A. Description of the Advisory Firm
Keller Financial Group, Inc. (hereinafter “KFG”) is a Corporation organized in the State of
Pennsylvania. The firm was formed in September 1998, and the principal owner is
Dwayne D Keller.
B. Types of Advisory Services
Portfolio Management Services
KFG offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. KFG creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. 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
KFG evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. KFG 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.
KFG seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of KFG’s economic, investment or
other financial interests. To meet its fiduciary obligations, KFG attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, KFG’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 KFG’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
KFG has entered into a sub-advisory relationship with AssetMark, an investment adviser
registered with the U.S. Securities and Exchange Commission. Through this relationship
clients can utilize the AssetMark investment platform to access various third-party
investment solutions, including specialized tactical strategy portfolios, diversified baskets
of exchange traded funds, indexing mutual funds, portfolios of individual equity
securities, or strategists specializing in other alternative styles. AssetMark provides KFG
with research, due diligence, and a curated list of the various third-party managers that
have been fully vetted, rated for their expertise, categorized for their trading style, and
are monitored by the AssetMark investment team.
KFG will remain responsible for determining the client’s investment objectives and
whether one or more of the available managers is best suited to meet the designed
investment objective of a specific account.
Pension Consulting Services
KFG 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 money 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.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
KFG offers two types of Financial Planning: One-Time Financial Planning and Ongoing
Financial Planning. Each financial planning service is tailored to address different client
needs.
Services Limited to Specific Types of Investments
KFG generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities, equities, hedge
funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors),
treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital
funds and private placements. KFG may use other securities as well to help diversify a
portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. We also have a fiduciary
duty under the Investment Advisers Act of 1940 with respect to all client accounts. The
way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead
of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
KFG will tailor a program for each individual client. This will include an interview session
to get to know the client’s specific needs and requirements as well as a plan that will be
executed by KFG on behalf of the client. KFG may use model allocations together with a
specific set of recommendations for each client based on their personal restrictions, needs,
and targets. 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
KFG from properly servicing the client account, or if the restrictions would require KFG
to deviate from its standard suite of services, KFG reserves the right to end the
relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. KFG does not participate in wrap fee
programs.
E. Assets Under Management
KFG has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 September 2023