About Our Firm
Kentucky Planning Partners, LLC (KPP), and now KPP Advisory Services LLC (KPPAS), was
founded in 2005 by Robert A. Davenport and Ken A. O’Neil. KPPAS is an SEC registered
investment advisor with its principal place of business located in Kentucky.
KPPAS provides personalized, confidential financial strategies and investment management to
individuals, trusts, estates, charitable organizations, small businesses, 401(k)’s, and pension and
profit-sharing plans. Our advice is provided through consultation for understanding of our
Client’s values, determination of their goals and objectives, and understanding of their current
financial situation.
We at KPPAS hold ourselves to a fiduciary standard, which means our firm and its associates will
act in the utmost good faith, and perform in a manner believed to be in the best interest of our
Clients. As fiduciaries, we are obligated to put you - our Client - first. Through our annual review
process and year-round communication with our Clients, we strive to understand all aspects of
our Clients financial and life situations to better assist in helping them pursue their long-term
goals and objectives. We tailor our advisory services to the individual needs of our clients.
KPPAS does not act as a custodian for Client assets. The Client always maintains asset control.
KPPAS places trades for Clients utilizing non-discretionary platforms or full discretion granted
under the terms of the Custodian's Brokerage Account Application and under KPPAS's Advisory
Services Agreement. Clients are under no obligation to act upon any of the recommendations
made by KPPAS under a financial strategy development or consulting engagement and/or to
engage the services of any such recommended professional, including KPPAS. The Client retains
absolute discretion over all such implementation decisions and is free to accept or reject any of
the Advisor's recommendations. Each Client is advised that it remains his/her responsibility to
promptly notify KPPAS of any changes in his/her financial situation or investment objectives for
reviewing, evaluating, or revising the Advisor's previous recommendations and/or services.
Principal Owners
Robert A Davenport - 50% owner
Ken A. O'Neil - 50% owner
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Client Assets Under Management
As of December 2023, our firm had approximately $106 million dollars of non-discretionary and
$774 million1 dollars of discretionary client assets under management through account
agreements (defined in item 16).
KPP Advisory Services Offered
At KPPAS, we offer the following four services:
Financial Planning Services
Investment Management Services
Wealth Management Services
Employer-Sponsored Retirement Plan Consulting Services
Financial Planning Services
Financial planning is a comprehensive 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. Through the financial planning process, all questions, information and analysis are
considered as they impact and are impacted by the entire financial and life situation of the Client.
Clients purchasing this service receive a written report which provides the Client with a detailed
financial plan designed to assist the Client pursue his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
Personal: We will review family records, budgeting, personal liability, estate information
and financial goals;
Tax & Cash Flow: We will analyze the Client’s income tax and spending as well as
planning for past, current and future years; then illustrate the impact of various
investments on the Client’s current income tax and future tax liability;
Investments: We will analyze investment alternatives and their effect on the Client’s
portfolio;
Insurance: We will review existing policies to ensure proper coverage for life, health,
disability, long-term care, liability and any other which may affect the overall stability of a
financial plan;
Retirement: We will analyze current strategies and investment plans to help the Client
pursue his or her retirement goals;
Death & Disability: We will review the Client’s cash needs at death, income needs of
surviving dependents, estate planning and disability income;
Estate: We assist Clients in identifying estate planning needs; and
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Business Planning, Growth & Succession: We will review all aspects of individual
businesses panning and insurance needs, retirement plans for owners and employees,
growth needs and business transition, sale or succession.
We gather required information through in-depth personal interviews. Information gathered
includes the Client’s current financial status, tax status, future goals, returns, objectives and
attitudes towards risk. We carefully review documents supplied by the Client. Implementation of
financial plan recommendations is entirely at the Client’s discretion and is separate and
additional to the Financial Planning Services.
In addition we may also provide general non-securities advice on topics that may include tax and
budgetary planning, estate planning and business planning:
Exchange-listed securities
Securities traded over-the-counter
Foreign issuers
Warrants
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Variable life insurance
Variable annuities
Mutual fund shares
United States governmental securities
Interests in partnerships investing in real estate
Interests in partnerships investing in oil and gas interests
Other assets being held by Client
Typically, the financial plan is presented to the Client within three months of the contract date,
provided that all information needed to prepare the financial plan has been promptly provided.
