Kinloch Capital, LLC (“Kinloch Capital”) has been in business since May of 2019. The firm is owned by Peter Walls. Kinloch Capital serves as an independent and unbiased advisor to our clients, characterized by a high level of accountability across the organization. As a fiduciary, Kinloch Capital places client interests at the forefront of all of its efforts. No adviser can guarantee that a client will meet their goals or achieve a given performance target, however Kinloch Capital does strive to provide all clients with the benefit of investment adviser representatives dedicated to providing attentive, client focused customer service. Asset Management If you wish us to manage your investment accounts, we will begin by determining investment guidelines, so that we can determine the model portfolios which meet your needs. Some examples of guidelines include your risk tolerance, or a maximum amount of assets to be held in non-U.S. investments, or a limit on the amount of stocks in your portfolio. Kinloch Capital can assist in developing these guidelines through the financial planning process described below. When we perform asset management services, we generally will do so on a discretionary basis. This means that while your advisor will communicate regularly with you, Kinloch Capital will not seek specific approval of changes within your portfolio. If Kinloch Capital is managing your assets, you may place reasonable restrictions on the types of investments in an account or portfolio. Because Kinloch Capital takes discretion when managing accounts, clients engaging the firm will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) through an Investment Management Agreement that outlines the responsibilities of both the client and Kinloch Capital. Our asset management services are a combination of value based long term buy and hold strategies and a dynamic strategy using technical analysis to make portfolio adjustments. Accounts are not typically managed to a static asset allocation guideline; instead portfolios are structured and adjusted based on prevailing market conditions. More information regarding our investment process is outlined in Item 8 of this brochure. In limited circumstances, we may provide investment management services on a non-discretionary basis such that we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time-sensitive, in which case recommendations not implemented because we are unable to reach a non-discretionary client may not be made on a timely basis, and therefore the client’s account may not perform as well as it would have had Kinloch Capital been able to reach the client for a consultation on the recommendation. Kinloch Capital uses a third party platform called Pontera to facilitate management of held away assets such as defined contribution plan participant accounts, on a non-discretionary or discretionary basis. The platform allows the firm to avoid being considered to have custody of Client funds since Kinloch Capital does not have direct access to Client log-in credentials to affect trades. Kinloch Capital is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once a Client account(s) is connected to the platform, Kinloch Capital will review the current account allocations. When deemed necessary, Kinloch Capital will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary. Wrap Program Kinloch Capital does not currently offer a wrap fee program. Financial Planning Kinloch Capital believes that thoughtful financial planning can be an effective tool for protecting and accumulating wealth. Kinloch Capital can also assist in financial planning for special needs clients, including their businesses and wealth transfer issues. In most cases, the client will supply to Kinloch Capital information including income, investments, savings, insurance, age and many other items that are helpful to the firm in assessing your financial goals. The information is typically provided during personal interviews and supplemented with written information. Once the information is received, we will discuss your financial needs

and goals with you, and compare your current financial situation with the goals you state. Once these are compared, we will create a financial and/or investment plan to help you meet your goals. The plan is intended to be a suggested blueprint of how to meet your goals. Not every plan will be the same for every client. Each one is specific to the client who requested it. Because the plan is based on information supplied by you, it is very important that you accurately and completely communicate to us the information we need. Also, your circumstances and needs may change as your engagement with us progresses. It is very important that you continually update us with any changes so that if the updates require changes to your plan, we can make those changes. Otherwise, your plan may no longer be accurate. Kinloch Capital provides all financial planning services “in house”, meaning the services are provided by Kinloch Capital professionals and not by any sub-adviser or contractor. During the planning process, it may be determined that a client would benefit from the expertise of another professional, such as an estate planning attorney or tax advisor. If you request, Kinloch Capital may recommend the services of other professionals for implementation purposes. You are under no obligation to engage the services of any such recommended professional. You retain absolute discretion over all such implementation decisions and are free to accept or reject any recommendation from Kinloch Capital. If you engage the services of any professional recommended by Kinloch Capital, and a dispute arises thereafter relative to such engagement, you agree to seek recourse exclusively from and against the engaged professional. Divorce Planning A Kinloch representative who has attained the CDFA® (Certified Divorce Financial Analyst) designation will work with you to help you gain an understanding of your unique situation and provide you with a financial picture so that you are in a better situation to communicate with legal counsel, a mediator or soon to be ex-spouse. We will complete cash flow and net worth projections, budgetary analysis, division of property, as well as help you to understand what the consequences and/or benefits are involving a settlement. The CDFA designation awarded by the Institute for Divorce Financial Analysts (IDFA). Individuals with a minimum of three years of professional experience in finance or divorce are eligible to enroll in the CDFA course. Candidates must pass each module exam with a 70% or higher to receive the CDFA designation. To retain the designation, an annual fee must be paid and 15 hours of divorce-related continuing education must be completed Retirement Plan Rollovers Depending on a client’s given circumstances, Kinloch may recommend that a client rollover retirement plan assets to an Individual Retirement Account (IRA) managed by us. As a result, Kinloch may earn fees on those accounts. This presents a conflict of interest, as Kinloch has a financial incentive to recommend that a client roll over retirement assets into an IRA Kinloch will manage. This conflict is disclosed to clients verbally and in this brochure. Clients are also advised that they are under no obligation to implement the recommendation to roll over retirement plan assets. Kinloch attempts to mitigate this conflict by requiring that all investment recommendations have a sound basis for the recommendation, and by requiring advisors of Kinloch to acknowledge their fiduciary responsibility toward each client. 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. Assets under Management As of March 28, 2024, Kinloch Capital manages approximately $218,889,819 all on a discretionary basis.