Retirementadvice | Jka

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure March 2026 1251 N. Manassero St., Suite 405A Anaheim, CA 92807 www.jackkeeter.com Firm Contact: Eric Domingues Chief Compliance Officer This brochure provides information about the qualifications and business practices of RetirementAdvice | JKATM (“JKA”) If you have any questions about the contents of this brochure, please contact our firm at (714) 779-9200 or by email at eric@jackkeeter.com. The information in this brochure has not been approved or verified by any State Securities Authority. Additional information about JKA also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #153803. Please note that the use of the term “registered investment adviser” and description of JKA and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees.  Item 2: Material Changes. RetirementAdvice | JKA is required to make clients aware of information that has changed since the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients can then determine whether to review the brochure in its entirety or to contact us with questions about the changes. Since our last annual amendment was filed, we have the following material changes to report: Eric Domingues has been named Chief Compliance Officer of the firm. ADV 2A: Firm Brochure Page 2 RetirementAdvice | JKA  Item 3: Table of Contents. Item 2: Material Changes. ..................................................................................................................................................... 2 Item 3: Table of Contents. .................................................................................................................................................... 3 Item 4: Advisory Business. .................................................................................................................................................. 4 Item 5: Fees and Compensation........................................................................................................................................ 7 Item 6: Performance-Based Fees and Side-By-Side Management. ..................................................................... 9 Item 7: Types of Clients. ....................................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss. ............................................................. 9 Item 9: Disciplinary Information. ................................................................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations. ........................................................................... 12 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. ..... 12 Item 12: Brokerage Practices. ......................................................................................................................................... 13 Item 13: Review of Accounts............................................................................................................................................ 16 Item 14: Client Referrals and Other Compensation. .............................................................................................. 17 Item 15: Custody. .................................................................................................................................................................. 18 Item 16: Investment Discretion. ..................................................................................................................................... 19 Item 17: Voting Client Securities. ................................................................................................................................... 19 Item 18: Financial Information. ...................................................................................................................................... 19 ADV 2A: Firm Brochure Page 3 RetirementAdvice | JKA  Item 4: Advisory Business. RetirementAdvice | JKA is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. We specialize in asset management and financial planning and consulting. Our firm is a corporation formed in the State of California. We have been in business as an investment adviser since 2011 and are wholly owned by Jack Keeter. Types of Advisory Services Offered. Asset Management. We emphasize continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), mutual funds and other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, we review the portfolio at least quarterly and if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Our firm utilizes the sub-advisory services of a third-party investment advisory firm to aid in the implementation of an investment portfolio designed by our firm. Before selecting a third-party manager, our firm will ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific securities or other investments in connection with this service. We will provide initial due diligence on the manager and ongoing reviews of their management of client accounts. To assist in the selection of a third-party manager, our firm will gather client information pertaining to financial situation, investment objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will periodically review third party manager reports provided to the client at least annually. Our firm will contact clients from time to time in order to review their financial situation and objectives; communicate information to third party managers as warranted; and, assist the client in understanding and evaluating the services provided by the third party money manager. Clients will be expected to notify our firm of any changes in their financial situation, investment objectives, or account restrictions that could affect their financial standing. Financial Planning and Consulting. We provide a variety of financial planning and consulting services to individuals, families, and other clients regarding the management of their financial resources based upon an analysis of client’s ADV 2A: Firm Brochure Page 4 RetirementAdvice | JKA  current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Our written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create, or revise wills or trusts, obtain, or revise insurance coverage, commence, or alter retirement savings, or establish education or charitable giving programs. It should also be noted that we refer clients to an accountant, attorney, or other specialist, as necessary for non-advisory-related services. For written financial planning engagements, we provide our clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our clients with a written summary of our observations and recommendations as the process is less formal than our planning service. Plans or consultations are typically completed within six (6) months of the client signing a contract with us, assuming that all the information and documents we request from the client are provided to us promptly. Clients should be aware that a conflict of interest may exist between our firm and the client, as some recommendations may result in the compensation of our representatives. Clients are under no obligation to act upon our recommendation and if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through our firm. