Levine Financial Group offers a variety of advisory services—which include financial planning, consulting,
and investment management services—with a focus on educating, guiding and counseling clients toward
reaching their full financial potential. Prior to Levine Financial Group rendering any of the advisory services
described herein, clients are required to enter into one or more written agreements with Levine Financial
Group setting forth the relevant terms and conditions of the advisory relationship (the “Advisory
Agreement”).
Levine Financial Group or its personnel will provide asset management and investment advisory services
to a new fund managed by Triade Holdings LLC. Triade Holdings LLC is the Managing Member to
KennMar INVST Diversified Income Fund, LLC—a private investment fund formed to invest in and
manage real estate. The detailed terms, strategies, and risks applicable to investors in the fund are described
in the fund’s organizational and offering documents.
Levine Financial Group has been registered as an investment adviser since February 2016 and is wholly
owned by Scott A. Jarred. has been registered as an investment adviser since February 2016 and is wholly
owned by Scott A. Jarred. As of December 31, 2023, Levine Financial Group had $1,347,246,943 of
assets under management, of which $1,083,943,530 was managed on a discretionary basis and
$263,303,413 was managed on a non-discretionary basis. Levine Financial Group provides advisory
services through its investment advisor representatives (“IARs”) and Supervised Persons. Certain IARs and
Supervised Persons have their own business entities whose trade names and logos which they use in
marketing the services they provide through the Firm. Such business entities are generally owned by one
or more IARs and/or Supervised Persons, not the Firm. Levine Financial Group may also maintain
“fictitious names” and/or “doing business as” names which IARs and/or Supervised Persons use in
marketing the services they provide through the Firm. IARs and Supervised Persons are under the
supervision of Levine Financial Group, and the advisory services of the IAR are provided through Levine
Financial Group.
While this brochure generally describes the business of Levine Financial Group, certain sections also
discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or
other persons occupying a similar status or performing similar functions), employees or any other person
who provides investment advice on Levine Financial Group’s behalf and is subject to the Firm’s supervision
or control.
Financial Planning and Consulting Services
Levine Financial Group offers clients a broad range of financial planning and consulting services, which
include any or all of the following functions:
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
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• Business Consulting
• Tax Planning
• Insurance Planning
• Retirement Planning
• Charitable Giving
• Distribution Planning
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While each of these services is available on a stand-alone basis, certain of them can also be rendered in
conjunction or in addition to investment portfolio management as part of a comprehensive wealth
management engagement (described in more detail below). Levine Financial Grouip may offer services
inside these areas including Tax Planning and Business Consulting where third party vendors are used and
paid directly by Levine Financial Group for their services as part of an overall Tax Planning or Business
Consulting engagement. These vendors may perform tasks such as business valuation, tax preparation, and
bookkeeping services. A comprehensive wealth management engagement may include an upfront or
recurring financial planning fee, and an advisory fee, and an investment management fee. Any of the fees
charged can be presented as a fixed fee and/or a fee based on assets under management as agreed to in the
Advisory Agreement.
In performing these services, Levine Financial Group is not required to verify any information received from
the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly
authorized to rely on such information. Levine Financial Group recommends certain clients engage the
Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents
or registered representatives of a broker-dealer and/or other professionals to implement its
recommendations. In addition, the Firm entered into an agreement with two third-party providers—
Pendella Technologies Inc.—to implement, deliver and maintain a platform that facilitates marketing and
sales functions and enables existing and prospective customers and clients to purchase individual insurance
products; and GJ Insurance Group, an independent auto, home, life, commercial and benefits insurance
agency in Carmel, Indiana. The Firm receives a portion of the commissions as further described in Item 10
and 14.
Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Levine
Financial Group or its affiliates to provide (or continue to provide) additional services for compensation,
including investment management services. Clients retain absolute discretion over all decisions regarding
implementation and are under no obligation to act upon any of the recommendations made by Levine
Financial Group under a financial planning or consulting engagement. Clients are advised that it remains
their responsibility to promptly notify the Firm of any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating or revising Levine Financial Group’s recommendations
and/or services.
