Overview
Assets Under Management: $175 million
Headquarters: OVERLAND PARK, KS
High-Net-Worth Clients: 57
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $75,000 | 1.50% |
| $10 million | $150,000 | 1.50% |
| $50 million | $750,000 | 1.50% |
| $100 million | $1,500,000 | 1.50% |
Clients
Number of High-Net-Worth Clients: 57
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 67.84
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 524
Discretionary Accounts: 524
Regulatory Filings
CRD Number: 328005
Last Filing Date: 2025-02-11 00:00:00
Website: https://mokanwealth.com
Form ADV Documents
Primary Brochure: FORM ADV PART 2A (2025-07-17)
View Document Text
Item 1: Cover Page
MOKAN Wealth Management Inc.
14221 Metcalf Ave #150
Overland Park, Kansas 66223
Form ADV Part 2A – Firm Brochure
(913) 257-3991
Dated July 17, 2025
This Brochure provides information about the qualifications and business practices of MOKAN Wealth
Management Inc., “MOKAN”. If you have any questions about the contents of this Brochure, please contact us at
(913) 257-3991. 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.
MOKAN Wealth Management Inc. is registered as an Investment Adviser with the U.S. Securities Exchange
Commission (“SEC”). Registration of an Investment Adviser does not imply any level of skill or training.
Additional information about MOKAN is available on the SEC’s website at www.adviserinfo.sec.gov, which
can be found using the firm’s identification number, 328005.
MOKAN Wealth Management Inc. maintains liability insurance coverage for its investment advisory services. If
requested, proof of professional liability insurance coverage shall be provided within 30 days of request.
1
Item 2: Material Changes
Material Changes:
Items 17: The firm has updated the language in this section to clarify the firm’s proxy voting policy.
•
Future Changes
From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices,
changes in regulations, and routine annual updates as required by the securities regulators. Either this
complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client
annually and if a material change occurs in the business practices of MOKAN Wealth Management Inc.
At any time, you may view the current Disclosure Brochure online at the SEC's Investment Adviser
Public Disclosure website at http://www.adviserinfo.sec.gov by searching for our firm name or by our
CRD number 328005.
You may also request a copy of this Disclosure Brochure at any time, by contacting us at (913) 257-
3991.
2
Item 3: Table of Contents
Contents
Item 1: Cover Page
1
Item 2: Material Changes
2
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Fees and Compensation
6
Item 6: Performance-Based Fees and Side-By-Side Management
8
Item 7: Types of Clients
8
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
8
Item 9: Disciplinary Information
11
Item 10: Other Financial Industry Activities and Affiliations
11
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
11
Item 12: Brokerage Practices
12
Item 13: Review of Accounts
13
Item 14: Client Referrals and Other Compensation
14
Item 15: Custody
14
Item 16: Investment Discretion
14
Item 17: Voting Client Securities
15
Item 18: Financial Information
15
3
Item 4: Advisory Business
Description of Advisory Firm
MOKAN Wealth Management Inc. is registered as an Investment Adviser with the U.S. Securities Exchange
Commission (“SEC”). Kyle Hammerschmidt is the principal owner of MOKAN Wealth Management Inc. As of
December 31, 2024, MOKAN Wealth Management Inc reports $174,727,504 in discretionary Assets Under
Management.
Types of Advisory Services
Investment Management Services (MOKAN Wealth Management manages accounts)
We are in the business of managing individually tailored investment portfolios. Our firm provides continuous
advice to a client regarding the investment of Client funds based on the individual needs of the Client. Through
personal discussions in which goals and objectives based on a client’s particular circumstances are established, we
develop a client’s personal investment policy or an investment plan with an asset allocation target and create and
manage a portfolio based on that policy and allocation targets. We will also review and discuss a client’s prior
investment history, as well as family composition and background.
Account supervision is guided by the stated objectives of the Client (e.g., maximum capital appreciation, growth,
income, or growth, and income), as well as tax considerations. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in
Item 5 of this brochure.
Financial Planning Services
Clients work one-on-one with MOKAN Wealth Management to develop and implement a personalized financial
plan. MOKAN Wealth Management will monitor the plan, recommend any changes and ensure the plan is up to
date. Clients may elect to participate in Ongoing Financial Planning or limited duration Financial Plan Creation
engagements. The fees for each of these services are outlined in Item 5 below. Clients enrolled in our investment
management service do not pay a fee for ongoing comprehensive financial planning in addition to what they are
paying for the investment management services.
