A. Korhorn Financial Group (“KFG”) is a limited liability company formed under the laws of
the state of Indiana. KFG became a registered investment adviser in April 2007. KFG is
owned by Korhorn Financial Group, Inc., which is principally owned by KFG’s President,
Kevin Korhorn.
B.
INVESTMENT ADVISORY SERVICES
Client may engage KFG to provide discretionary investment advisory services on a fee
basis. KFG’s annual investment advisory fee is based upon a percentage (%) of the market
value and type of assets placed under KFG’s management (generally between negotiable
and 1.25%).
SEI ASSET MANAGEMENT PROGRAM
KFG may direct all of a portion of a client’s account to the SEI Asset Management Program
(SEI Program). The SEI Program is offered on a wrap-fee basis and is an institutional asset
allocation program. KFG’s associated persons assist you in establishing an SEI Program
Account (the Account) at SEI Trust Company (SEI). All transactions in your account will
be processed and cleared through SEI. The SEI Program uses asset allocation portfolios
developed by SEI Investments. The portfolios consist of SEI Family of Institutional Mutual
Funds (Mutual Funds) and other securities approved by SEI to be held in an account.
KFG provides SEI with the asset allocation policy (Asset Allocation Policy) that our clients
select for their Account. KFG directs SEI to reallocate client investments in accordance
with each client’s asset allocation policy. In addition, KFG directs SEI to rebalance the
investments within client accounts at least quarterly so that the market value of the shares
of each mutual fund held in client accounts are the same percentage of the total market
value of their account as required by the clients asset allocation policy. SEI holds custody
of all SEI Program client Account assets.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
To the extent specifically requested by a client, KFG may provide financial planning and/or
consulting services (including investment and non-investment related matters, including
estate planning, insurance planning, etc.) on a stand-alone separate fee basis.
KFG offers financial planning and consulting services on either a comprehensive or single-
needs basis. If a client chooses to engage KFG to provide comprehensive financial planning
and consulting services, KFG will prepare a written financial plan, analysis and/or
recommendations targeting your needs. Additionally, for a twelve (12) month period
beginning at the time a comprehensive Financial Planning and Consulting Agreement is
executed, those clients who choose to engage KFG to provide comprehensive financial
planning and consulting services will be eligible for ongoing consultations, reviews, and
monitoring of the client’s investment accounts. Whereas, those clients choosing to engage
KFG on a single-needs basis will receive a written financial plan but no additional financial
planning and consulting services under their agreement.
Prior to engaging KFG to provide planning or consulting services, clients are generally
required to enter into a Financial Planning and Consulting Agreement with KFG setting
forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the portion of the fee that is due from the client
prior to KFG commencing services (if any).
If requested by the client, KFG may recommend the services of other professionals for
implementation purposes, including KFG’s representatives in their individual capacities as
registered representatives of a broker-dealer and/or licensed insurance agents. (See
disclosures at Item 10.C). The client is under no obligation to engage the services of any
such recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from KFG.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional.
It remains the client’s responsibility to promptly notify KFG if there is ever any change in
their financial situation or investment objectives for the purpose of reviewing, evaluating
or revising KFG’s previous recommendations and/or services.
RETIREMENT PLAN SERVICES
KFG also provides retirement plan consulting and management services, pursuant to which
it assists sponsors of retirement plans organized under the Employee Retirement Security
Act of 1974 (“ERISA”). The terms and conditions of the engagement shall be set forth in
a Retirement Plan Services Agreement between KFG and the plan sponsor.
If the plan sponsor engages KFG in an ERISA Section 3(21) capacity, KFG will assist with
the selection and/or monitoring of investment options (generally open-end mutual funds
and exchange traded funds) from which plan participants shall choose in self-directing the
investments for their individual plan retirement accounts. If the plan sponsor chooses to
engage KFG in an ERISA Section 3(38) capacity, KFG may provide the same services as
described above, but may also: create specific asset allocation models, modify the
investment options made available to plan participants or manage a plan’s pooled assets on
a discretionary basis.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, KFG may provide
financial planning and related consulting services. Neither KFG nor its investment adviser
representatives assist clients with the implementation of any financial plan, unless they
have agreed to do so in writing. KFG does not monitor a client’s financial plan, and it is
the client’s responsibility to revisit the financial plan with KFG, if desired.
