative of a securities broker- dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use my services in this separate capacity or to use LPL and can select any broker/dealer you wish to implement securities transactions. If you select me to implement securities transactions in my separate capacity as a registered representative, I must use LPL. Item 5 – Account Requirements and Types of Clients Minimum Account Size The minimum account size to open any KAMP Program account is $15,000, although exceptions may be granted upon request. Factors considered when granting an exception include the total value of the overall engagement, the types of assets in the account, the time and resources expended on the services and the relationship between the adviser providing services and the client. Types of Accounts Koob Wealth Management generally provides investment advice to the following types of clients: Individuals • • High net worth individuals • Trusts, estates, or charitable organizations 6 You are required to execute a written agreement with Koob Wealth Management specifying the particular advisory services in order to establish a client arrangement with Koob Wealth Management. Item 6 – Portfolio Manager Selection and Evaluation I select and review portfolio managers based on many criteria including, but not limited to, performance, holdings, track record, turnover, manager tenure, expense ratio, peer group rating and historical consistency of all of the above. I rely on third party performance calculations. These third party services utilize standard performance calculation methods. I cannot confirm or deny the accuracy of these performance measures but rely on them based on their national reputation and standard methods of calculation. I believe them to be fair and accurate representations but do not verify or confirm their accuracy. I do not act as a portfolio manager for our wrap fee program. I do, however, choose managers with respect to the following: asset class, percentage of portfolio, when to add/subtract them from the portfolio, etc. Managers are chosen based on your best interests. Other Advisory Services In addition to the management services described above, I provide the following services: • Financial Planning & Consulting Services • Newsletters A description of all fee-based investment advisory services that I provide is available in my Form ADV Part 2A Disclosure Brochure. Limits Advice to Certain Types of Investments Koob Wealth Management provides investment advice on the following types of investments: • Mutual Funds • Exchange Traded Funds (ETFs) • Exchange-listed Securities • Securities Traded Over-the-Counter Although I generally provide advice only on the products previously listed, I reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not my typical investment strategy to attempt to time the market, but I may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. I may modify my investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. Tailor Advisory Services to Individual Needs of Clients 7 Koob Wealth Management’s advisory services are always provided based on your individual needs. This means, for example, that when I provide asset management services, you are given the ability to impose restrictions on the accounts I manage for you, including specific investment selections and sectors. I work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. I will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with my investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Performance-Based Fees and Side-By-Side Management Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation of the assets held in a client’s account. Koob Wealth Management does not charge or accept performance-based fees. Methods of Analysis Koob Wealth Management uses the following methods of analysis in formulating investment advice: Fundamental – This is a method of evaluating a security by attempting to measure its intrinsic value by examining related economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the security's value, including macroeconomic factors (like the overall economy and industry conditions) and individually specific factors (like the financial condition and management of a company). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Fundamental analysis is considered to be the opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. The risk associated with fundamental analysis is that it is somewhat subjective. While a quantitative approach is possible, fundamental analysis usually entails a qualitative assessment of how market forces interact with one another in their impact on the investment in question. It is possible for those market forces to point in different directions, thus necessitating an interpretation of which forces will be dominant. This interpretation may be wrong and could therefore lead to an unfavorable investment decision. There are risks involved in using any analysis method. To conduct analysis, Koob Wealth Management gathers information from financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses and filings with the SEC, and company press releases. Investment Strategies Koob Wealth Management uses the following investment strategies when managing client assets and/or providing investment advice: Long term purchases. Investments held at least a year. 8 Short term purchases. Investments sold within a year. Risk of Loss Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, my firm is unable to represent, guarantee, or even imply that my services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated with investing in securities through my investment management program, as described below: • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk. When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You will also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with my firm varies with the success and failure of my investment strategies, research, analysis and determination of portfolio securities. If my investment strategies do not produce the expected returns, the value of the investment will decrease. Voting Client Securities 9 Koob Wealth Management does not vote proxies on behalf of Clients. I have determined that taking