A. Firm Information
Kleinfelder Capital, Inc. (“Kleinfelder Capital” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). Kleinfelder Capital is organized as a Corporation under the laws
of the State of Ohio. Kleinfelder Capital was founded in July 2017 and is owned and operated by Michael J.
Kleinfelder President and Chief Executive Officer. This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Kleinfelder Capital.
B. Advisory Services Offered
Kleinfelder Capital offers advisory services to individuals, high net worth individuals, families, trusts, estates,
businesses, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Kleinfelder Capital’s fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Kleinfelder Capital provides a holistic approach to its wealth advisory services. Client engagements typically
include comprehensive financial plannng and investment management services as described below. Services
are tailored to the unique needs of each Client.
Investment Management Services
Kleinfelder Capital provides customized wealth management solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and
planning services. Kleinfelder Capital works closely with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to create an investment strategy. Kleinfelder
Capital customizes its investment management services for its Clients. Portfolios may be constructed using
open-end mutual funds, exchange-traded funds (“ETFs”), individual equity securities and or individual fixed
income securities. For certain Clients, the Advisor may utilize tax-free municipal bonds and other types of
investments. For certain Clients, the Advisor may employ leveraged ETFs and or the short-term use of margin.
For mutual funds, the Advisor selects active and passive managers and will seek institutional share classes when
available.
Kleinfelder Capital’s investment approach is primarily long-term investment focused, but the Advisor may buy,
sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due
to market conditions. Kleinfelder Capital will construct, implement and monitor the portfolio to ensure it meets the
goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity
to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
At no time will Kleinfelder Capital accept or maintain custody of a Client’s funds or securities, except for the
limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the advisory agreement, please see Item 12 – Brokerage Practices.
Financial Planning Services
Kleinfelder Capital will typically provide a variety of financial planning and consulting services to Clients either as
a component of wealth management services or as a separate service, pursuant to the terms of the agreement
with the Client. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a
specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client.
For example,
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recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
In certain circumstances, Kleinfelder Capital may also refer Clients to an accountant, attorney or other specialist,
as appropriate for the Client’s unique situation. For certain financial planning engagements, the Advisor will
generally provide a written report that contains observations and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed
within six (6) months of contract date, assuming all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor.
Retirement Plan Advisory Services
Kleinfelder Capital provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance
These services are provided by Kleinfelder Capital serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of Kleinfelder Capital’s fiduciary status, the specific
services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the
engagement.
C. Client Account Management
Prior to engaging Kleinfelder Capital to provide advisory services, each Client is required to enter into one or
more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – Kleinfelder Capital will develop a strategy that seeks to achieve
the Client’s goals and objectives.
• Asset Allocation – Kleinfelder Capital will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Kleinfelder Capital will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
• Investment Management and Supervision – Kleinfelder Capital will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Kleinfelder Capital includes securities transaction fees together with its investment advisory fee. Including these
fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment
management services for its Clients. The Advisor sponsors the Kleinfelder Capital Wrap Fee Program solely as a
supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the
Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own
transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to
this Disclosure Brochure.
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E. Assets Under Management
As of December 31, 2023, the Advisor manages $243,923,055 in discretionary assets under management and
$829,526 in non-discretionary assets under management. Total assets under management are $244,752,581.
Clients may request more current information at any time by contacting the Advisor.