Ownership KingsMark Private Financial Advisors, LLC (“KingsMark,” “Advisor,” “we” or “us”) is an investment adviser registered with the U.S. Securities and Exchange Commission since March 12, 2008. KingsMark is a limited liability company formed under the laws of the State of Georgia. Thomas E. Sanders and Rebecca A. Anderson are the owners of KingsMark. General Description of Primary Advisory Services KingsMark offers personalized investment advisory services including financial plans, consultations and asset management. The following are brief descriptions of KingsMark’s primary services. A detailed description is provided in Item 5, Fees and Compensation, so that clients and prospective clients can review the services and description of fees more thoroughly. Financial Planning Services (Plans and Consultations) Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning and other areas. The role of a financial planner is to find ways to help clients understand their overall financial situation and help them set financial objectives. KingsMark provides financial planning services in the form of full and modular (segmented) financial plans. These services do not involve actively managing client accounts. Instead, full planning services and consultations focus on a client’s overall financial situation. Modular planning services and consultations (both one-time and on-going) focus on specific areas of client concern. KingsMark provides financial planning services by offering analyses and recommendations in areas including, but not limited to:
• Personal planning (family records, budgets, personal liability, etc.)
• Cash flow and management
• Retirement planning
• Business planning
• Estate planning
• Education planning
• Tax planning
• Risk management
• Insurance analysis
• Investment analysis
• Benefit plans
• Disability and long-term care
• Stock option analysis KingsMark’s services do not include legal or tax advice except for tax considerations incidental to investment recommendations. Tax advice may be provided independently through one or more businesses operated by our investment adviser representatives. At present, only Britt C. Bazemore, a licensed certified public accountant, offers such services through his own company, Broadview Advisory Group, LLC. KingsMark’s investment adviser representatives (“representatives”) meet with clients to gather information and documentation needed to perform an analysis and review of a client’s situation as well as his or her objectives and goals. One or more meetings may be required in order to gather all needed information and determine the services best suited to help meet the client’s needs. KingsMark and its representatives rely on the information provided by clients. Therefore, it is very important that the information provided by clients is complete and accurate. KingsMark and its representatives are not responsible for verifying the information supplied by clients. Clients are also urged to work closely with their attorney, accountant or other professionals regarding their financial and personal situation. After completing a review and analysis of the information and documents received, the representatives develop their analyses and recommendations and present either a full or modular (segmented) written KingsMark Private Financial Advisors, LLC 6 Form ADV Part 2A: Firm Brochure financial plan to the client. A full plan focuses on a client’s overall financial situation and covers several of the areas previously noted, as needed by client’s specific situation. A modular (segmented) plan focuses only on one or more specific area(s) of client concern, and clients should be aware that other important issues may not be taken into consideration when KingsMark’s representatives develop their analyses and recommendations. Investment Management Services KingsMark provides investment management services by providing clients with continuous and on-going supervision over their accounts. This means that KingsMark continuously monitors a client’s account and makes trades in that account when necessary or desirable in order to meet the client’s investment objectives. KingsMark provides investment management services, defined as giving regular investment advice and/or making investments for the client based on the individual needs, goals and objectives of the client. KingsMark offers a customized and individualized investment management program providing clients advice regarding various asset classes (including equity and fixed income securities), ongoing assistance with evaluating and selecting investments, adjusting and rebalancing portfolios. In some instances, KingsMark may serve as a sub-advisor or co-advisor when working with investment management programs offered by other registered investment adviser firms. KingsMark assists the client in establishing one or more investment account(s) with a qualified custodian. Certain programs offered by KingsMark may require that a client use a particular custodian to maintain the account. In addition, KingsMark will recommend particular broker/dealers and custodians based on currently established relationships. While clients are always free to choose any broker/dealer or custodian they want to maintain their account(s), KingsMark only allows clients to direct it to use a particular broker/dealer or custodian in limited circumstances. It is KingsMark’s discretion whether or not it will manage an account that is not maintained at one of the custodians recommended by KingsMark. The qualified custodian maintains custody of all client funds and securities. KingsMark does not act as custodian and does not have direct access to client funds and securities. KingsMark provides investment management services on either a discretionary or non-discretionary basis. On a