Financial Planning recommendations are not limited to any specific product or service offered by
a broker-dealer or insurance company. The Client should be aware of the following disclosures:
a) A conflict exists between the interests of the investment advisor and the interests
of the Client;
b) The Client is under no obligation to act upon the investment advisor’s
recommendation; and
c) If the Client elects to act on any of the recommendations, the Client is under no
obligation to effect the transaction through the investment advisor.
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You will retain full discretion over all implementation decisions and are free to accept or reject
any recommendation we make. Further, it remains your responsibility to promptly notify us
there is any change in your financial situation or investment objectives for the purpose of our
reviewing, evaluating, or revising previous recommendations and/or services.
This service falls under the KPPAS Financial Planning Services Agreement.
In some circumstances, a Retainer Agreement may be executed in lieu of a Financial Planning
Services Agreement when it is deemed more appropriate to work on a fixed-fee basis. If the Client
later engages KPPAS under an Advisory Services Agreement, the Advisor may waive all or a
portion of its fees under this agreement. The fee for a Retainer Agreement is $1,500 and is
negotiable.
Investment Management Services
In situations where comprehensive wealth management is not desired, our Investment
Management Services may be utilized for comprehensive portfolio management. The scope of
these engagements is normally limited in nature, whereby we are providing investment selection,
asset allocation and rebalancing services for Client assets. Additional Financial Planning Services
are not generally offered, or only offered in a limited fashion rather than in a comprehensive,
coordinated manner. This service is a fee based service and managed on a discretionary or non-
discretionary basis.
Our Investment Management Services falls under the KPPAS Investment Management Services
Agreement.
Wealth Management Services
Most Clients of KPPS choose to utilize our Wealth Management Services. All aspects of the
Client’s financial affairs are reviewed. Agreed-upon realistic and measurable goals are set, and
objectives to reach those goals are defined. As goals and objectives change over time, suggestions
are made and implemented on an ongoing basis. Our Wealth Management Services reviews
aspects such as:
Cash flow analysis and budgeting;
Future savings goals;
Insurance review;
Protection/Family Security;
Investment management (including performance reporting);
Education planning;
Retirement planning;
Financial position planning;
Estate planning guidance and tax planning guidance may be offered in conjunction with
legal and tax partners; and
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Small Business development, growth and transition.
This is a full service comprehensive wealth management service that includes our Financial
Planning Services and Investment Management Services. This service is a fee based service and
managed on a discretionary or non-discretionary basis.
Our Wealth Management Services falls under the KPPAS Wealth Management Services
Agreement.
Employer-Sponsored Retirement Plan Consulting Services
Our Employer-Sponsored Retirement Plan Consulting Service provides services to employer plans
falling under the Employee Retirement Income Security Act (ERISA).
These services may include:
Investment Policy Statement
Ongoing Investment Recommendations
Ongoing Investment Monitoring
Qualified Default Investment Alternative Assistants
Non-Discretionary Model Portfolios
Performance Reports
Service Provider Liaison
Education Services to Plan Committee
Participant Enrollment
Participant Education
Plan Search Support/Vendor Analysis
Benchmarking Services
Assistance Identifying Plan Fees
ERISA 3(21) investment co-fiduciary services
*For detailed definitions of these services, please see the Employer-Sponsored Retirement Plan
Consulting Services Agreement
Our Employer-Sponsored Retirement Plan Consulting Services falls under the KPPAS Employer-
Sponsored Retirement Plan Consulting Services Agreement. How this service is charged is
dependent on the compensation schedule agreed upon by KPPAS and the Client.
ERISA Disclosure for Retirement Planning
When KPPAS provides investment advice to Clients regarding ERISA retirement accounts or individual
retirement accounts (“IRAs”), KPPAS is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which
are laws governing retirement accounts. When deemed to be in the Client’s best interest, KPPAS will
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provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll
over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA
sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). Such a recommendation creates a conflict of interest if
KPPAS will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under
any obligation to roll over a retirement account to an account managed by KPPAS.
Workshop Presentations
We may provide educational workshops on an “as announced” basis for groups desiring general
advice on investments and personal finance. Topics may include issues related to wealth
management, financial planning, retirement strategies, or various other economic investment
topics.
Our workshops are purely educational in nature and do not involve the sale of any investment
products. Information presented will not be based on any one person’s need, nor do we provide
individualized investment advice to attendees during general sessions.
Types of Custodial Programs Utilized By KPP Advisory
Services
LPL Financial Sponsored Advisory Programs:
KPPAS may provide advisory services through certain programs sponsored by LPL Financial LLC
(LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL
advisory program available to KPPAS. For more information regarding the LPL programs,
including more information on the advisory services and fees that apply, the types of investments
available in the programs, and the potential conflicts of interest presented by the programs,
please see the program account packet (which includes the account agreement and LPL Form
ADV program brochure) and the Form ADV,
Part 2A of LPL or the applicable program.