on the responsibilities for voting client securities does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities held in Account. You will receive proxies directly from the qualified custodian or transfer agent; I will not provide you with the proxies. You are encouraged to read through the information provided with the proxy-voting documents and make a determination based on the information provided. Item 7 – Client Information Provided to Portfolio Managers Periodically I may need to provide certain financial information about clients to a portfolio manager. This requirement may be necessary when working with an investment that has certain net worth or income requirements. This information may be supplied to the portfolio manager each year as necessary. The information is only provided to establish financial suitability/wherewithal for the specific investment. Item 8 - Client Contact with Portfolio Managers My KAMP Program primarily utilizes pooled investment vehicles which have investment/portfolio managers. These managers are not typically available to my clients for direct contact. I have relationships with those managers’ companies and each provides me with points of contact so that I can obtain important information, updates and analysis necessary and relevant for my portfolio decision making process. Periodically I may be in direct contact with an investment manager to obtain their view on certain market events. This meeting usually does not include clients. Item 9 - Additional Information Disciplinary Information I have no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of my business or the integrity of my management. Other Financial Industry Activities and Affiliations Koob Wealth Management is not and does not have a related person that is a broker/dealer, municipal securities dealer, government securities dealer or broker, an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), another investment adviser or financial planner, a futures commission merchant, commodity pool operator, or commodity trading advisor, a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator of limited partnerships. I am an independent registered investment registered adviser and only provide investment advisory services. I am not engaged in any other business activities and offer no other services except those described in this Disclosure Brochure. However, while I do not sell products or services other than 10 investment advice, I may sell other products or provide services outside of my role as investment adviser representatives with Koob Wealth Management. Registered Representative of a Broker-Dealer I am also a registered representative of LPL, a securities broker-dealer. You may work with me in my separate capacity as a registered representative of LPL. When acting in this separate capacity as a registered representative, I may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to you. As such, I may suggest that you implement investment advice by purchasing securities products through a commission-based brokerage account in addition to or in lieu of a fee-based investment-advisory account. This receipt of commissions creates an incentive to recommend those products for which I will receive a commission in my separate capacity as a registered representative of a securities broker- dealer. Consequently, the objectivity of the advice rendered to you could be biased. You are under no obligation to use my services in this separate capacity or to use LPL and can select any broker/dealer you wish to implement securities transactions. If you select me to implement securities transactions in my separate capacity as a registered representative, I must use LPL. The commissions charged by LPL may be higher or lower than those charged by other broker/dealers. In addition, I am may also receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that you maintain the mutual fund investment. Insurance Agent You may work with your investment adviser representative in his or her separate capacity as an insurance agent. When acting in his or her separate capacity as an insurance agent, the investment adviser representative may sell, for commissions, general disability insurance, life insurance, annuities, and other insurance products to you. As such, your investment adviser representative in his or her separate capacity as an insurance agent, may suggest that you implement recommendations of Koob Wealth Management by purchasing disability insurance, life insurance, annuities, or other insurance products. This receipt of commissions creates an incentive for the representative to recommend those products for which your investment adviser representative will receive a commission in his or her separate capacity as an insurance agent. Consequently, the advice rendered to you could be biased. You are under no obligation to implement any insurance or annuity transaction through your investment adviser representative. Interest in Client Transactions and Code of Ethics An investment adviser is considered a fiduciary and has a fiduciary duty to all clients. Koob Wealth Management has established a Code of Ethics to comply with the requirements of the securities laws and regulations that reflects its fiduciary obligations and those of its supervised persons. The Code of Ethics also requires compliance with federal securities laws. Koob Wealth Management’s Code of Ethics covers all individuals that are classified as “supervised persons”. All employees, officers, directors and investment adviser representatives are classified as supervised persons. Koob Wealth Management requires its supervised persons to consistently act in your best interest in all advisory activities. Koob Wealth Management imposes certain requirements on its affiliates and supervised persons to ensure that they meet the firm’s fiduciary responsibilities to you. The standard of conduct required is higher than ordinarily required and encountered in commercial business. 