discretionary basis, KingsMark may make all decisions to buy, sell or hold securities, cash or other investments in the managed account in KingsMark’s sole discretion without consulting with the client before making any transactions. Clients must provide KingsMark with written authorization to exercise this discretionary authority, and they can place reasonable restrictions and limitations on the discretionary authority. If asset management services are provided on a non-discretionary basis, this means that KingsMark always contacts the client before implementing any transactions in an account. See Item 16, Investment Discretion, for additional discussion on discretionary and non-discretionary authority. KingsMark provides investment management services, as described above, though several different custodians. At present, these include Charles Schwab & Co., Inc., Wilmington Trust Company, American Funds, Ameritas, Pacific Life, and Security Benefit, among others. See Item 12, Brokerage Practices, for additional information. Selection of Other Advisers As part of our investment advisory services, KingsMark may recommend that the client use the services of an unaffiliated, third-party investment adviser ("TPA") to manage the entire, or a portion of the investment portfolio. After gathering information about specific financial situation and objectives, KingsMark may recommend that the client engage a specific TPA or investment program. KingsMark has the discretion to hire or fire the TPA. The TPA will actively manage the client’s portfolio and will assume discretionary investment authority over the account. Factors that KingsMark takes into consideration when making recommendation(s) include, but are not limited to, the following: the TPA's performance, methods of analysis, fees, financial needs, investment goals, risk tolerance, and investment objectives. KingsMark will periodically monitor the TPAs' performance to ensure management and investment style remains aligned with the client’s investment goals and objectives. KingsMark Private Financial Advisors, LLC 7 Form ADV Part 2A: Firm Brochure If a TPA is recommended to the client, the client will be required to sign an agreement directly with the recommended TPAs. The client may terminate their advisory relationship with the TPA according to the terms of the agreement with the TPA. The client should review each TPA's brochure for specific information on how to terminate the advisory relationship with the TPA and how to receive a refund, if applicable. Contact the TPA directly for questions regarding an advisory agreement with the TPA. Retirement Plan Services We offer retirement plan consulting services to retirement plan sponsors. We also offer consulting and investment management services to individual participants in retirement plans. For a corporate sponsor of a retirement plan, KingsMark’s retirement plan services may include, but are not limited to, the following services: Fiduciary Consulting Services
• Investment Policy Statement Preparation. KingsMark may help clients develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the plan. Clients have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. KingsMark may provide clients with general, non- discretionary investment advice regarding assets classes and investment options, consistent with the plan’s investment policy statement.
• Investment Selection Services. KingsMark may provide clients with recommendations of investment options consistent with ERISA Section 404(c). Clients have the ultimate responsibility for compliance with Section 404(c).
• Investment Due Diligence Review. KingsMark may provide clients with periodic due diligence reviews of the plan’s reports, investment options and recommendations.
• Investment Monitoring. KingsMark may assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement. KingsMark makes recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. KingsMark may provide clients with non-discretionary investment advice to assist with developing qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who otherwise fail to make an investment election. Clients retain the sole responsibility to provide all notices to participants required under ERISA Section 404(c)(5).
• Individualized Participant Advice. Upon request, KingsMark may provide one-on-one advice to plan participants regarding their

individual situations. KingsMark acknowledges that in performing the fiduciary consulting services listed above it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. KingsMark acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause KingsMark to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, KingsMark (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of the client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets and (c) is not the “administrator” of the client’s retirement plan as defined in ERISA. KingsMark Private Financial Advisors, LLC 8 Form ADV Part 2A: Firm Brochure Non-Fiduciary Services
• Participant Education. KingsMark may provide education services to plan participants about general investment principles and the investment alternatives available under the plan. KingsMark’s assistance in participant investment education is consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations do not take into account the individual circumstances of each participant and do not refer to the appropriateness of any specific investment alternatives or options for the participants. Individual recommendations are not provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. KingsMark may assist clients with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. These meetings do not include recommendations with respect to any specific investment alternatives or options available to participants.