Ongoing Financial Planning Services
Ongoing financial planning involves an evaluation of a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining
aspect of financial planning is that through the financial planning process, all questions, information, and analysis
will be considered as they affect and are affected by the entire financial and life situation of the Client. Clients
purchasing this service will receive annual household tax reports and a monthly electronic report, providing the
Client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. The
adviser will meet with the Client to review the financial plan and outline the corresponding action plan. At the
client’s request there will be a full review of this plan every 6-12 months to ensure its accuracy and ongoing
appropriateness.
In general, the financial plan will address any or all of the following areas of concern. The Client and advisor will
work together to select specific areas to cover. These areas may include, but are not limited to, the following:
4
● Income Planning: We will conduct a review of your income and expenses to determine your current
surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce
expenses if they exceed your income. Advice may also be provided on which debts to pay off first based
on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend
what we believe to be an appropriate cash reserve that should be considered for emergencies and other
financial goals, along with a review of accounts (such as money market funds) for such reserves, plus
strategies to save desired amounts.
● Employee Benefits Optimization: We will provide review and analysis as to whether the client, as an
employee, is taking the maximum advantage possible of their employee benefits. If the client is a business
owner, we will consider and/or recommend the various benefit programs that can be structured to meet
both business and personal retirement goals.
● Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will
identify what clients plan to accomplish, what resources will be needed to make it happen, how much
time will be needed to reach the goal, and how much the client should budget for the goals.
● Retirement Planning: Our retirement planning services typically include projections of your likelihood
of achieving your financial goals, typically focusing on financial independence as the primary objective.
For situations where projections show less than the desired results, we may make recommendations,
including those that may impact the original projections by adjusting certain variables (e.g., working
longer, saving more, spending less, taking more risk with investments). If you are near retirement or
already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of
running out of money or having to adversely alter spending during your retirement years.
● Insurance: Review of existing policies to ensure proper coverage for life, health, disability, and long-
term care.
●
Investment Analysis: This may involve developing an asset allocation strategy to meet clients’ financial
goals and risk tolerance, providing information on investment vehicles and strategies, reviewing
employee stock options, as well as assisting clients in establishing their own investment accounts at a
selected broker/dealer or custodian. The strategies and types of investments we may recommend are
further discussed in Item 8 of this brochure.
● Tax-Efficient Planning Strategies: Advice may include ways to minimize current and future income
taxes as a part of your overall financial planning picture. For example, we may make recommendations on
which type of account(s) or specific investments should be owned based in part on their “tax efficiency,”
with the consideration that there is always a possibility of future changes to federal, state or local tax laws
and rates that may impact your situation.
To the extent MOKAN Wealth Management feels the level of tax expertise needed exceeds MOKAN
Wealth Management’s knowledge and/or abilities, we will recommend that clients consult with another
qualified tax professional before initiating any tax planning strategy. To that end, we may provide clients
with contact information for accountants or attorneys who specialize in this area if clients wish to hire
someone for such purposes. With clients’ approval, we will participate in meetings or phone calls
between clients and their chosen external tax professional.
● Estate Planning: This usually includes an analysis of the client’s exposure to estate taxes and current
estate plan which may include whether the client has a will, powers of attorney, trusts and other related
documents. Our advice also typically includes ways for the client to minimize or avoid future estate taxes
5
by implementing appropriate estate planning strategies such as the use of applicable trusts. We always
recommend that the client consults with a qualified attorney when the client initiates, updates or
completes estate planning activities. We may provide the client with contact information for attorneys
who specialize in estate planning when the client wishes to hire an attorney for such purposes. From time-
to-time, we will participate in meetings or phone calls between the client and their attorney with the
client’s approval or request.
Ongoing Financial Planning Services for High-Net-Worth Clients
Ongoing financial planning is also available for clients with high-complexity planning needs. Clients who would
qualify for this service would have more than $10 million in net worth, are required to file more than one
Schedule K-1 annually, and are small business owners.
Clients purchasing this service will receive annual household tax reports and a monthly electronic report,
providing the Client with a detailed financial plan designed to achieve his or her stated financial goals and
objectives. The adviser will meet with the Client to review the financial plan and outline the corresponding action
plan. At the client’s request there will be a full review of this plan every 6-12 months to ensure its accuracy and
ongoing appropriateness.
