A. Description of the Advisory Firm Kinwell LLC (hereinafter “Kinwell”) 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 law of the State of South Carolina. The firm was formed in September 2017, and became registered as an investment adviser in January 2018. The firm became registered with the U.S. Securities and Exchange Commission on May 26, 2023. The principal owners are James Louis Carlson and Matthew Dayton Ritt. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Kinwell. B. Types of Advisory Services Portfolio Management Services Kinwell offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Kinwell creates an Investment Policy Statement for each client, which outlines the client’s current situation (including income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
• Investment strategy
• Personal investment policy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring Kinwell evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Kinwell will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Kinwell seeks to ensure that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Kinwell’s economic, investment or other financial interests. To meet its fiduciary obligations, Kinwell attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Kinwell’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Kinwell’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over

time. Pension Consulting Services Kinwell offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending third-party investment managers to manage plan assets in ways designed to achieve objectives
• monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker-dealers
• creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments Kinwell generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. Kinwell may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Kinwell offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Kinwell from properly servicing the client account, or if the restrictions would require Kinwell to deviate from its standard suite of services, Kinwell reserves the right to end the relationship. D. Wrap Fee Programs Kinwell does not participate in any wrap fee programs. A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. E. Assets Under Management Kinwell has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $81,334,693 $67,404,475 December 2023