KFG may provide financial planning and related consulting services regarding non-
investment related matters, such as estate planning, tax planning, insurance, etc. KFG does
not serve as an attorney, and no portion of our services should be construed as legal
services. Accordingly, KFG does not prepare estate planning documents.
To the extent requested by a client, we may recommend the services of other professionals
for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance,
etc.), including certain supervised persons of KFG in their separate individual capacities as
registered representatives of Silver Oak Securities, Inc. (“Silver Oak Securities”), a SEC
registered and FINRA member broker-dealer and as licensed insurance agents. KFG may
also recommend certain affiliated service providers such as KFG Tax and Business
Services, LLC, an affiliated bookkeeping and tax service provider and KFG Insurance
Agency, LLC, an affiliated insurance agency.
The client is under no obligation to engage the services of any recommended professional.
The client retains absolute discretion over all implementation decisions and is free to accept
or reject any recommendation from KFG and/or its representatives.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from
and against the engaged professional.
eMoney Advisor Platform. KFG may provide its clients with access to an online platform
hosted by “eMoney Advisor” (“eMoney”). The eMoney platform allows a client to view
their complete asset allocation, including those assets that KFG does not manage (the
“Excluded Assets”). KFG does not provide investment management, monitoring, or
implementation services for the Excluded Assets. Therefore, KFG shall not be responsible
for the investment performance of the Excluded Assets. Rather, the client and/or their
advisor(s) that maintain management authority for the Excluded Assets, and not KFG, shall
be exclusively responsible for such investment performance. Without limiting the above,
KFG shall not be responsible for any implementation error (timing, trading, etc.) relative
to the Excluded Assets. The client may choose to engage KFG to manage some or all of
the Excluded Assets pursuant to the terms and conditions of an Investment Advisory
Agreement between KFG and the client.
The eMoney platform also provides access to other types of information and applications
including financial planning concepts and functionality, which should not, in any manner
whatsoever, be construed as services, advice, or recommendations provided by KFG.
Finally, KFG shall not be held responsible for any adverse results a client may experience
if the client engages in financial planning or other functions available on the eMoney
platform without KFG’s assistance or oversight.
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or
prospective client leaving an employer 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 KFG recommends that a client roll over their
retirement plan assets into an account to be managed by KFG, such a recommendation
creates a conflict of interest if KFG will earn a new (or increase its current) advisory fee as
a result of the rollover. If KFG provides a recommendation as to whether a client should
engage in a rollover or not, KFG is acting as a fiduciary 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. No client is under any
obligation to roll over retirement plan assets to an account managed by KFG.
Independent Managers. KFG may allocate a portion of the client’s investment assets
among unaffiliated independent investment managers in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager[s] shall
have day-to-day responsibility for the active discretionary management of the allocated
assets, including, to the extent applicable, proxy voting responsibility. KFG shall continue
to render investment supervisory services to the client relative to the ongoing monitoring
and review of account performance, asset allocation and client investment objectives.
Factors that KFG shall consider in recommending Independent Manager[s] include the
client’s designated investment objective(s), management style, performance, reputation,
financial strength, reporting, pricing, and research. The investment management fee
charged by the Independent Manager[s] is separate from, and in addition to, KFG’s
investment advisory fee disclosed at Item 5 below.
Use of Mutual Funds and Exchange Traded Funds. While KFG may recommend
allocating investment assets to mutual funds and exchange traded funds (“ETFs”) that are
not available directly to the public, KFG may also recommend that clients allocate
investment assets to publicly available mutual funds and ETFs that the client could obtain
without engaging KFG as an investment advisor. However, if a client or prospective client
determines to allocate investment assets to publicly available mutual funds and ETFs
without engaging KFG as an investment advisor, the client or prospective client would not
receive the benefit of KFG’s initial and ongoing investment advisory services.