11 This section is intended to provide a summary description of the Code of Ethics of Koob Wealth Management. If you wish to review the Code of Ethics in its entirety, you should send me a written request and upon receipt of your request, I will promptly provide a copy of the Code of Ethics to you. Affiliate and Employee Personal Securities Transactions Disclosure Koob Wealth Management or associated persons of the firm may buy or sell for their personal accounts, investment products identical to those recommended to clients. This creates a conflict of interest. It is the express policy of Koob Wealth Management that all persons associated in any manner with my firm must place clients’ interests ahead of their own when implementing personal investments. Koob Wealth Management and its associated persons will not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of employment or association with my firm unless the information is also available to the investing public upon reasonable inquiry. I am now and will continue to be in compliance with applicable state and federal rules and regulations. To prevent conflicts of interest, I have developed written supervisory procedures that include personal investment and trading policies for my representatives, employees and their immediate family members (collectively, associated persons): • Associated persons cannot prefer their own interests to that of the client. • Associated persons cannot purchase or sell any security for their personal accounts prior to implementing transactions for client accounts. • Associated persons cannot buy or sell securities for their personal accounts when those decisions are based on information obtained as a result of their employment, unless that information is also available to the investing public upon reasonable inquiry. • Associated persons are prohibited from purchasing or selling securities of companies in which any client is deemed an “insider”. • Associated persons are discouraged from conducting frequent personal trading. • Associated persons are generally prohibited from serving as board members of publicly traded companies unless an exception has been granted to the Chief Compliance Officer of Koob Wealth Management. Any associated person not observing our policies is subject to sanctions up to and including termination. Account Reviews KAMP Program accounts are reviewed at least quarterly but usually on a monthly basis. While the calendar is the main triggering factor, reviews may also be performed due to your specific request, a change in your circumstances and unusual market activity or economic conditions. Absent your specific instructions, accounts are reviewed for accuracy of holdings and to ensure that the portfolios continue to work toward your goals and objectives. Account Statements and Reports You receive account statements at least quarterly directly from LPL, the money manager or the qualified account custodian. I also provide an account summary during review meetings with you. 12 You are encouraged to always compare any reports or statements provided by me or a sub-adviser against the account statements delivered from the qualified custodian. When you have questions about your account statement, you should contact my firm and the qualified custodian preparing the statement. Client Referrals Koob Wealth Management does not directly or indirectly compensate any person for client referrals. The only compensation received from advisory services is the fees charged for providing investment advisory services. Koob Wealth Management receives no other forms of compensation in connection with providing investment advice. Financial Information Koob Wealth Management does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. Therefore, I am not required to include a balance sheet for the most recent fiscal year. I am not subject to a financial condition that is reasonably likely to impair my ability to meet contractual commitments to clients. Finally, Koob Wealth Management has not been the subject of a bankruptcy petition at any time. Item 10 –Requirements for State-Registered Advisers Other than relationships described above, Koob Wealth Management and our management persons do not have a relationship with any issuers of securities. Item 11 - Customer Privacy Policy Notice In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. Advisor does not share or disclose customer information to non-affiliated third parties except as permitted or required by law or as required by broker/dealer firms with supervisory obligations over certain of Advisor’s activities. Advisor is committed to safeguarding the confidential information of its clients. Advisor holds all personal information provided by clients in the strictest confidence and it is the objective of Advisor to protect the privacy of all clients. Except as permitted or required by law, or as required by broker/dealer firms with supervisory obligations, Advisor does not share confidential information about clients with non-affiliated parties. In the event that there were to be a change in this policy, Advisor will provide clients with written notice and clients will be provided an opportunity to direct Advisor as to whether such disclosure is permissible. To conduct regular business, Advisor may collect personal information from sources such as: • • Information reported by the client on applications or other forms the client provides to Advisor Information about the client’s transactions implemented by others 13 • Information developed as part of financial consultations and analyses To provide related services for client accounts, it is necessary for Advisor to provide access to customer information within the firm and to non-affiliated companies with whom Advisor has entered into agreements. To provide the utmost service, Advisor may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on behalf of Advisor: • • • Information Advisor receives from the client on applications (name, social security number, address, assets, etc.) Information about the client’s transactions with others (account information, payment history, parties to transactions, etc.) Information about a client’s financial products and services transaction with Advisor Since Advisor shares non-public information solely to service its client, Advisor does not disclose any non-public personal information about its customers or former customers to anyone, except as permitted by law. However, Advisor may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. 14