Financial Plan Creation
The one-time Financial Plan Creation service may involve, at the client’s request, the preparation of a written
financial plan covering specific topics or a comprehensive financial plan. When providing financial planning
services, MOKAN’s role is to find ways to help the clients understand the client’s overall financial situation and
help the client set financial objectives. Financial planning is based on the individual goals, objectives, time
horizon, and risk tolerance of each client. Plans may include, but are not limited to, the following: Income
Planning, Employee Benefits Optimization, Financial Goals, Retirement Planning, Insurance Planning,
Investment Analysis, Tax-Efficient Planning Strategies, and Estate Planning.
Client Tailored Services and Client Imposed Restrictions
We offer the same suite of services to all of our clients. However, specific Client financial plans and their
implementation are dependent upon the Client Investment Plan which outlines each Client’s current situation
(income, tax levels, and risk tolerance levels) and is used to construct a Client specific plan to aid in the selection
of a portfolio that matches restrictions, needs, and targets.
Wrap Fee Programs
We do not participate in wrap fee programs.
Item 5: Fees and Compensation
Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing the
investment advisory contract, the investment advisory contract may be terminated by the Client within five (5)
business days of signing the contract without incurring any advisory fees. How we are paid depends on the type of
advisory service we are performing. Please review the fee and compensation information below.
Ongoing Financial Planning & Investment Management Fees
Our standard advisory fee is based on the market value of the assets under management and is calculated as
follows: The annual fees are negotiable, pro-rated, and paid in arrears on a monthly basis based on the average
daily balance of the assets of the previous month. The annual advisory fee ranges between 1% and 1.5% of the
6
market value of all assets under management. No increase in the annual fee shall be effective without agreement
from the Client by signing a new agreement or amendment to their current advisory agreement. Ongoing financial
planning is included at no additional cost for all assets under management. Financial planning for assets not under
management of the firm will be charged an additional fee for either Ongoing Financial Planning or a Financial
Plan Creation.
We calculate period-end account values after all dividends settle in the account. Therefore, the account value used
to calculate advisory fees may differ from that of the custodial account statement. Our billing invoice will indicate
the total account value used to calculate the advisory fee.
Advisory fees are directly debited from Client accounts. Accounts initiated or terminated during a month will be
charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be
terminated with written notice at least 15 calendar days in advance. Since fees are paid in arrears, no refund will
be needed upon termination of the account.
Ongoing Financial Planning
Ongoing Financial Planning consists of an ongoing fee that is paid monthly, in arrears, at the rate of $500 - $750
per month. The fee may be negotiable in certain cases. Fees for this service may be paid through AdvicePay. The
term of this Agreement shall commence on the Effective Date and shall continue until either party gives the other
party written notice of termination in which case termination shall be effective within 5 business days. Upon
termination of any agreement, the fee will be prorated and billed to the Client.
Ongoing Financial Planning Services for High-Net-Worth Clients
This service consists of an ongoing fee that is paid monthly, in arrears, at the rate of $2,000 - $5,000 per month.
The fee may be negotiable in certain cases. Fees for this service may be paid through AdvicePay. The term of this
Agreement shall commence on the Effective Date and shall continue until either party gives the other party written
notice of termination in which case termination shall be effective within 5 business days. Upon termination of any
agreement, the fee will be prorated and billed to the Client.
Financial Plan Creation Fees
Financial Planning Creation engagements are offered for a fee of $2,500 - 3,500. The fee may be negotiable in
certain cases with the total fee due at the completion of the engagement. In the event of early termination by the
Client, any fees for the hours already worked will be due. Fees for this service may be paid by AdvicePay. The
term of this Agreement shall commence on the Effective Date and shall continue until the delivery of the
completed financial plan or until either party gives the other party written notice of termination, in which case
termination shall be effective within 5 business days.
Other Types of Fees and Expenses
Fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be
incurred by the Client. Clients may incur certain charges imposed by custodians, brokers, and other third parties
such as custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual fund and exchange-
traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees,
and commissions are exclusive of and in addition to our fee, and we shall not receive any portion of these
commissions, fees, and costs.
Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for Client’s
transactions and determining the reasonableness of their compensation (e.g., commissions).
7
Item 6: Performance-Based Fees and Side-By-
Side Management
We do not offer performance-based fees and do not engage in side-by-side management.
Item 7: Types of Clients
We provide financial planning and portfolio management services to individuals and high net-worth individuals,.
