Keystone Financial Group is an investment adviser registered with the United States Securities and
Exchange Commission (“SEC”) and is a limited liability company (LLC) formed under the laws of the State
of Kentucky. Keystone Financial Group has established a network of representative offices that will
provide advisory services under local “doing business as” names. A complete list of approved doing
business as names came be found by searching for Keystone Financial Group, CRD# 170201 on the
Internet at
www.adviserinfo.sec.gov.
Keystone Wealth Managed Asset Program
We are the sponsor of the Keystone Wealth Managed Asset Program (“KEYMAP Program”), a wrap fee
or non-wrap fee asset management program developed through an arrangement using LPL Financial
Corporation’s (“LPL”) Strategic Wealth Management platform. Through the KEYMAP Program, we
provide investment management services, including providing continuous investment advice to and
making investments for you based on your individual needs. Through this service, we offer a customized
and individualized investment program. A specific asset allocation strategy and suitability profile is
crafted to focus on your specific goals and objectives. The IPS defines your risk tolerance and
investment objective. Your information should be updated regularly, but at a minimum every 2 years.
KEYMAP Program accounts are custodied at LPL in its capacity as a registered broker/dealer, member
FINRA/SIPC. LPL is also an investment advisor registered with the SEC, but does not serve as an
investment advisor for you through the KEYMAP Program. LPL provides clearing, custody and other
brokerage services for accounts established through the KEYMAP Program. Therefore, you are required
to establish a brokerage account(s) through LPL’s Strategic Wealth Management platform. Separate
accounts are maintained for you, and you retain all rights of ownership of you accounts (e. g., the right to
withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations).
KEYMAP Program accounts allow you to authorize us to purchase and sell, on either a discretionary
basis or non-discretionary basis, portfolios consisting of securities and investments. We may limit our
discretion with respect to your account and the securities eligible to be purchased for your account.
(See,
Limits Advice to Certain Types of Investments at Item 6, Portfolio Manager Selection and Evaluation
elsewhere in this Disclosure Brochure.)
With discretionary authority, we make all decisions to buy, sell or hold securities, cash or other
investments in the managed account in our sole discretion without consulting with you before
implementing any transactions. You must provide us with written authorization to exercise this
discretionary authority. Discretionary authority is limited. We do not have access to your funds and/or
securities with the exception of having advisory fees deducted from your account and paid to us by the
account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the
account custodian. You have the ability to place reasonable restrictions on the types of investments that
may be purchased in an account. You may also place reasonable limitations on the discretionary power
granted to us so long as the limitations are specifically set forth or included as an attachment to the client
agreement.
(Please see Item 16, Investment Discretion, in the separate Keystone Financial Group, LLC
Disclosure Brochure for additional information concerning discretionary authority.)
During any month that there is activity in the KEYMAP Program account, you receive a monthly account
statement from LPL showing account activity as well as positions held in the account at month end.
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Additionally, you receive a confirmation of each transaction that occurs within the KEYMAP Program
account unless the transaction is the result of a systematic purchase, redemption or exchange. You also
receive a detailed quarterly report showing performance, positions, and activity. All account data and
statements are also available on-line through the account view portal through LPL.
The annual investment advisory fee charged will vary between 0.25% – 2.75% of the assets held in the
account and is negotiable depending on the market value of the account, asset types, complexity of your
portfolio, your financial situation and trading activity. The annual fee is divided and paid quarterly in
advance through a direct debit to your account. LPL is responsible for calculating and debiting all fees
from your accounts. You must provide LPL with written authorization to debit advisory fees from your
accounts and pay the fees to Keystone Financial Group. Fees are based on the account's asset value as
of the last business day of the prior calendar quarter. Fees for accounts opened at any time other than
the beginning of a quarter are prorated based on the number of days remaining in the initial quarter.
Prior to engaging Keystone Financial Group to provide investment management services, you are
required to enter into a formal investment advisory agreement with us setting forth the terms and
conditions, including the amount of investment advisory fees, under which we manage your assets and a
also separate custodial/clearing agreement with LPL.