Dimensional Funds. As noted above,
many mutual funds are available directly to the
public, without need to engage an investment professional. Other mutual funds, such as
those issued by Dimensional Fund Advisors (“DFA”), are generally only available through
registered investment advisers. KFG utilizes DFA mutual funds. Therefore, if the client
was to terminate KFG’s services, restrictions regarding transferability and/or additional
purchases of, or reallocation among, DFA funds will apply.
Structured Notes. KFG may purchase Structured Notes for client accounts. A Structured
Note is a financial instrument that combines two elements, a debt security and exposure to
an underlying asset or assets. It is essentially a note, carrying counter party risk of the
issuer. However, the return on the note is linked to the return of an underlying asset or
assets (such as the S&P 500 Index or commodities). It is this latter feature that makes
structured products unique, as the payout can be used to provide some degree of principal
protection, leveraged returns (but usually with some cap on the maximum return), and be
tailored to a specific market or economic view. Structured Notes will generally be subject
to liquidity constraints, such that the sale thereof before maturity will be limited, and any
sale before the maturity date could result in a substantial loss. There can be no assurance
that the Structured Notes investment will be profitable, equal any historical performance
level(s), or prove successful.
If the issuer of the Structured Note defaults, the entire value of the investment could be
lost.
Innovator Defined Outcome ETFs™. When consistent with a client’s investment
objectives, KFG may allocate investment assets to Innovator Defined Outcome ETFs.
Innovator Defined Outcome ETFs are generally designed for defined upside growth and
downside buffer (or floor) levels, or defined acceleration, with various market exposures
(e.g., US Equity, US Technology, International, Emerging Markets, and US Treasuries).
The funds only seek to provide shareholders that hold shares for the entire Outcome Period
with their respective buffer level against Index losses during the Outcome Period. You will
bear all reference asset losses exceeding the buffer. Depending upon market conditions at
the time of purchase, a shareholder that purchases shares after the Outcome Period has
begun may also lose their entire investment. Fund shareholders are subject to an upside
return cap (the “Cap”) that represents the maximum percentage return an investor can
achieve from an investment in the funds for the Outcome Period, before fees and expenses.
If the Outcome Period has begun and the Fund has increased in value to a level near to the
Cap, an investor purchasing at that price has little or no ability to achieve gains but remains
vulnerable to downside risks. Additionally, the Cap may rise or fall from one Outcome
Period to the next. The Cap, and the Fund’s position relative to it, should be considered
before investing in the Fund.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing
involves the incorporation of Environmental, Social and Governance (“ESG”)
considerations into the investment due diligence process. ESG investing incorporates a set
of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company
manages relationships with its employees, customers, and the communities in which it
operates); and Governance (i.e., company management considerations). The number of
companies that meet an acceptable ESG mandate can be limited when compared to those
that do not and could underperform broad market indices. Investors must accept these
limitations, including potential for underperformance. Correspondingly, the number of
ESG mutual funds and exchange-traded funds are limited when compared to those that do
not maintain such a mandate. As with any type of investment (including any investment
and/or investment strategies recommended and/or undertaken by KFG), there can be no
assurance that investment in ESG securities or funds will be profitable or prove
successful. KFG does not maintain or advocate an ESG investment strategy but will seek
to employ ESG if directed by a client to do so. If implemented, KFG shall rely upon the
assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate
account portfolio manager to determine that the fund’s or portfolio’s underlying company
securities meet a socially responsible mandate.
Cryptocurrency. Cryptocurrency is a digital currency that can be used to buy goods and
services but uses an online ledger with strong cryptography (i.e., a method of protecting
information and communications through the use of codes) to secure online transactions.
Unlike conventional currencies issued by a monetary authority, cryptocurrencies are
generally not controlled or regulated and their price is determined by the supply and
demand of their market. Because cryptocurrency is currently considered to be a
speculative investment, KFG will not exercise discretionary authority to purchase a
cryptocurrency investment for client accounts. Rather, a client must expressly authorize
the purchase of the cryptocurrency investment.
KFG does not recommend or advocate the purchase of, or investment in, cryptocurrencies.
KFG considers such an investment to be speculative.