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring, and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. • Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. ADV 2A: Firm Brochure Page 5 RetirementAdvice | JKA  • Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation, and tolerance for risk. • Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Tailoring of Advisory Services. We offer individualized investment advice to asset management clients. Additionally, we offer general investment advice to clients utilizing our firm’s financial planning and consulting services. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. However, restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Participation in Wrap Fee Programs. Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management. We manage $267,334,728 on a discretionary basis as of December 31, 2025. ADV 2A: Firm Brochure Page 6 RetirementAdvice | JKA  Item 5: Fees and Compensation. Compensation of Our Advisory Services. Asset Management. Assets Under Management Annual Percentage of Assets Charge $1,000,000 plus 1.00% $500,000 - $999,999 1.25% $250,000 - $499,999 1.50% $100,000 - $249,999 1.75% $0.00 - $99,999 (Minimum of $100,000 per household) 1.99% Fees to be assessed will be outlined in the advisory agreement to be signed by the client. Annualized fees are billed on a pro-rata basis quarterly in arrears based on the account value on the final business day of the billing period. Fees are negotiable and will be deducted from client account(s). There are some instances where an alternative asset may be priced once per year and not calculated on a quarterly basis. Management fees will be based on the latest available value and fees calculated on alternative assets held outside the custodian will be deducted from the account held at Schwab. Unless otherwise agreed to in writing, these fees shall be assessed on cash and cash equivalents. In rare cases, our firm will agree to directly invoice. Fees are negotiable on an individual basis. As part of this process, Clients understand the following: • The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements, including the amount of the advisory fees paid to our firm; • Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and • If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Clients utilizing the third-party management services of Zacks Investment Management, Inc. will be charged a separate fee that is in addition to our fee quoted above. For the Zacks Investment Management, Inc. equity portfolios this fee will be 28 basis points annually, and for the Zacks Investment Management, Inc. exchange traded fund (ETF) portfolios this will be 18 basis points annually. This fee shall be debited directly by Zacks and charged quarterly in arrears. ADV 2A: Firm Brochure Page 7 RetirementAdvice | JKA  Financial Planning and Consulting. We charge on an hourly or flat fee basis for financial planning and consulting services. The total estimated fee, as well as the ultimate fee that we charge you, is based on the scope and complexity of our engagement with you. Our hourly fees are $500 for financial advisors and $75 for administrative time. Flat fees generally range from $750 to $5,000. We require a retainer of fifty percent (50%) of the ultimate financial planning or consulting fee with the remainder of the fee directly billed to you and due to us within thirty (30) days of your financial plan being delivered or consultation rendered to you. In all cases, we will not require a retainer exceeding $1,200 when services cannot be rendered within 6 (six) months. *Fees are negotiable on an individual basis. Retirement Plan Consulting: Our Retirement Plan Consulting services are billed as a fee based on the percentage of Plan assets under management. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Fees based on a percentage of managed Plan assets will not exceed 1.99%. The fee-paying arrangements will be determined on a case-by- case basis and will be detailed in the signed consulting agreement. Other Types of Fees & Expenses. Clients will incur transaction fees for trades executed by their chosen custodian via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Charles Schwab & Co., Inc. (“Schwab”) does not charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination & Refunds. We charge our advisory fees quarterly in arrears. In the event that you wish to terminate our services, you need to contact us in writing and state that you wish to terminate our services. Upon receipt of your letter of termination, we will proceed to close out your account and bill for the remaining advisory fees due. ADV 2A: Firm Brochure Page 8 RetirementAdvice | JKA  Commissionable Securities Sales. We do not sell securities for a commission. Item 6: Performance-Based Fees and Side-By-Side Management. We do not charge performance fees to our clients. Item 7: Types of Clients. We have the following types of clients: • Individuals; • High Net Worth Individuals; • Pension and Profit-Sharing Plans; and Our requirements for opening and maintaining accounts or otherwise engaging us: • We require a minimum account balance of $250,000 for our asset management service. Generally, this minimum account balance requirement is negotiable and may be modified at the discretion of management. • We generally charge a minimum fee of $750 for written financial plans. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss. Methods of Analysis. Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. ADV 2A: Firm Brochure Page 9 RetirementAdvice | JKA  Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies & Asset Classes. Long-term purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Real Estate Investment Trusts (“REITs”). REITs primarily invest in real estate or real estate-related loans. Equity REITs own real estate properties, while mortgage REITs hold construction, development and/or long-term mortgage loans. Changes in the value of the underlying property of the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory requirements, such as those relating to the environment, all can affect the values of REITs. Both types of REITs are dependent upon management skill, the cash flows generated by their holdings, the real estate market in general, and the possibility of failing to qualify for any applicable pass-through tax treatment or failing to maintain any applicable exemptive status afforded under relevant laws. ADV 2A: Firm Brochure Page 10 RetirementAdvice | JKA  Alternative Investments. Hedge funds, commodity pools, non-public Real Estate Investment Trusts (“REITs”), Real Estate Delaware Statutory Trusts, Opportunity Zone Funds, Business Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees and may require “capital calls” which would require additional investment. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. Risk of Loss. Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have. Description of Material, Significant or Unusual Risks. We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to asset management, as applicable. Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited market in which they trade. This can create a substantial delay in the receipt of proceeds from an investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Item 9: Disciplinary Information. There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. ADV 2A: Firm Brochure Page 11 RetirementAdvice | JKA  Item 10: Other Financial Industry Activities and Affiliations. Our firm is also registered as an insurance agency, doing business as JKA Insurance Agency and Investment Adviser Representatives of our firm are licensed insurance agents. In such a capacity, we may recommend, on a fully disclosed basis, the purchase of insurance-related products. Our firm and representatives may receive the normal commissions for insurance sales in their separate roles as insurance agents and agency. A conflict of interest may arise as these commissionable insurance product sales may create an incentive to recommend products based on the compensation they may earn. To minimize this conflict of interest, they will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics. Clients are not obligated to purchase these products. Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading. We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers, and employees for their personal accounts. To monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all our associates. Furthermore, our firm has established a Code of Ethics which applies to all our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. ADV 2A: Firm Brochure Page 12 RetirementAdvice | JKA  Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. See Item 11A of this Brochure. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. To minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. See Item 11A of this Brochure. Item 12: Brokerage Practices. Selecting a Brokerage Firm. We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, these: • Ability to maintain the confidentiality of • Execution facilitation services provided trading intentions • Record keeping services provided • Timeliness of execution • Custody services provided • Timeliness and accuracy of trade • Frequency and correction of trading confirmations errors • Liquidity of the securities traded • Ability to access a variety of market • Willingness to commit capital venues • Ability to place trades in difficult market • Expertise as it relates to specific environments securities • Research services provided • Financial condition • Ability to provide investment ideas • Business reputation With this in consideration, our firm has an arrangement with Charles Schwab & Co., Inc. (“Schwab”), registered broker-dealer, Member SIPC, which provides our firm with Schwab’s “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support our firm in conducting business and in serving the best interests of our clients but that may benefit our firm. ADV 2A: Firm Brochure Page 13 RetirementAdvice | JKA  Soft Dollars. Schwab makes certain research and brokerage services available at no additional cost to our firm. These services include certain research and brokerage services, including research services obtained by Schwab directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab to our firm may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab to our firm in the performance of our investment decision-making responsibilities. Our firm does receive some “eligible” products and services under safe harbor as determined under the Securities and Exchange Act, Section 28(e). These products and services include: national, regional or investment adviser specific educational events; professional compliance; legal and business consulting; publications and conferences on practice management; information technology; business succession; employee benefits providers; human capital consultants; insurance; and marketing. Additionally, this includes any compensation limited to lunches, air flights or hotels received from attending a company’s due diligence meeting. While, as a fiduciary, our firm endeavors to act in its clients’ best interests, our recommendation may be based in part on the benefit to our firm of the availability of some of the foregoing products and services and other arrangements, and not solely on the nature, cost, or quality of custody and brokerage services, which may create a potential conflict of interest. Our firm examined this potential conflict of interest and have determined that the relationship is in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. Client Brokerage Commissions. We do not use client brokerage commissions to obtain research or other products or services. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As a result of receiving the services discussed in 12A(1)a of this Firm Brochure for no additional cost, we may have an incentive to continue to use or expand the use of Schwab’s services. Our firm examined this potential conflict of interest when we chose to enter into the relationship with Schwab and we have determined that the relationship is in the best interest of our firm’s clients and satisfies our client obligations, including our duty to seek best execution. Schwab charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are ADV 2A: Firm Brochure Page 14 RetirementAdvice | JKA  charged for individual equity and debt securities transactions). Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by Schwab may be higher or lower than those charged by other custodians and broker-dealers. Our clients may pay a commission to Schwab that is higher than another qualified broker dealer might charge to affect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit or all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the investment research products and services that may be obtained by our firm will generally be used to service all our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. We do not acquire client brokerage commissions (or markups or markdowns). Client Transactions in Return for Soft Dollars. We do not receive any soft dollar relationships and do not direct client transactions to a particular broker-dealer in return for soft dollar benefits. Brokerage for Client Referrals. Our firm does not engage in the practice of directing client brokerage to compensate or otherwise reward brokers for client referrals. Directed Brokerage. We do not limit or restrict our clients’ authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are affected. ADV 2A: Firm Brochure Page 15 RetirementAdvice | JKA  Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, we will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Client-Directed Brokerage. We allow clients to direct brokerage outside our recommendation. However, we may be unable to achieve the most favorable execution of client transactions. Client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Aggregation of Purchase or Sale. We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the affected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration, and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts. We review accounts on at least a quarterly basis for our clients subscribing to Asset Management services. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. ADV 2A: Firm Brochure Page 16 RetirementAdvice | JKA  Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we meet with clients who subscribe to the following services: Asset Management. As also mentioned in Item 13A of this Brochure, financial planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately contract with us for a post-financial plan meeting or update to their initial written financial plan. Item 14: Client Referrals and Other Compensation. Charles Schwab. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Product Sponsors Our firm occasionally sponsors events in conjunction with our product providers in an effort to keep our clients informed as to the services we offer and the various financial products we utilize. These events are educational in nature and are not dependent upon the use of any specific product. While a conflict of interest may exist because these events are at least partially funded by product sponsors, all funds received from product sponsors are used for the education of our clients. We will always adhere to our fiduciary duty in recommending appropriate investments for our clients. Representatives of our firm will occasionally accept travel expense reimbursement provided by product sponsors in order to attend their educational events. The reimbursement is not directly dependent upon the recommendation of any specific product. Although we may be incentivized to ADV 2A: Firm Brochure Page 17 RetirementAdvice | JKA  recommend products from product sponsors that reimburse our travel, our representatives will always adhere to their fiduciary duty in recommending appropriate investments for our clients. Referral Fees. In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Item 15: Custody. Our firm does not have custody of client funds or securities except for the limited instance of standing letters of authorization outlined below. All our clients receive account statements directly from their qualified custodians at least quarterly upon opening of an account. If our firm decides to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. On February 21, 2017, the SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐ 2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse Advisory Client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, JKA has adopted the following safeguards in conjunction with our custodian: • The Advisory Client provides an instruction to the qualified custodian, in writing, that includes the Advisory Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The Advisory Client authorizes JKA, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The Advisory Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Advisory Client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The Advisory Client has the ability to terminate or change the instruction to the Advisory Client’s qualified custodian. • JKA has no authority or ability to designate or change the identity of the third party, the ADV 2A: Firm Brochure Page 18 RetirementAdvice | JKA  address, or any other information about the third party contained in the Advisory Client’s instruction. • JKA maintains records showing that the third party is not a related party of JKA or located at the same address as JKA. • The Advisory Client’s qualified custodian sends the Advisory Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion. Clients have the option of providing our firm with investment discretion on their behalf, pursuant to a signed investment advisory client agreement. By granting investment discretion, we are authorized to execute securities transactions, which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be affected. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. Item 17: Voting Client Securities. We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write, or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information. Our firm is not required to provide financial information in this Brochure because: • Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. • Our firm does not take custody of client funds or securities • Our firm does not have a financial condition that is likely to impair out ability to meet contractual commitments. • Our firm has never been the subject of a bankruptcy proceeding. ADV 2A: Firm Brochure Page 19 RetirementAdvice | JKA