Optimum Market Portfolios Program (OMP)
OMP offers Clients the ability to participate in a professionally managed asset allocation program
using Optimum Funds Class I shares. Under OMP, a Client will authorize LPL on a discretionary
basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the
Client. Advisor will assist the Client in determining the suitability of OMP for the Client and
assist the Client in setting an appropriate investment objective. Advisor will have discretion to
select a mutual fund asset allocation portfolio designed by LPL consistent with the Client's
investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to
the portfolio selected for the Client. LPL will also have authority to rebalance the account.
A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a
lower minimum account size.
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Personal Wealth Portfolios Program (PWP)
PWP offers Clients an asset management account using asset allocation model portfolios designed
by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on
Client's investment objective. Advisor will also have discretion for selecting third party money
managers (PWP Advisors) or mutual funds within each asset class of the model portfolio. LPL
will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase
and sell on a discretionary basis mutual funds and equity and fixed income securities.
A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit
a lower minimum account size.
Model Wealth Portfolios Program (MWP)
MWP offers Clients a professionally managed mutual fund asset allocation program. [Advisor]
will obtain the necessary financial data from the Client, assist the Client in determining the
suitability of the MWP program and assist the client in setting an appropriate investment
objective. The Advisor will initiate the steps necessary to open an MWP account and have
discretion to select a model portfolio designed by LPL’s Research Department consistent with the
Client’s stated investment objective. LPL’s Research Department or third-party portfolio
strategists are responsible for selecting the mutual funds or Exchange-traded funds (ETFs) within
a model portfolio and for making changes to the mutual funds or ETFs selected.
The Client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds
and ETFs and to liquidate previously purchased securities. The Client will also authorize LPL to
effect rebalancing for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The minimums vary
depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The
lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is
permitted.
Guided Wealth Portfolios (GWP)
GWP offers Clients the ability to participate in a centrally managed, algorithm-based investment
program, which is made available to users and Clients through a web-based, interactive account
management portal (“Investor Portal”). Investment recommendations to buy and sell open-end
mutual funds and ETFs are generated through proprietary, automated, computer algorithms
(collectively, the “Algorithm”) of Xulu, Inc., doing business as FutureAdvisor (“FutureAdvisor”),
based upon model portfolios constructed by LPL and selected for the account as described below
(such model portfolio selected for the account, the “Model Portfolio”). Communications
concerning GWP are intended to occur primarily through electronic means (including but not
limited to, through email communications or through the Investor Portal), although [Advisor]
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will be available to discuss investment strategies, objectives or the account in general in person or
via telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45)
days to help users determine whether they would like to become advisory clients and receive
ongoing financial advice from LPL, FutureAdvisor and [Advisor] by enrolling in the advisory
service (the “Managed Service”). The Educational Tool and Managed Service are described in
more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to
be advisory clients of LPL, FutureAdvisor or [Advisor], do not enter into an advisory agreement
with LPL, FutureAdvisor or [Advisor], do not receive ongoing investment advice or supervisions of
their assets, and do not receive any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Manager Access Select Program
Manager Access Select provides Clients access to the investment advisory services of professional
portfolio management firms for the individual management of Client accounts. Advisor will assist
Client in identifying a third party portfolio manager (Portfolio Manager) from a list of Portfolio
Managers made available by LPL. The Portfolio Manager manages Client’s assets on a
discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio
Manager Selection process.
A minimum account value of $100,000 is required for Manager Access Select, however, in certain
instances, the minimum account size may be lower or higher.
Fees for LPL Advisory Programs
The account fee charged to the Client for each LPL advisory program is negotiable, subject to a
maximum account fee of 2.50%.
Account fees are payable quarterly in advance.
LPL serves as program sponsor, investment advisor, and broker-dealer for the LPL advisory
programs. KPPAS and LPL Financial may share in the account fee and other fees associated with
program accounts. Associated persons of Advisor may also be registered representatives of LPL
financial.
Strategic Wealth Management (SWM) – Individual Portfolio
Management
Our firm provides non-continuous asset management of Client funds based on the individual
needs of the Client. Through personal discussions in which goals and objectives based on the
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Client’s particular circumstances are established, we develop the Client’s personal investment
policy. We create and manage a portfolio based on that policy. During our data-gathering
process, we determine the Client’s individual objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we may also review and discuss a Client’s prior investment
history, as well as family composition and background.