Clients who authorize the purchase of a cryptocurrency investment must be prepared for
the potential for liquidity constraints, extreme price volatility and complete loss of
principal.
Cash Positions. KFG continues to treat cash as an asset class. As such, unless determined
to the contrary by KFG, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating KFG’s advisory
fee. At any specific point in time, depending upon perceived or anticipated market
conditions/events (there being no guarantee that such anticipated market conditions/events
will occur), KFG may maintain cash positions for defensive purposes. In addition, while
assets are maintained in cash, such amounts could miss market advances. Depending upon
current yields, at any point in time, KFG’s advisory fee could exceed the interest paid by
the client’s money market fund.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion KFG shall (usually within 30
days thereafter) generally (with exceptions) purchase a higher yielding money market fund
(or other type security) available on the custodian’s platform, unless KFG reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to
purchase additional investments for the client’s account. Exceptions and/or modifications
can and will occur with respect to all or a portion of the cash balances for various reasons,
including, but not limited to the amount of dispersion between the sweep account and a
money market fund, the size of the cash balance, an indication from the client of an
imminent need for such cash, or the client has a demonstrated history of writing checks
from the account.
The above does not apply to the cash component maintained within a KFG actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager and cash balances
maintained for fee billing purposes.
The client shall remain exclusively responsible for yield dispersion/cash balance decisions
and corresponding transactions for cash balances maintained in any KFG unmanaged
accounts.
Client Obligations. In performing its services, KFG shall not be required to verify any
information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify KFG if there is ever any change in their financial situation
or investment objectives for the purpose of reviewing, evaluating or revising KFG’s
previous recommendations and/or services.
Cybersecurity Risk. The information technology systems and networks that KFG and its
third-party service providers use to provide services to KFG’s clients employ various
controls, which are designed to prevent cybersecurity incidents stemming from intentional
or unintentional actions that could cause significant interruptions in KFG’s operations and
result in the unauthorized acquisition or use of clients’ confidential or non-public personal
information. Clients and KFG are nonetheless subject to the risk of cybersecurity incidents
that could ultimately cause them to incur losses, including for example: financial losses,
cost and reputational damage to respond to regulatory obligations, other costs associated
with corrective measures, and loss from damage or interruption to systems. Although KFG
has established procedures to reduce the risk of cybersecurity incidents, there is no
guarantee that these efforts will always be successful, especially considering that KFG does
not directly control the cybersecurity measures and policies employed by third-party
service providers. Clients could incur similar adverse consequences resulting from
cybersecurity incidents that more directly affect issuers of securities in which those clients
invest, broker-dealers, qualified custodians, governmental and other regulatory authorities,
exchange and other financial market operators, or other financial institutions.
Disclosure Statement. A copy of KFG’s written Brochure and Client Relationship
Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be
provided to each client prior to, or contemporaneously with, the execution of the Investment
Advisory Agreement or Financial Planning and Consulting Agreement.
C. KFG shall provide investment advisory services specific to the needs of each client. Prior
to providing investment advisory services, an investment adviser representative will
ascertain each client’s investment objective(s). Thereafter, KFG shall allocate and/or
recommend that the client allocate investment assets consistent with the designated
investment objective(s). The client may, at any time, impose reasonable restrictions, in
writing, on KFG’s services.
D. Wrap/Separate Managed Account Programs: In the event that KFG is engaged to
provide investment advisory services as part of an unaffiliated wrap-fee program, KFG will
be unable to negotiate commissions and/or transaction costs. As a result, client may receive
less favorable net prices, on transactions for the account than would otherwise be the case
through alternative clearing arrangements recommended by KFG. Higher transaction costs
adversely impact account performance.
Under a wrap program, the wrap program sponsor arranges for the investor participant to
receive investment advisory services, the execution of securities brokerage transactions,
custody and reporting services for a single specified fee. Participation in a wrap program
may cost the participant more or less than purchasing such services separately.
E. As of December 31, 2023, KFG had $723,934,389 in assets under management on a
discretionary basis and $15,42,419 in assets under management on a non-discretionary
basis.