A. Firm Information Keen Capital, LTD, (“Keen Capital” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). Keen Capital is organized as a Corporation under the laws of South Carolina. Keen Capital was founded in 2007, and is owned and operated by Thomas Gore (President). The Advisor conducts business under the practice name (“doing business as” or “dba” name) Core Advisors, Ltd. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Keen Capital.
B. Advisory Services Offered 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. Keen 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.
Keen Capital offers a variety of advisory services to individuals, high net worth individuals, trusts, estates, businesses, retirement plans, and charitable organizations (each referred to as a “Client”). These services can be categorized as Financial Planning Services, Investment Management Services, or a combination of services under Wealth Management Services Wealth Management Services Keen Capital provides customized wealth management services for its Clients pursuant to a wealth management agreement. These services consist of two components: financial planning services and investment management services.
Financial Planning Services Keen Capital will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. 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: ●Business planning ●Retirement planning ●Financial planning ●Tax strategy ●Personal tax and cash flow planning ●Estate planning ●Insurance planning ●Divorce planning ●College planning ●Compensation and benefits planning ●Other areas as determined by Client needs 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, 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.
Page 4 Keen Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, 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 and consulting 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.
Investment Management Services Keen Capital provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Keen 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 a portfolio strategy. Keen Capital will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks to meet the needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax considerations. In certain client engagements financial planning is included as an additional service to investment management services.
Keen Capital’s investment approach is primarily long-term 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. Keen 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.
Keen Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Keen Capital may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Keen Capital may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Keen Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Independent Managers – Keen Capital may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Under certain circumstances, Keen Capital may accept or maintain custody of a Client ‘s funds or securities.
Please see Item 15 – Custody for more information.
Page 5 Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor 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, the Advisor will 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 the Advisor 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 the Advisor.
Retirement Plan Advisory Services Keen 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: ●Vendor Analysis ●Plan Participant Enrollment and Education Tracking ●Investment Policy Statement (“IPS”) Design and Monitoring ●Investment Management Services ●Performance Reporting ●Ongoing Investment Recommendation and Assistance ●ERISA 404(c) Assistance ●Benchmarking Services These services are provided by Keen 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 Keen 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 Keen Capital to provide investment 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 – Keen Capital, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
●Asset Allocation – Keen 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 – Keen 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 – Keen Capital will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs Keen Capital does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Keen Capital.
E. Assets Under Management Page 6 As of December 31, 2023, Keen Capital manages $144,232,746 in Client assets, $142,220,265 of which are managed on a discretionary basis and $2,012,481 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.