KCFA offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to KCFA rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with KCFA setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). KCFA is an SEC-registered investment adviser with its principal place of business located in New Jersey. KCFA began conducting business in 2018. The firm's shareholders are Richard Flora and Eric Fishman. As December 31, 2023, KCFA had $636,061,688 in assets under management, all of which was managed on a discretionary basis. While this brochure generally describes the business of KCFA, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on KCFA’s behalf and are subject to the Firm’s supervision or control. Financial Planning Services KCFA provides financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• Personal: KCFA reviews family records, budgeting, personal liability, estate information and financial goals.
• Tax & Cash Flow: KCFA analyzes the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability.
• Investments: KCFA analyzes investment alternatives and their effect on the client's portfolio.
• Insurance: KCFA reviews existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• Retirement: KCFA analyzes current strategies and investment plans to help the client achieve his or her retirement goals.
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• Death & Disability: KCFA reviews the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• Estate: KCFA assists the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. KCFA gathers required information through in-depth personal interviews and through an interactive online planning portal, through which the client can also enter and link information. Information gathered includes the client’s current financial status, tax status, future goals, returns objectives and attitudes towards risk. KCFA carefully reviews documents the client supplies, including a questionnaire completed by the client, and prepare a written or an interactive report. Should the client choose to implement the recommendations contained in the plan, KCFA suggests the client work closely with his/her appropriate professional partners. Implementation of financial plan recommendations is entirely at the client's discretion. KCFA also provides general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically the financial plan is presented to the client within three months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. In performing these services, KCFA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. KCFA recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage KCFA or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising KCFA’s recommendations and/or services. Investment Management Services KCFA provides continuous advice to clients regarding the investment of client funds based on the client’s individual needs. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, KCFA develops a client’s personal investment policy and creates and manages a portfolio based on that policy. During KCFA’s data-gathering process, the Firm determines the Page | 5 © MarketCounsel 2021 client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, KCFA also reviews and discusses a client’s prior investment history, as well as family composition and background. KCFA manages these advisory accounts on a discretionary basis. Account supervision is guided by the client’s stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or

industry sectors. KCFA’s investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Foreign issuers Warrants Corporate debt securities (other than commercial paper) Certificates of deposit Municipal securities Mutual fund shares Insurance products Unit Trusts United States governmental securities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. Retirement Plan Consulting Services KCFA also provides discretionary or non-discretionary advisory services to various retirement plans and accounts. While the primary clients for these services will be pension, profit sharing and 401(k) plans, KCFA offers these services, where appropriate, to individuals, trusts, estates and charitable organizations. Retirement Plan Consulting Services can include four distinct components. Investment Policy Statement Preparation (IPS) KCFA will meet with the client to determine an appropriate investment strategy that reflects the plan sponsor’s stated investment objectives for management of the overall plan. KCFA then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance.
Page | 6 © MarketCounsel 2021 Selection of Investment Vehicles KCFA assists plan sponsors in constructing appropriate asset allocation models. KCFA will then review various mutual funds (both index and managed) to determine which investments are appropriate to implement the client’s IPS. The number of investments to be recommended will be determined by the client, based on the IPS. Monitoring of Investment Performance KCFA monitors client investments regularly, based on the procedures and timing intervals delineated in the IPS. Employee Communications For 401(k) plan clients with individual plan participants exercising control over assets in their own account, KCFA also provides annual or more frequent educational support and investment workshops for the plan participants. The nature of the topics to be covered will be determined by KCFA and the client under the guidelines established in ERISA Section 404(c). The educational support and investment workshops will not provide plan participants with individualized, tailored investment advice or asset allocation recommendations. As disclosed in the Advisory Agreement, certain of the foregoing services are provided by KCFA as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of KCFA’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. Use of Independent Managers As mentioned above, KCFA selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. KCFA evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. KCFA also takes into consideration each Independent Page | 7 © MarketCounsel 2021 Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. KCFA continues to provide services relative to the discretionary or non-discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. KCFA seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.