KWMG LLC, d/b/a Keen Wealth Advisors (hereafter referred to as “KWA” or “we”) is a limited liability company formed in the State of Missouri and has been in business as a registered investment adviser since 2014. The firm is owned by William T. Keen Trust (92.5%) through a subsidiary, KWA Holdings, LLC as of June 30, 2023, and Matthew Wilson (7.5%) through a subsidiary, MDW Holdings, LLC as of June 30, 2023. Matthew Wilson is the Chief Compliance Officer as of July 19, 2021. We specialize in providing our clients (individuals who have an executed advisory agreement) with comprehensive portfolio management services as described in this wrap fee brochure. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, time horizon, and other pertinent factors, with a focus on building wealth for their retirement years. A wrap fee program allows our clients to pay a specified fee for investment advisory services and the execution of transactions. The advisory services may include portfolio management and/or advice. The fee is not based directly upon transactions in your account. Types of Wrap Advisory Services We Offer. Wrap Comprehensive Portfolio Management. Our comprehensive portfolio management service includes asset management services, financial planning, and financial consulting to clients. The majority of our clients engage KWA in this capacity. As a condition of this service, we require discretionary trading authorization on client accounts, which enables us to manage your accounts based on your financial situation, investment objectives, and risk tolerance. We actively monitor the account and provide advice regarding buying, selling, reinvesting, or holding securities, cash or other investments of the account. All clients are offered a financial plan as part of our portfolio management services. These plans will be evaluated and potentially amended to help align them to the client's goals and objectives without approval from the client. All accounts are monitored in the same manner, whether a financial plan was created or not. On a limited basis, clients are able to open accounts with KWA without completing a financial plan. Accounts opened under these circumstances will be monitored in the same manner as accounts that are opened under our more comprehensive portfolio management service. We conduct at least one, but sometimes more than one, meeting (in person, if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. You are responsible for notifying us of any significant changes and updates regarding your financial situation, risk tolerance or investment objectives, and whether you wish to impose or modify existing investment restrictions; however, we will attempt to contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance, or investment objectives. We are always available to consult with you relative to the status of your account. We may propose an investment approach consisting of exchange-traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. We may periodically rebalance or adjust client accounts under our discretionary management. It is important that each client understands that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell, or recommend any security or other investment that we may buy, sell, or recommend for any other clients or for our own accounts. A majority of our clients will open an account under the wrap fee program. In limited circumstances, clients will be able to open accounts under the non-wrap fee program. A non-wrap account may be assessed transaction fees for the execution of trades, and there is also the possibility that you will pay exchange fees in your account on certain transactions. Non-wrap fee accounts are only offered to (1) KWA employees and their applicable family members, (2) accounts that only hold a concentrated position or non-discretionary accounts and are not actively managed, (3) Donor Advised Funds (DAF), and (4) Personal Choice Retirement Accounts (PCRA) through Schwab Advisor Services. PCRAs are self- directed brokerage accounts that reside within an employer-sponsored retirement plan. Certain employers allow their plan participants to move a portion of their retirement plan assets to this type of account, which then can be managed by KWA. Schwab Advisor Services (“Schwab”) eliminated commissions for online trades of U.S. equities, ETFs and options. This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. When you enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account, please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. Retirement Plan Services. KWA offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. KWA operates in an ERISA 3(21) co-fiduciary capacity. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: For Fiduciary Management, we offer (1) Discretionary Management Services which allow KWA to provide individuals with continuous and ongoing supervision over the designated retirement plan assets by making all decisions to buy, sell, or hold securities, cash, or other investments by giving instructions, on your behalf, to brokers and dealers and the qualified custodian (2) Discretionary Investment Selection Services which includes monitoring, adding, and/or removing investment options for the plan participant with discretionary authority (3) Default Investment Alternative Management, in which KWA will develop and actively manage 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. For Fiduciary Consulting, we offer (1) Non-Discretionary Investment Advice, in which KWA will provide you with general investment advice regarding asset classes and investment options, consistent with your plan’s investment policy statement with Non-Discretionary authority (2) Investment Selection Services, in which KWA will provide you with recommendations of investment options consistent with ERISA section 404(c) (3) Investment Due Diligence, where KWA will provide periodic reviews of the plans reports, including possible investment options and recommendations (4) Investment Monitoring, in which KWA will assist in monitoring investment options via generated investment reports, confirming alignment with investment policy statements, and recommending removal or no changes regarding investment options (5) Individualized Participant Advice, which upon request KWA will provide one-on- one advice to plan participants regarding their individual situations. Retirement Plan Rollover Recommendations can be included within investment advice given to clients. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by KWA, please know that KWA and our investment adviser representatives have a conflict of interest. We could earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to an IRA managed by KWA. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by us. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (1) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (2) not recommend investments that result in KWA receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (3) fully disclose compensation received by KWA and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to you regarding a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of KWA or our affiliated personnel. Acknowledgment of Fiduciary Duty: When KWA provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, rollover such investment/proceeds from the retirement plan account to an IRA or make a distribution from the retirement plan account, KWA acknowledges that KWA is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way KWA makes money creates some conflicts with your interests, so KWA operates under a special rule that requires us to act in your best interest and not put our interests ahead of you. Under this special rule’s provisions, KWA must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g., give prudent advice);
• Never put the financial interests of KWA ahead of you when making recommendations (e.g., give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that KWA gives advice that is in your best interest;
• Charge no more than is reasonable for KWA’s services; and
• Give the client basic information about conflicts of interest. Third Party Money Managers. KWA only offers asset management services through third-party money managers to clients who are currently receiving this advisory service. This service is grandfathered for these clients only. The third-party managers are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Under this program, we assist the client with identifying their risk tolerance and investment objectives. We are available to answer questions that clients may have regarding their account(s) and act as the communication conduit between the client and the third-party money manager. The third-party money manager will take discretionary

authority to determine the securities to be purchased and sold for your account. We do not have any trading authority with respect to your designated account managed by the third-party money manager. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third-party investment adviser recommended by our firm. Further, no guarantees of performance can ever be offered by our firm. Under this program, clients may incur additional charges including but not limited to, mutual fund 12b-1 fees and surrender charges. Administrative Services Provided by Orion Advisor Services, LLC KWA has contracted with Orion Advisor Services, LLC (referred to as “Orion”) to utilize its technology platforms to support data reconciliation, fee calculation and billing, research, client database maintenance, reports, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Orion will have access to client accounts, but Orion will not serve as an investment advisor to Keen Wealth Advisor clients. KWA and Orion are non- affiliated companies. Clients will have access to view account performance through the Orion portal. There is not an additional charge for this access. The Orion Vault/Portal is an alternative method for clients to provide documents containing sensitive information in a secure manner, separate of our standard email encryption. This service is made available to clients upon request. Fees for Our Wrap Asset Management Services. Comprehensive Wrap Portfolio Management Fee Schedule. KWA will assess a Management Fee (the “Management Fee”) to provide discretionary portfolio management services. The Management Fee is an annual fee based on a percentage of the client’s assets under management unless specifically excluded. The following is a sample fee schedule provided for illustrative purposes. Since the exact fees and other terms may vary, they will be outlined in the Wrap Comprehensive Portfolio Management Agreement which is signed by the client and KWA. This agreement is required to be in place prior to the commencement of any portfolio management services. Management Fees for our comprehensive portfolio and asset management services are charged based on a percentage of assets under management, billed in advance (at the start of the billing period) on a quarterly calendar basis. Fees are calculated based on the fair market value of your account(s) as of the last business day of the previous quarter as provided by Orion, our third-party technology platform provider, unless KWA otherwise agrees in writing. The total account value of the advisory managed account shall be determined on the basis of such asset reports as provided by Orion or by any investment vehicle utilized in the account. As such, you may see slight differences in the quarter-end market value of your account from your custodian’s statement as compared to the market value of your account from Orion, due to differences in the treatment of accrued interest posting, trade date versus settlement date, and other variables. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account(s) opened at any time other than the beginning of the billing period. If asset management services are commenced in the middle of a billing period, the prorated fee for the initial billing period is billed in arrears at the same time as the next full billing period’s fee is billed. Margin accounts are billed on the total market value and are not reduced by the margin balance on the account. Our fee schedule operates on a tiered system based on Assets Under Management (AUM). As AUM crosses into a new fee bracket, the fee for that tier applies to the total billable account value above the prior bracket's threshold. Fee rates are agreed to and disclosed in your KWA agreement. Any excess AUM above a threshold is charged at the next tier's rate. Additionally, changes to a fee schedule will be applied to the next fee billing cycle. The fee schedule will not be prorated back to the time of the amended agreement. Our fees are negotiable on a limited basis based on the complexity of the client’s situation, the composition of the client’s account(s), the potential for additional account deposits, the relationship of the client with the firm and the total amount of assets under management for the client. Adjustments will be made for deposits and withdrawals during the quarter. These adjustments are based on debits and credits of $50,000 or more that occur within the same business day. Assets Under ManagementAnnual Percentage of Assets Charge $0 to $499,999.992.00% $500,000 to $999,999.991.85% $1,000,000 to $1,999,999.991.70% Over $2,000,0001.60% Deduction of Client Fees. Fees will be automatically deducted from your managed account on a quarterly basis. In rare cases, we will agree to bill clients directly. As part of the automatic fee deduction process, please note the following:
• You provide written authorization to the custodian in their custodial client agreement, permitting us to be paid directly from the managed account held by the independent custodian. We will provide the custodian with a fee notification file;
• Our firm sends an electronic request to the custodian indicating the amount of the fee to be paid from the client’s managed account;
• Your independent custodian sends statements at least quarterly to you showing the market values for each security included in the assets and all disbursements in your account, including the amount of the advisory fees paid to us;
• As required by paragraph (a)(2) of Rule 206(4)-2 under the Investment Advisers Act of 1940, if we send our own statement to our clients, we urge them to compare information provided in their statements with those from the qualified custodian in account opening notices and subsequent statements. Annual Fees. KWA believes that its annual fee is reasonable in relation to: (1) services provided and (2) the fees charged by other investment advisers offering similar services/programs. However, our annual investment advisory fee may be lower or higher than that charged by other investment advisers offering similar services/programs. You should review your account statements received from the qualified custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified custodian(s) will not verify the accuracy of the investment advisory fees deducted. Through investment selection and active account management, KWA attempts to minimize many of the charges that would otherwise be imposed by third parties. However, it should be known that in rare cases when these fees do occur, the Management fees charged by KWA are separate and distinct from the fees and expenses charged by investment companies. A description of these fees and expenses are available from each investment company. You may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark- downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees, charitable donor-advised fund accounts and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Fees for Financial Planning and Consulting Services. Hourly Fee. KWA provides financial planning and consulting services under an hourly fee arrangement. An hourly fee of $1,000 is charged by KWA under this arrangement. This fee is negotiable on a limited basis and based on the scope and complexity of the client’s situation. Before commencing financial planning services, KWA provides an estimate of the approximate hours needed to complete the requested financial planning services. If KWA anticipates exceeding the estimated number of hours required, KWA will contact you to receive authorization to provide additional services. You will pay in advance a retainer equal to 50% of the estimated total of the financial planning and consulting services with the remainder of the fee directly billed to you and due within thirty (30) days of delivery of your financial plan. Under no circumstances will KWA require you to pay fees more than $1,200 more than six months in advance. Any unpaid hourly fees are due immediately upon completion and delivery of the financial plan. Fixed Fee. At our sole discretion, you may be required to pay in advance of the fixed fee at the time you execute an agreement with KWA; however, at no time will KWA require payment of more than $1,200 in fees more than six months in advance. Upon completion and delivery of the financial plan, the fixed fee is considered earned by KWA and any unpaid amount is immediately due. Clients may choose to pay for financial planning or consulting services by check. All or a portion of the financial planning or consulting services may be waived by KWA at our sole discretion. Fees for Retirement Plan Services. Retirement plan fees are negotiated by the retirement plan sponsor; however, the assessed fee is billed to the individual participant’s account. For retirement plan participants, KWA will charge an annual fee that is billed quarterly and is calculated as a percentage of the value of participants’ managed assets. This fee is negotiable by the plan sponsor based on the complexity of the plan, the size of the plan assets, and the actual services requested. For retirement plan sponsors and participants, fees are billed in advance (at the start of the billing period) on a quarterly calendar basis and calculated based on the fair market value of your account as of the last business day of the previous billing period. Your specific fee will be disclosed in your KWA Agreement. Fees are prorated (based on the number of days service is provided during the initial billing period) for your account opened at any time other than the beginning of the billing period. Either party may terminate services by providing written notice of termination to the other party. If services are terminated within five business days of signing the client agreement, services are terminated without penalty. Any prepaid but unearned fees are promptly refunded to the client at the effective date of termination. KWA does not reasonably expect to receive any other compensation, direct or indirect, for its Services. If we receive any other compensation for such services, we will (1) offset that compensation against our stated fees, and (2) disclose the amount of such compensation, the services rendered for such compensation, and the payer of such compensation to you. Fees for Third-Party Money Managers. KWA no longer offers this advisory service to new clients. KWA will continue to offer third-party management services only to clients currently using this service. Third-party managers generally have account minimum requirements that will vary among third-party money managers. Account minimums are generally higher for fixed-income accounts than for equity-based accounts. A complete description of the third-party money managers’ services, fee schedules, and account minimums will be disclosed in the third-party money managers disclosure brochure, which will be provided to clients prior to or at the time an agreement for services is executed and the account is established. Please refer to your agreement with the third party and their ADV Part 2A to review their associated fees, calculations, and methodology. The actual fee charged on accounts with third-party money managers will vary depending on the manager and the investment strategy of the account. KWA bills the client a management fee which is separate from the management fee charged by the third-party manager. The combined fee from the third-party manager and KWA’s fee will not exceed the agreed-upon fee listed in the KWA Agreement. Under this program, clients may incur additional charges including but not limited to, mutual fund 12b-1 fees and surrender charges.