A. Firm Information
Kropog Financial Group, LLC (“Kropog Financial” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC)
under the laws of Louisiana. Kropog Financial was founded in June 2011 and became a Registered Investment
Advisor in February, 2016. Kropog Financial is owned and operated by Jim Kropog (President and Chief
Compliance officer) and Ryan Kropog (Vice-President). This Disclosure Brochure provides information regarding
the qualifications, business practices, and the advisory services provided by Kropog Financial.
B. Advisory Services Offered
Kropog Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates, and
businesses (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. Kropog Financials’ 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.
Wealth Management Services
Kropog Financial provides wealth management services for its Clients. These services generally include
discretionary investment management services in connection with a broad range of financial planning services.
These services are described below.
Investment Management Services – Kropog Financial provides customized investment advisory solutions for its
Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary
non-discretionary investment management and related advisory services. Kropog Financial 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. Kropog Financial will then construct an investment portfolio, consisting of low-cost,
exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize mutual
funds, individual stocks, REITs and alternative investments to meet the needs of its Clients. The Advisor may retain
certain types of investments based on a Client’s legacy investments based on portfolio fit and/or tax considerations.
Kropog Financial’s investment strategies are 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. Kropog Financial 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.
Kropog Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Kropog Financial may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Kropog Financial 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.
Kropog Financial 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 the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
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
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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.
At no time will Kropog Financial 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 the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services – Kropog Financial will typically provide a variety of financial planning and consulting
services to Clients, either as a component
of wealth management services, or pursuant to a separate 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, 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,
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.
Kropog Financial 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.
C. Client Account Management
Prior to engaging Kropog Financial 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 – Kropog Financial, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Kropog Financial 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 – Kropog Financial will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Kropog Financial will provide investment management and
ongoing oversight of the Client’s investment portfolio.
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Retirement Plan Advisory Services
Kropog Financial 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:
● Plan Participant Enrollment and Education Tracking
● Investment Policy Statement (“IPS”) Design and Monitoring
● Investment Oversight Services (ERISA 3(21))
● Performance Reporting
● Ongoing Investment Recommendation and Assistance
These services are provided by Kropog Financial 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 Kropog Financials’ fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
D. Wrap Fee Programs
Kropog Financial typically does not manage or place Client assets into a wrap fee program. However, for certain
Clients, Kropog Financial includes securities transaction fees together with its investment advisory fees. 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 Kropog Financial 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.
E. Assets Under Management
As of December 31, 2023, Kropog Financial manages $117,234,502 in Client assets, $111,590,317 of which are
managed on a discretionary basis and $5,644,185 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.