We do not have a minimum account size requirement.
Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss
Our primary methods of investment analysis are fundamental, technical, cyclical and charting analysis.
Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s
financial statements, details regarding the company’s product line, the experience, and expertise of the company’s
management, and the outlook for the company’s industry. The resulting data is used to measure the true value of
the company’s stock compared to the current market value. The risk of fundamental analysis is that the
information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which
may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental
analysis may not result in favorable performance.
Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick
sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will
develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods
will presumably occur in the future. Even where major trends develop, outside factors like government intervention
could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into
price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method
may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements,
establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method
may underperform other trading methods when fundamental factors dominate price moves within a given market.
Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based
upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between
long-term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy
and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the
changing value of securities that would be affected by these changing trends.
Passive Investment Management
8
We primarily practice passive investment management. Passive investing involves building portfolios that are
composed of various distinct asset classes. The asset classes are weighted in a manner to achieve the desired
relationship between correlation, risk, and return. Funds that passively capture the returns of the desired asset classes
are placed in the portfolio. The funds that are used to build passive portfolios are typically index mutual funds or
exchange-traded funds.
Passive investment management is characterized by low portfolio expenses (i.e. the funds inside the portfolio have
low internal costs), minimal trading costs (due to infrequent trading activity), and relative tax efficiency (because
the funds inside the portfolio are tax efficient and turnover inside the portfolio is minimal).
In contrast, active management involves a single manager or managers who employ some method, strategy or
technique to construct a portfolio that is intended to generate returns that are greater than the broader market or a
designated benchmark.
Material Risks Involved
All investing strategies we offer involve risk and may result in a loss of your original investment which you
should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities, and any other
investment or security. Material risks associated with our investment strategies are listed below.
Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a
general market decline, reducing the value of the investment regardless of the operational success of the issuer’s
operations or its financial condition.
Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended.
Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations
are often more volatile and less liquid than investments in larger companies. Small and medium cap companies
may face a greater risk of business failure, which could increase the volatility of the Client’s portfolio.
Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A
high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in
the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s
performance.
Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be
more volatile than at other times. Under certain market conditions, we may be unable to sell or liquidate
investments at prices we consider reasonable or favorable or find buyers at any price.
Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of
investment. From time to time these strategies may be subject to greater risks of adverse developments in such
areas of focus than a strategy that is more broadly diversified across a wider variety of investments.
Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall
below par value or the principal investment. The opposite is also generally true: bond prices generally rise when
interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price
changes. Most other investments are also sensitive to the level and direction of interest rates.
Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the
securities’ claim on the issuer’s assets and finances.
Inflation: Inflation may erode the buying power of your investment portfolio, even if the dollar value of your
investments remains the same.
9
Risks Associated with Securities
Apart from the general risks outlined above which apply to all types of investments, specific securities may have
other risks.
Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or
restructuring could lose all value. A slower-growth or recessionary economic environment could have an adverse
effect on the price of all stocks.
Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and
repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively,
investors can purchase other debt securities, such as zero coupon bonds, which do not pay current interest, but
rather are priced at a discount from their face values and their values accrete over time to face value at maturity.
The market prices of debt securities fluctuate depending on factors such as interest rates, credit quality, and
maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest
rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk.
Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the
banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely
affected by downturns in the U.S. and foreign economies or changes in banking regulations.
Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the
construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds.
However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return
to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds
carries the same general risks as investing in bonds in general. Those risks include interest rate risk, reinvestment
risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk.
Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions.
Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the
following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii)
the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares
may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the
exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices)
halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the
Clients invest.
Mutual Funds When a Client invests in open-end mutual funds or ETFs, the Client indirectly bears its
proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur
higher expenses, many of which may be duplicative. In addition, the Client's overall portfolio may be affected by
losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund
(such as the use of derivatives).
Alternative Investments Investing in alternative investments and/or strategies will not be suitable for all
investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling
securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential
illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities,
such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s
concentration in the real estate industry.
10
Item 9: Disciplinary Information
On April 8, 2024, MOKAN entered into a consent agreement and order (“order”) with the Missouri Securities
Division of the Office of Secretary of State, Enforcement Section. MOKAN is alleged to have transacted business
as an Investment Adviser with Missouri resident clients without being registered or exempt from registration in
Missouri. MOKAN agreed to pay a total administrative assessment of $26,286.55.
