too much insurance coverage, inadequate cash flow, a high tax burden, inadequate retirement savings, high levels of exposure to risk, inappropriate or deficient estate planning, etc.
• Design a written financial plan that includes recommendations and solutions to any financial related issues.
• Implementation of the financial plan. The financial plan is finalized and agreed upon. The recommendations and solutions are executed to increase the probability of reaching the desired goals and objectives.
• Evaluation and Monitoring of the financial plan. KC provides periodic review and revision of the plan to assist in the achievement of financial goals. This periodic review looks back at all aspects of the financial plan to evaluate progress. Modifications and adjustments to the financial plan, including changes in risk tolerance and account reallocation/rebalancing, are undertaken to adapt to the changes in a client’s life and circumstances. The frequency of this periodic review is determined by the client’s preferences. Wealth Management Type of Relationship Investment Management KC offers clients a comprehensive planning and investment management relationship. The solution includes:
• development, implementation, and monitoring of the financial plan.
• discretionary or non-discretionary investment management.
• implementation and active management of the client’s portfolio; assets are held (in part or in whole) with KC’s custodian.
• working with the client to implement and monitor the recommended asset allocation of client’s investments held at other financial institution(s) (brokerage accounts, mutual funds, 401k/403b, etc.).
• on-going reviews to monitor the investment plan including performance reviews, rebalancing, and reallocation.
• monitoring the client’s financial situation to adjust to changing circumstances, priorities, and life events. Ideal for clients who:
• are not self-directed investors.
• feel that consolidation of their investments will aid in the organization of their financial life, reduce risk, and provide greater ease of management.
• do not feel that they have the time, knowledge, and discipline to manage their own assets.
• desire an advocate who will develop, implement, and monitor a customized strategy. With Investment Management, KC incorporates the client’s income needs, tax levels, time horizon, and risk tolerance to develop and implement allocation strategies. KC will request (but will not require) discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. If a non-discretionary relationship is desired, KC will discuss the strategy and secure approval from clients prior to each transaction. KC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of KC’s economic, investment, or other financial interests. To meet its fiduciary obligations, KC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly,

KC’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 KC’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. Selection of Other Advisers KC may direct clients to third-party investment advisers. Before selecting other advisers for clients, KC will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where KC is recommending the adviser to clients. Types of Investments KC generally invests in mutual funds, ETFs, individual equities, fixed income securities, real estate (REITs, funds, or direct through LLCs or LLPs), fee-only annuities, commodities, hedging strategies, private debt, and private equity. KC may use other investments as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions KC 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 KC from properly servicing the client account, or if the restrictions would require KC to deviate from its standard suite of services, KC reserves the right to end the relationship. KC does not participate in any wrap fee programs. KC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 130,001,830.47 $0 March 19, 2024 Fee Schedule A. Investment Management Keen Capital’s fees for Investment Management are based on an annual percentage of assets under management or an annual fixed dollar fee. The tiered fee schedule below outlines our firm’s fee structure. These advisory fees are set forth in each client’s Investment Advisory Contract. The annual fees are negotiable and paid in arrears on a quarterly basis (calendar quarter). Unless instructed by the client, KC will aggregate asset amounts in accounts from the client’s same household to determine the advisory fee for all accounts. KC would do this, for example, when managing accounts on behalf of the client’s minor children, individual or joint accounts for a spouse/partner, and/or other types of related accounts. This consolidation practice is designed to allow the benefit of an increased asset total, which could potentially cause account(s) to be assessed a lower advisory fee. There is a minimum Investment Management fee of $5,000 annually; this account minimum can be waived at the discretion of KC. Assets Under ManagementAnnual Fee % First $1,000,0001.00% Next $2,000,0000.75% Next $2,000,0000.60% Above $5,000,0000.45% Investment Management