You can open a KEYMAP Program I or KEYMAP Program II account. A KEYMAP Program I account is a
non-wrap or traditional account. This means in addition to our investment advisory fee, you also certain
pay transaction charges to defray the
costs associated with trade execution. These costs are set out in
the LPL Strategic Wealth Management platform brokerage account and application agreement. The
KEYMAP Program II account is a wrap fee account, meaning you do not pay transaction charges
associated with trade execution.
The minimum account size to open any KEYMAP Program account is $10,000, although exceptions may
be granted upon request. Factors considered when granting an exception include the total value of the
overall engagement, the types of assets in the account, the time and resources expended on the services
and the relationship between the adviser providing services and the client.
You may incur certain charges imposed by third parties other than Keystone Financial Group in
connection with investments made through the account including, but not limited to, 12b-1 fees and
surrender charges, and IRA and qualified retirement plan fees. Our management fees (which include
transaction and execution fees charged by LPL for KEYMAP Program II accounts) are separate and
distinct from the fees and expenses charged by investment company securities that may be
recommended to you. A description of these fees and expenses are available in each investment
company security’s prospectus. Our representatives, in their separate capacity as registered
representatives of LPL, may retain a portion of the commissions charged to you. These commissions
may include 12b-1 fees, surrender charges and IRA and qualified retirement plan fees.
The KEYMAP Program I and KEYMAP Program II may cost you more or less than if the assets were held
in a traditional brokerage account. In a brokerage account, you are charged commissions for each
transaction, and the representative has no duty to provide ongoing advice with respect to the account. If
you plan to follow a buy and hold investment strategy for the account or do not wish to purchase ongoing
investment advice or management services, you should consider opening a brokerage account rather
than a KEYMAP Program I or KEYMAP Program II account.
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We do not always charge a lower advisory fee for KEYMAP Program I accounts versus KEYMAP
Program II accounts. The cost for a KEYMAP Program II account is typically higher than a KEYMAP I
Program. This is because transaction costs are passed along to you in KEYMAP Program I accounts
while the transaction costs are covered under the overall fee charged for KEYMAP Program II accounts.
When making the determination of whether one of the advisory programs available through Keystone
Financial Group is appropriate for your needs, you should bear in mind that fee-based accounts, when
compared with commission-based accounts, 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, the fee-based account arrangements may result in a higher annual cost for transactions.
Thus, depending on a number of factors, the total cost for transactions under a fee account versus a
commission account can vary significantly. Factors which affect the total cost include account size,
amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax
situation. It should also be noted that lower fees for comparable service may be available from other
sources. You should discuss the advantages and disadvantages of fee-based and commission-based
accounts with your adviser representative.
Either party may terminate the agreement for services at any time. If services are terminated within five
business days of executing the agreement, services are terminated without penalty and a full refund of all
fees paid in advance is provided. If services are terminated after the initial five day period, we provide
you with a prorated refund of fees paid in advance. The refund is based on the number of days service is
actually provided during the final billing period. Termination is effective from the time the other party
receives written notification or such other time as may be mutually agreed upon, subject to the settlement
of transactions in progress and the final refund of advisory fees. There is no penalty charge on
termination.
Additional Compensation, Economic and Non-Economic Benefits
Our representatives are also registered representatives of LPL, a securities broker-dealer. You may work
with your investment adviser representative in his or her separate capacity as a registered representative
of LPL. When acting in this separate capacity as a registered representative, your investment adviser
representative may sell, for commissions, general securities products such as stocks, bonds, mutual
funds, exchange-traded funds, and variable annuity and variable life products to you. As such, your
investment adviser representative may suggest that you implement investment advice by purchasing
securities products through a commission-based brokerage account in addition to or in lieu of a fee-based
investment-advisory account. This receipt of commissions creates an incentive to recommend those
products for which your investment adviser representative will receive a commission in his or her separate
capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the
advice rendered to you could be biased.
You are under no obligation to use the services of our representatives in this separate capacity or to use
LPL and can select any broker/dealer you wish to implement securities transactions. If you select our
representatives to implement securities transactions in their separate capacity as registered
representatives, they must use LPL.
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