Item 10: Other Financial Industry Activities and
Affiliations
No MOKAN employee is registered, or have an application pending to register, as a broker-dealer or a registered
representative of a broker-dealer.
No MOKAN employee is registered, or have an application pending to register, as a futures commission
merchant, commodity pool operator or a commodity trading advisor.
MOKAN does not have any related parties. As a result, we do not have a relationship with any related parties.
MOKAN only receives compensation directly from Clients. We do not receive compensation from any outside
source. We do not have any conflicts of interest with any outside party.
Recommendations or Selections of Other Investment Advisers
MOKAN does not recommend Outside Managers to manage client accounts.
Item 11: Code of Ethics, Participation or
Interest in Client Transactions and Personal
Trading
As a fiduciary, our firm and its associates have a duty of utmost good faith to act solely in the best interests of
each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard
on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected
basis of all of our dealings. The firm also accepts the obligation not only to comply with the mandates and
requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and
professionally responsible manner in all professional services and activities.
Code of Ethics Description
This code does not attempt to identify all possible conflicts of interest, and literal compliance with each of its
specific provisions will not shield associated persons from liability for personal trading or other conduct that violates
a fiduciary duty to advisory Clients. A summary of the Code of Ethics' Principles is outlined below.
Integrity - Associated persons shall offer and provide professional services with integrity.
●
● Objectivity - Associated persons shall be objective in providing professional services to Clients.
11
● Competence - Associated persons shall provide services to Clients competently and maintain the necessary
knowledge and skill to continue to do so in those areas in which they are engaged.
● Fairness - Associated persons shall perform professional services in a manner that is fair and reasonable to
Clients, principals, partners, and employers, and shall disclose conflict(s) of interest in providing such
services.
● Confidentiality - Associated persons shall not disclose confidential Client information without the specific
consent of the Client unless in response to proper legal process, or as required by law.
● Professionalism - Associated persons' conduct in all matters shall reflect the credit of the profession.
● Diligence - Associated persons shall act diligently in providing professional services.
We periodically review and amend our Code of Ethics to ensure that it remains current, and we require all firm
access persons to attest to their understanding of and adherence to the Code of Ethics at least annually. Our firm
will provide a copy of its Code of Ethics to any Client or prospective Client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
None among our firm, its associates, or any related person is authorized to recommend to a Client or to effect a
transaction for a Client that involves any security in which our firm or a related person has a material financial
interest, such as in the capacity as an underwriter, adviser to the issuer, etc.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to
Clients for their accounts. In an effort to reduce or eliminate certain conflicts of interest involving the firm or
personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable
securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance
of the transaction in an account, and we maintain the required personal securities transaction records per
regulation.
Trading Securities At/Around the Same Time as Client’s Securities
From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the
same time as Clients. We will not trade non-mutual fund securities 5 days prior to the same security for Clients.
Item 12: Brokerage Practices
Factors Used to Select Custodians and/or Broker-Dealers
MOKAN Wealth Management Inc. does not have any affiliation with Broker-Dealers. Specific custodian
recommendations are made to the Client based on their need for such services. We recommend custodians based
on the reputation and services provided by the firm.
1. Research and Other Soft-Dollar Benefits
While MOKAN does not receive formal soft dollar benefits other than execution from broker/dealers in connection
with client securities transactions, the Firm does receive some economic benefits through its participation in their
programs. These benefits are typically not available to retail account holders with these firms. Further, these benefits
are generally not contingent on the number of accounts, number of transactions or amount of revenue to the
brokerage/custodial firms and are available to any investment advisor using their custody and execution. These
benefits include the following products and services which are provided without cost or at a discount: Issues such
as costs passed on through broker-dealer and/or clearing entity costs and fees for things MOKAN might benefit
12
from such arrangements, such as company and/or vendor provided meetings have no bearing on the clients’ costs.
The firm's use of these benefits is intended to comply with the requirements of Section 28(e) of the Securities
Exchange Act of 1934. Section 28(e) provides a “safe harbor” for investment managers who use commissions or
transaction fees paid by their advised accounts to obtain investment research services that provide lawful and
appropriate assistance to the manager in performing investment decision-making responsibilities. Specific benefits
provided to the Firm through the firm’s custodial relationships are outlined below.
2. Brokerage for Client Referrals
We receive no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
We recommend that a client use Adviser’s broker of choice (Altruist). Should the client indicate that they would
prefer not to use Altruist, then we reserve the right to decide not to provide AUM services for the client.
