KDKPWM offers a variety of advisory services, which include financial planning, consulting, investment management, and reporting services. Prior to KDKPWM rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with KDKPWM setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). KDKPWM registered as an investment adviser in January 2019. The Firm is principally owned by Kamden D. Kanaly as trustee of the Kamden D. Kanaly 1992 Gift Trust. As of December 31, 2022, the Firm had approximately $ 260,942,768 in assets under management, of which $ 257,036,518 was managed on a discretionary basis and $ 3,906,250 of which was managed on a non-discretionary basis. As part of its latest annual amendment the firm filed for registration with the Securities and Exchange Commission as a large investment adviser. While this brochure generally describes the business of KDKPWM, 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 KDKPWM’s behalf and are subject to the Firm’s supervision or control. Wealth Management Services The Firm generally offers clients financial planning and consulting as well as investment management services as part of a comprehensive wealth management engagement with clients. Financial Planning and Consulting Services KDKPWM offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence These services are not offered on a stand-alone basis, but rather, are rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement. In performing these services, KDKPWM 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. KDKPWM will recommend that certain clients engage the Firm for additional related services as well as other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage KDKPWM or its affiliates to provide (or continue to provide) additional services for compensation. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by KDKPWM. 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 KDKPWM’s recommendations and/or services. Investment Management Services KDKPWM manages client investment portfolios on a discretionary basis. KDKPWM primarily allocates client assets among various exchange-traded funds (“ETFs), mutual funds, and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. The Firm may also allocate client assets among individual debt and equity securities. In addition, KDKPWM also recommends that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage KDKPWM to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In

these situations, KDKPWM directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. KDKPWM tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. KDKPWM consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify KDKPWM if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if KDKPWM determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Sponsor and Manager of Wrap Program The Firm’s investment advisory services do not include securities brokerage services as the Firm does not serve as the sponsor or manager to a wrap fee program (i.e., an arrangement where certain brokerage commissions and transaction costs are absorbed by the Firm). Retirement Plan Consulting Services KDKPWM provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services:
• Plan Design and Strategy
• Plan Review and Evaluation
• Executive Planning & Benefits
• Investment Selection
• Plan Fee and Cost Analysis
• Plan Committee Consultation
• Fiduciary and Compliance
• Participant Education As disclosed in the Advisory Agreement, certain of the foregoing services are provided by KDKPWM 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 KDKPWM’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the engagement. The Firm also offers discretionary investment management services to qualified employee benefit plans. Use of Independent Managers As mentioned above, KDKPWM 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. KDKPWM 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. KDKPWM also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. KDKPWM 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. KDKPWM seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Reporting Services The Firm will provide stand-alone reporting services to high-net-worth clients and family offices who need the level of reporting and data that the Firm can provide through its technology infrastructure.