• Qualified Plan Development. KingsMark may assist clients with establishing a qualified plan by working with clients and a selected third party administrator. If clients have not already selected a third party administrator, KingsMark assists clients with reviewing and selecting a third party administrator for the plan. The client retains final decision-making authority over the selection of the third party administrator.
• Due Diligence Review. KingsMark may provide clients with periodic due diligence reviews of the plan’s fees and expenses and the plan’s service providers. The client retains final decision- making authority over the hiring and firing of the plan’s service providers. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non- fiduciary are not considered fiduciary services for the purposes of ERISA since KingsMark is not acting as a fiduciary to the plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to clients are listed and detailed in the Qualified Retirement Plan Agreement. All recommendations of investment options and portfolios are submitted to the client for ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept or reject KingsMark’s investment recommendations and, if accepted, to then physically make changes to the plan itself. In the event a client contracts with KingsMark for one-on-one consulting services with plan participants, those services are consultative in nature and do not involve KingsMark implementing recommendations in individual participant accounts. It is the responsibility of each participant to implement changes in the participant’s individual accounts. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. KingsMark may recommend that a client or prospective client roll over their retirement plan assets into an account to be managed by KingsMark. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement plan assets into an account to be managed by KingsMark, such a recommendation creates a conflict of interest as we will earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Retirement plan consulting services are not investment management services, and KingsMark does not serve as administrator or trustee of the plan. KingsMark does not act as custodian for any client account or have access to client funds or securities (with the exception of some accounts having written authorization from the client to deduct advisory fees). In addition, KingsMark does not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the KingsMark Private Financial Advisors, LLC 9 Form ADV Part 2A: Firm Brochure retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. KingsMark will disclose to client, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to the information that KingsMark is required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which KingsMark is informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond KingsMark’s control, in which case the information will be disclosed as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), KingsMark will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or plan administrator (unless such disclosure is precluded due to extraordinary circumstances beyond KingsMark’s control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If KingsMark makes an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), KingsMark will disclose to the client the correct information as soon as practicable, but no later than thirty (30) days from the date on which KingsMark learns of such error or omission. Types of Investments KingsMark provides advice on the following types of investments:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Interests in partnerships involving real estate and involving oil and gas interests
• Covered call options
• Non-covered call options
• Put options We reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives whether or not listed here. Please refer to Item 8, Methods of Analysis, Investment Strategies and Risk of Loss for more information. Individual Needs of Clients KingsMark’s services are always provided based on the specific needs of the individual client. Clients are given the ability to impose reasonable restrictions on their accounts, including specific investment selections and sectors. However, KingsMark will not enter into an investment adviser relationship with a client whose investment objectives may be considered incompatible with KingsMark's investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Retirement Plan Rollovers When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income KingsMark Private Financial Advisors, LLC 10 Form ADV Part 2A: Firm Brochure Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with our client’s interests, so we operate under a special rule that requires us to act in our client’s best interest and not put our interest ahead of our clients. A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we are asked by a client or prospective client to make a recommendation from among these choices, we have a conflict of interest in that we have an incentive to recommend that a client roll over their retirement plan assets into an account to be managed by Aspire in order to earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict of interest by reviewing any such recommendation to ensure it is in the best interest of the client. No client is under any obligation to roll over retirement plan assets to an account managed by us. Wrap-Fee Program versus Portfolio Management Program In traditional management programs, advisory services are provided for a fee and transaction services are billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction services are provided for one fee. KingsMark does not act as a portfolio manager of, participate in, or sponsor any wrap fee programs. Client Assets Managed by Advisor The amount of client assets managed or advised by KingsMark totaled $353,046,148 as of December 31, 2023. As of that date, KingsMark had $329,065,540 assets under management managed on a discretionary basis and $23,980,608 on a non-discretionary basis. In addition, KingsMark has assets under advisement totaling $ 5,207,907.