The Custodian and Brokers We Use (Altruist)
MOKAN Wealth Management offers investment advisory services through the custodial platform offered by
Altruist Financial LLC (“Altruist”), an unaffiliated SEC-registered broker dealer and FINRA/SIPC member.
Custody, clearing and execution services are provided by Altruist Financial LLC as a self-clearing broker-dealer.
MOKAN Wealth Management’s clients establish brokerage accounts through Altruist. We maintain an
institutional relationship with Altruist whereby Altruist provides certain benefits to us, including a fully digital
account opening process, a variety of available investments, and integration with software tools that can benefit us
and our clients. We are not affiliated with Altruist. Altruist does not supervise MOKAN Wealth Management, its
agents, activities, or its regulatory compliance.
Aggregating (Block) Trading for Multiple Client Accounts
Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares
to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance or the amount or structure of
management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we
combine orders, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may
participate in block trading with your accounts; however, they will not be given preferential treatment.
Item 13: Review of Accounts
Kyle Hammerschmidt, Owner and CCO of MOKAN Wealth Management Inc., will work with clients to obtain
current information regarding their assets and investment holdings and will review this information as part of our
financial planning services. MOKAN Wealth Management does not provide to clients specific reports, other than
financial plans.
Client accounts under MOKAN Wealth Management’s ongoing investment management service will be reviewed
regularly on a quarterly basis by Kyle Hammerschmidt, Owner and CCO. The account is reviewed with regards to
the client’s investment policies and risk tolerance levels. Events that may trigger a special review would be
unusual performance, additions or deletions of client-imposed restrictions, excessive draw-down, volatility in
performance or buy and sell decisions from the firm or per client's needs.
13
Clients will receive trade confirmations from the broker(s) for each transaction in their accounts as well as
monthly or quarterly statements and annual tax reporting statements from their custodian showing all activity in
the accounts, such as receipt of dividends and interest.
MOKAN Wealth Management will not provide written reports to investment advisory clients.
Item 14: Client Referrals and Other
Compensation
We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our
Clients. Nor do we, directly or indirectly, compensate any person who is not advisory personnel for Client
referrals.
Item 15: Custody
MOKAN does not accept custody of Client funds except in the instance of withdrawing Client fees.
For Client accounts in which MOKAN directly debits their advisory fee:
i. MOKAN will send a copy of its invoice to the custodian at the same time that it sends the Client a copy.
ii.
iii.
The custodian will send at least quarterly statements to the Client showing all disbursements for the account,
including the amount of the advisory fee.
The Client will provide written authorization to MOKAN, permitting them to be paid directly for their
accounts held by the custodian.
Clients should receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that
holds and maintains Client's investment assets. We urge you to carefully review such statements and compare such
official custodial records to the account statements or reports that we may provide to you. Our statements or reports
may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies
of certain securities.
Item 16: Investment Discretion
For those Client accounts where we provide Investment Management Services, we maintain discretion over Client
accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold.
Investment discretion is explained to Clients in detail when an advisory relationship has commenced. At the start
of the advisory relationship, the Client will execute a Limited Power of Attorney, which will grant our firm
discretion over the account. This means that the Adviser is authorized, without consulting the Client in advance,
to buy, sell, and trade in stocks, bonds, mutual funds, index funds, exchange-traded funds, and other securities
and/or contracts relating to the same, in order to invest the Portfolio in accordance with the Client's IPS. Clients
may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors.
Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the Client.
14
Item 17: Voting Client Securities
We do not vote Client proxies. Therefore, Clients maintain exclusive responsibility for: (1) voting proxies, and (2)
acting on corporate actions pertaining to the Client’s investment assets. The Client shall instruct the Client’s
qualified custodian to forward to the Client copies of all proxies and shareholder communications relating to the
Client’s investment assets.
Clients will receive proxy materials directly from the account custodian and should direct any questions as
instructed in the specific proxy matter.
Item 18: Financial Information
Registered Investment Advisers are required in this Item to provide you with certain financial information or
disclosures about our financial condition. We have no financial commitment that impairs our ability to meet
contractual and fiduciary commitments to Clients, and we have not been the subject of a bankruptcy proceeding.
We do not have custody of Client funds or securities or require or solicit prepayment of more than $1,200 in fees
per Client six months in advance.
15