DMKC Advisory Services, LLC (also referred to as the “Firm”, “us”, and “we”) has been an SEC
Registered Investment Adviser since 2007 and an Iowa Limited Liability Company since 1999. D.M. Kelly
& Company, a registered broker/dealer member FINRA/SIPC, is our parent company; the Daniel M. Kelly
2004 Trust is the majority owner of D.M. Kelly & Company; and Patrick B. Kelly is the Trustee for the
Daniel M. Kelly 2004 Trust.
We are a fiduciary and are required to act in your best interest at all times. We provide fee-based
investment advisory services and financial planning. The nature and extent of the specific services
provided to clients depends on each client’s financial status, objectives and needs, time horizons,
concerns, expectations and risk tolerance.
Our investment advisor representatives (“Advisors”) are also registered representatives of D.M. Kelly &
Company. When making the determination of whether the advisory programs available through us are
appropriate for your individual needs, please keep in mind that fee based accounts, when compared with
commission based accounts (such as those available through D.M. Kelly & Company), often result in
lower costs during periods when trading activity is heavier, such as the year an account is established.
However, during periods when trading activity is lower, such arrangements may result in a higher annual
cost for transactions. Thus, depending on a number of factors, the total cost to you under a fee account
versus a commission based account can vary significantly and a commission based account may be
cheaper than a fee based account. Some such factors are account size, amount of turnover, type and
quantities of securities purchased or sold, commission rates and your tax situation.
You should have a conversation with your Advisor and read this Brochure carefully when deciding if the
advisory services available through our Firm are right for your investment needs.
Description of Advisory Services
Our firm specializes in providing portfolio management services which involve providing you with on-going
supervision over your accounts. This means that we monitor your account and make trades when
necessary. Through this service, we implement a customized and individualized investment program for
you by applying our investment strategy and philosophy. We actively manage your investment portfolios
in accordance with your individual needs, return objectives, and risk tolerance.
We will be granted trading authorization on your account. Please refer to Item 16 for more details. You
are always responsible for notifying us of any changes to your financial situation or investment objectives,
or if you would like to impose and/or modify any reasonable restrictions on the management of their
accounts. We are always reasonably available to consult with you relative to the status of your accounts.
It is important that you understand that we manage investments for other clients and we are not obligated
to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for
any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts we manage. We strive
to allocate investment opportunities believed appropriate for your account(s) and other accounts advised
by our firm among such accounts equitably and consistent with the best interests of all accounts involved.
However, there can be no assurance that a particular investment opportunity that comes to our attention
will be allocated in any particular manner. If we obtain material, non-public information about a security or
its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the
information to any client or use it for any client’s benefit.
Our portfolio management services are provided through three managed platforms: Atlas, Anchor, and
Dividend Low-Volatility (DLV).
Comparison of Atlas, Anchor, and DLV
Atlas is an open-architecture style program available to larger accounts and allows investments in a
variety of securities. The Atlas program allows more customization in the portfolio’s composition and the
timing of transactions. Individual Advisors help tailor the investment portfolio and may or may not be
granted discretionary trading. There is a $500,000 minimum account size and a minimum annual fee of
$1,000. All participants must be our client.
The discretionary Anchor offers investors five asset allocation models and can be used for accounts with
a $50,000 minimum account size and a minimum annual fee of $200. The models primarily use mutual
fund and ETF investments. The Anchor program has an Investment Team create, update, and
periodically rebalance the model portfolios. All participants must be our client.
The discretionary DLV offers certain investors an equity strategy paired with a blend of high-quality fixed
income investments that meets with the Client’s risk objective. The DLV program is designed for long-
term investing, while remaining liquid, and aims to deliver growth and income while reducing volatility.
This program also utilizes a third party money manager. There is a $250,000 minimum account size and
a minimum annual fee of $1,000. All participants must be our client.
All brokerage transactions implemented through Atlas, Anchor, and DLV are processed by D.M. Kelly &
Company in its capacity as a full-service introducing broker/dealer, and then cleared through Wells Fargo
Clearing Services, LLC, which are both registered broker/dealers and members of FINRA/SIPC. D.M.
Kelly & Company is our affiliated broker/dealer. Wells Fargo Clearing Services, LLC is not affiliated with
D.M. Kelly & Company or us. In addition to serving as the clearing broker/dealer, Wells Fargo Clearing
Services, LLC serves as qualified custodian for Atlas, Anchor, and DLV accounts (see Items 12 and 15
for more information).