We manage these advisory accounts on a discretionary or non-discretionary basis. Account
supervision is guided by the Client’s stated objectives (i.e., Aggressive Growth, Growth, Growth
with Income, Income with Moderate Growth or Income with Capital Preservation), as well as tax
considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities,
or industry sectors.
Once the Client’s portfolio has been established, we review the portfolio on an ongoing basis, and
if necessary, rebalance the portfolio as required, based on the Client’s individual needs.
Our investment recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. Our primary investment philosophy is based on building
mutual fund and ETF portfolios, but may include advice regarding the following securities:
Exchange-listed securities
Securities traded over-the-counter
Structured Notes
Foreign issuers
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Variable life insurance
Variable annuities
Unites States governmental securities
Because some types of investments involve certain additional degrees of risk, they will only be
recommended when consistent with the Client’s stated investment objectives, tolerance for risk,
liquidity and suitability.
Account fees are payable quarterly in advance.
There is no minimum account value required for SWM.
Fidelity Sponsored Advisory Programs:
Separate Account Network (SAN):
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KPPAS may utilize the Separate Account Network through Fidelity for certain money managers
not available in LPL’s network.
The Separate Account Network provides Clients access to the investment advisory services of
professional portfolio management firms for the individual management of Client accounts.
Advisor will assist Client in identifying a third party portfolio manager (Portfolio Manager) from a
list of Portfolio Managers made available in the program. The Portfolio Manager manages Client’s
assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the
Portfolio Manager Selection process.
Each Portfolio Manager has individual minimums for their portfolio management.
Third-Party Managers
Based upon the stated investment objectives of the Client, KPPAS may recommend to certain
Clients that they authorize the active discretionary management of a portion of their assets by
certain investment managers that are independent of, and not affiliated with, KPPAS, either
directly or through a wrap fee program. Prior to selecting a third-party manager for a Client,
KPPAS shall review information about a third-party manager such as its disclosure statement
and/or material supplied by the third-party manager or another independent third party.
KPPAS shall continue to render services to the Client and monitor and review the performance of
the third-party manager and the performance of the Clients’ accounts that are being managed.
The terms and conditions under which the Client shall engage such third-party managers shall be
set forth in separate written agreements between the Client and KPPAS, and/or the Client and the
third-party manager, and/or the wrap fee program sponsor.
Factors that KPPAS may consider in recommending a particular third-party manager may include
the Client’s stated investment objective and the manager’s management style, performance,
reputation, financial strength, reporting, pricing and research. In addition to KPPAS written
disclosure statement, Clients shall also receive the written disclosure statement of the third-party
manager and/or wrap fee program sponsor, if applicable, recommended by KPPAS.
General Information
All initial meetings are free of charge and are considered exploratory interviews to determine the
extent to which financial strategizing and investment management may be beneficial to the
prospect.
With your consent, we may work with your attorney or accountant to assist with the coordination
and implementation of accepted strategies. You should be aware that these advisors may bill you
separately for services and these fees will be in addition to those of our firm.
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Our firm will use its best judgement and good faith effort in rendering its services. KPPAS cannot
warrant or guarantee any particular level of account performance, or that accounts will be
profitable over time. Past performance is not necessarily indicative of future results.
Except as may otherwise be provided by law, our firm will not be liable to the Client, heirs, or
assignees for any loss an account may suffer by reason of an investment decision made or other
action taken or omitted in good faith by our firm with that degree of care, skill, prudence and
diligence under the circumstances that a prudent person acting in a fiduciary capacity would use;
any loss arising from our adherence to your direction or that of your legal agent; or any act or
failure to act by a service provider maintaining an account.
Federal and state securities laws impose liabilities under certain circumstances on persons who
act in good faith and, therefore, nothing contained in this document or a client agreement shall
constitute a waiver of any rights that a Client may have under federal and state securities laws.
Termination of Agreements
A Client may terminate any of the aforementioned agreements at any time by notifying KPPAS in
writing and paying the rate for the time spent on the investment advisory engagement prior to
notification of termination. KPPAS may terminate any of the aforementioned agreements at any
time by notifying the Client in writing. If the Client made an advance payment, KPPAS will
refund any unearned portion of the advance payment within thirty (30) days. If the termination
occurs within five (5) business days of entering into an agreement for services, the Client will be
entitled to a full refund.