Investment Management Services
Levine Financial Group manages client investment portfolios on a discretionary basis. In addition, Levine
Financial Group provides clients with wealth management services which includes a broad range of
comprehensive financial planning and consulting services as well as discretionary management of
investment portfolios. Clients can engage the Firm directly or through an unaffiliated registered investment
adviser or other financial advisor (“Delegating Advisor”). Clients engaged through a Delegating Advisors
are referred to herein as “Sub- Advisory Clients.”
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Levine Financial Group primarily allocates client assets among various
exchange-listed securities, mutual
fund shares, corporate debt, exchange-traded funds (“ETFs”), US government securities, real estate
investment trusts (“REITs”), independent investment managers (“Independent Managers”) and certificates
of deposit in accordance with their stated investment objectives. Where appropriate, the Firm also provides
advice about any type of legacy position or other investment held in client portfolios, however, clients should
not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless
specifically agreed upon. Clients can engage Levine Financial Group to manage and/or advise on certain
investment products that are not maintained at their primary custodian, such as variable life insurance and
annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans). In these situations, Levine Financial Group directs or recommends the allocation of client assets
among the various investment options available with the product. These assets are generally maintained at
the underwriting insurance company, or the custodian designated by the product’s provider.
Levine Financial Group tailors its advisory services to meet the needs of its individual clients and seeks to
ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and
objectives. Levine Financial Group consults with clients on an initial and ongoing basis to assess their specific
risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of
their portfolios. Clients are advised to promptly notify Levine Financial Group if there are changes in their
financial situation or if they wish to place any limitations on the management of their portfolios. Clients
can impose reasonable restrictions or mandates on the management of their accounts if Levine Financial
Group determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts. Notwithstanding the
foregoing, where the Firm is engaged by a Delegating Advisor on behalf of a Sub-Advisory Client, Levine
Financial Group provides such management through the Program consistent with each Sub-Advisory
Client’s individual stated goals, objectives, and risk tolerances, as provided to Levine Financial Group by
the Delegating Advisor.
Levine Financial Group also provides clients an online portal (“Client Portal”) through which clients can
login and aggregate and monitor accounts managed by the Firm and their other personal accounts, prepare
projections, among other services.
Retirement Plan Consulting Services
Levine Financial Group provides various consulting services to qualified employee benefit plans and their
fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing,
and optimizing their corporate retirement plans. Each engagement is individually negotiated and
customized, and includes any or all the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection and Management
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education
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As disclosed in the Advisory Agreement, certain of the foregoing services are provided by Levine Financial
Group as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description
of
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Levine Financial Group’s fiduciary status, the specific services to be rendered and all direct and indirect
compensation the Firm reasonably expects under the engagement.
Use of Independent Managers
As mentioned above, Levine Financial Group selects certain Independent Managers to actively manage a
portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent
Manager may be set forth in a separate written agreement with the designated Independent Manager. In
addition to this brochure, clients may also receive the written disclosure documents of the respective
Independent Managers engaged to manage their assets.
Levine Financial Group evaluates a variety of information about Independent Managers, which includes
the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance and risk results in relation to
its clients’ individual portfolio allocations and risk exposure. Levine Financial Group also takes into
consideration each Independent Manager’s management style, returns, reputation, financial strength,
reporting, pricing and research capabilities, among other factors.
Levine Financial Group continues to provide services relative to the discretionary selection of the
Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being
managed by Independent Managers. Levine Financial Group seeks to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best
interests.
Participant Account Management
We use a third-party platform to facilitate management of held away assets such as defined contribution
plan participant accounts, with discretion. The platform allows us to avoid being considered to have custody
of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A
link will be provided to the Client allowing them to connect an account(s) to the platform.
Once Client account(s) is connected to the platform, Adviser will review the current account allocations.
When deemed necessary, Adviser will rebalance the account considering client investment goals and risk
tolerance, and any change in allocations will consider current economic and market trends. The goal is to
improve account performance over time, minimize loss during difficult markets, and manage internal fees
that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes
will be made as deemed necessary.
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