Selection and Monitoring of Third Party Money Managers
Client’s investment portfolios are managed either by our Investment Adviser Representatives or outside
portfolio managers selected by us. We select and review outside portfolio managers based on the following
factors:
• past performance;
• cost;
• investment philosophy;
• market outlook;
• experience of portfolio managers and executive team;
• opinions of third party analysts;
• disciplinary, legal and regulatory histories of the firm and its
associates;
• whether established compliance procedures are in place to address at a minimum, insider trading,
conflicts of interest, anti-money laundering.
We do not calculate portfolio manager performance. Instead, we rely upon the performance figures based
on the client’s account statements or reports provided to us by the outside portfolio managers. We do,
however, watch for several types of events in conjunction with poor performance. These events trigger an
in-depth review of an outside portfolio manager and primarily include:
• Significant changes in asset allocation;
• Substantial drift in investment style; and/or
• Sustained under-performance.
We do not verify the accuracy of such performance information or its compliance with presentation
standards. As a result, performance information may not be calculated on a uniform and consistent basis.
We have the ability to hire or delegate authority to independent third party investment managers to
manage a portion of our client's portfolio through advisory management services programs and we have
the ability to fire independent third party managers.
Financial Planning Services
Based on information gathered from you, we present a financial plan intended generally to assist you with
your financial affairs. This financial plan is not intended as a comprehensive financial plan covering every
possible aspect of your financial affairs. It is intended to cover, in a general sense, those financial issues
and decisions typically important to most clients. Financial planning may include advice on retirement,
education, tax planning, survivorship issues, disability, asset allocation and estate planning. In the
implementation of the financial plans, you retain the actual responsibility and authority to implement
recommendations in the financial plan presented by our Advisor. We may assist in the implementation at
the request of clients.
Types of Investments
We provide investment advice on the following types of investments: municipal securities, fixed income
securities (i.e. bonds), exchange-listed securities (i.e. stocks), securities traded over-the-counter (i.e.
stocks), commercial paper, certificates of deposit, US government securities, preferred stock, mutual fund
shares, or exchange traded funds.
We do not provide advice on foreign issues, warrants, variable life insurance, variable annuities, options
contracts on securities, options contracts on commodities, futures contracts on tangibles or intangibles,
interests in partnerships investing in real estate, oil, and gas interests, or hedge funds and other types of
private (i.e. non-registered) securities.
When providing asset management services, we typically construct your account holdings using no-load
mutual funds, funds at Net-Asset-Value (NAV), equity positions and fixed income positions to build
diversified portfolios. It is not our typical investment strategy to attempt to time the market but we may
increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our
expectations of market behavior. We may modify our investment strategy to accommodate special
situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses,
collectibles, or special tax situations.
Tailor Advisory Services to Individual Needs of Clients
Our services are provided based on the individual needs of each client. This means, for example, that
you are given the ability to impose restrictions on the accounts we manage for you, including specific
investment selections and sectors. We work with you on a one-on-one basis through interviews and
questionnaires to determine your investment objectives and suitability information.
When managing your accounts through the Anchor program, we manage in accordance with one or more
investment models. Because your accounts are managed using models, investment selections are based
on the underlying model and we generally do not develop customized (or individualized) portfolio holdings
for each client. However, the determination to use a particular model or models is always based on your
individual investment goals, objectives and mandates and at times, we may create individualized
portfolios. Our services are always based on your individual needs as we select strategies and models
most appropriate for you.
When we provide asset management services, you are given the ability to impose restrictions on the
accounts we manage for you, including specific investment selections and sectors. However, we will not
enter into an investment adviser relationship with a prospective client whose investment objectives may
be considered incompatible with our investment philosophy or strategies or where the prospective client
seeks to impose unduly restrictive investment guidelines.
Services through Client Directed Brokerage Arrangements
Generally, all clients engaging us for our investment management services will be solicited to open an
Atlas, Anchor, or DLV program account as previously described. However, at your specific written
request, and subsequent consent from us, we can provide investment management services through
accounts maintained at a qualified custodian selected by the client. The client selected qualified
custodian (which may include a broker-dealer, bank, or product sponsor) will maintain custody of all funds
and securities. Please see Items 12 and 15 for more details. The type and form of investment
management services provided through this service are similar to the investment management services
provided through the Atlas, Anchor, or DLV programs. Some brokerage platforms may have constraints
limiting our ability to trade in the client’s account or a client may decide to restrict our trading authority. In
these situations, our services are considered “consultative” in nature and trading authorization is not
granted to us by you. Through this type of arrangement, we provide ongoing review services of your
account; however, you must implement all trades in the account as we will not have direct trading access
to the account.
We do not participate in a wrap program.
Client Assets Managed
The amount of clients’ assets managed totaled approximately $562,510,319 as of December 31, 2023.
Approximately $475,265,642 is managed on a discretionary basis and $87,244,677 is managed on a non-
discretionary basis.