Description of Firm Keeler Thomas Management LLC is a registered investment adviser based in Orem, Utah. Our firm is organized as a limited liability company under the laws of the State of Utah. We have been providing investment advisory services since 1987. Richard K. Jones and John L. Unice are our principal owners.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Keeler Thomas Management LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Financial Planning Services Our services typically begin with providing financial planning services whereby we will collect information about your financial situation and provide a financial plan and structured financial planning services. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. Dependent upon the scope of the services to be performed by our firm, the preparation of each plan involves fact gathering, compiling, and analyzing of your liquidity needs, personal needs, insurance needs, risk tolerance, and other financial related information relevant to understanding your unique investment circumstances. Once we have reviewed and analyzed your information, we will deliver a written financial plan to you that is designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. As a part of our financial planning service, we commonly recommend products other than securities. Such products may include various forms of life, and disability insurance, tax-deferred annuities, certificates of deposit, etc. Our firm and our Associated Persons will contract with Insurance Companies to offer the referenced insurance products. Neither our firm, nor our Associated Persons are "captive" agents of any company or agency but remain independent. Companies or products are selected for recommendation based upon your individualized needs and objectives.
We offer a variety of ways in which you can implement your financial plan. These services are listed below. Estate Planning Guru We provide a service through an electronic system called Estate Planning Guru whereby we assist you with the implementation of simple estate plans. We will work with you as needed to coordinate, organize are maintain your estate plan and act as a liaison between you, Estate Planning Guru and any other professionals you hire to implement your estate plan. 4 Wealth Planning Implementation Service We provide advice to you as part of an ongoing Wealth Management service. These services are designed to help you organize your financial situation and invest your assets based on personal criteria and financial goals. Clients purchasing this service receive written recommendations on planning issues that are raised by our firm or that you bring to our attention. We will have periodic discussions with you to identify any changes in your risk tolerance or stated goals and objectives. We will gather required information from copies of client documents and statements and from information supplied by you or by your other advisers. Information gathered includes details on your current financial status, future goals, and attitudes toward risk.
We will advise you on the strategic organization, structure and management of assets, the development of retirement strategies, implementation of your objectives, and/or the coordination of other professionals as needed for the achievement of your financial goals. We provide ongoing access to our staff and will coordinate and orchestrate the efforts of other professionals (legal, tax, accounting etc.) to help you maximize your plan. Wealth Planning Retainer Service After the first year of implementation we offer an ongoing wealth planning retainer service which continues the services provided in the first year and provides continued and more advanced planning as your financial situation changes and grows. Financial Consulting Services We offer financial consulting services that primarily involve advising clients on specific financial- related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation.
Portfolio Management Services We offer discretionary (and in limited cases, non-discretionary) portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to

a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. 5 Portfolio Planning Retainer Services We offer portfolio planning and asset allocation services on a non-discretionary basis. We will assess and prepare investment portfolio strategies utilizing strategic investment and allocation modeling technologies. This includes building a model plan for asset deployment. It also includes recommendations for deploying assets to meet your objectives. We will provide quarterly investment model performance reports allowing for you to monitor your portfolio strategies and the deployment of assets. These services will be provided on a pre-determined basis, such as monthly, quarterly, semi- annually or annually. The frequency of the services provided will be agreed upon between you and our firm and will be detailed in the agreement for services. These services may include a review of your existing portfolio with asset allocation recommendations, management and/or monitoring of a participant's investments in a 401(k) plan, and periodic reporting.
Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. We may provide plan auditing services for a separate fee. These services include review and recommendations covering such areas as: employee fiduciary training, documentation and filing, investment policy statement development, key management training, investment committee training and support, and other activities as deemed necessary by the client. These functions are outside the scope of the investment and portfolio fees outlined separately in this document. Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
6 Types of Investments We offer advice on equity securities, warrants, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, variable life insurance, variable annuities, mutual fund shares, United States government securities, options contracts on securities, money market funds, REITs and ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $321,259,022 in client assets on a discretionary basis, and $17,110,096 in client assets on a non-discretionary basis.