Klingenstein, Fields & Co., L.P. formed and initially registered with the SEC as an adviser in
1988. From 1998 through July 2020, the adviser operated as Klingenstein, Fields & Co.,
L.L.C. In August 2020, the adviser reverted to limited partnership form as Klingenstein,
Fields & Co., L.P.
The principal owner of 25% or more of the ADVISER is a trust for the benefit of the
Klingenstein family. Additional owners include active partners of management of KF
Advisors. Please see our Brochure Supplement on Form ADV Part 2B for more
information about our investment advisory personnel.
KF Advisors provides investment advice to selected clients primarily on a discretionary
basis and, to a lesser extent, on a nondiscretionary basis, based upon the individual
investment objectives, risk tolerance and constraints, time horizon and liquidity needs
of our clients. Individual accounts will have differing asset allocation, different
securities or different amounts of specific securities to reflect their individual
objectives, risk tolerance and constraints, time horizon and liquidity needs. Clients can
impose reasonable restrictions on our investment discretion with respect to investing
in certain securities or types of securities or can indicate that a particular held security
is not to be sold; however, this could affect their investment results.
Services include ongoing advice and supervision over client accounts principally regarding
both equity and fixed income securities, and to a lesser extent other asset classes, which
exposures could be achieved through investments in mutual funds and/or exchange traded
funds (“ETFs”). As part of its closed architecture strategy, KF Advisors has developed a
model portfolio that represents the implementation of the firm’s core equity strategy and
that can be applied consistently across applicable new and existing accounts, as deemed
appropriate (as described in Item 8). These activities are primarily based upon
fundamental research and an analysis of general economic, business and market
conditions.
KF Advisors, directly or through a sub-advisory agreement with our advisory affiliate KF
Group, LP (“KF Group”), also provides an open architecture approach to investing through
implementation of a full asset allocation framework that utilizes investments across a
range of asset classes, including investments with external managers on whom we have
conducted due diligence and hold a high level of conviction, as well as, when we deem
appropriate and/or in the clients best interests, investments in our core equity strategy. A
full description of the open architecture approach and related risks, policy summaries and
conflicts disclosures are included in KF Group’s ADV Part 2A, which should be read in its
entirety, in conjunction with this ADV Part 2A, for a comprehensive description of our
expanded strategy and conflicts of interest and is provided to all our clients prior to
entering into an advisory relationship. KF Group is an SEC registered investment adviser
with whom we are under common control, share the same principal place of business,
personnel and other resource as well as conduct and operate a fully integrated advisory
business.
For a subset of accounts seeking to invest in municipal and/or taxable fixed income
products, KF Advisors may allocate a percentage of a client’s account to Charles Schwab
Investment Management, Inc.’s Wasmer Schroeder Strategies (“CSIM”), pursuant to a sub-
advisory relationship.
We do not regularly issue any publication or report to our clients other than quarterly
valuation of their individual accounts, a monthly investment outlook and periodic market
commentaries. KF Advisors produces and distributes a variety of communications on
topics relevant to our clients, which vary in frequency and format, including emails, white
papers, newsletters, webinars, videos, etc., and are distributed live, electronically, in print
or posted on our website or social media accounts.
We serve as the investment adviser to several pooled investment vehicles that we refer
to in this Brochure as “Funds.” Additional information regarding the Funds can be found
in Item 8, below and in the Fund’s offering documents, available upon request.
We occasionally provide investment advice to clients with respect to pooled investment
vehicles such as partnerships or other private entities engaging in investment strategies
including, but not limited to, private equity and venture capital. Where appropriate, we
provide advice with respect to, and solicit certain clients to participate in, such entities,
some of which are affiliated with us.
As discussed in Item 10, KF Advisors is affiliated with various private investment funds.
KF Advisors, on a non-discretionary basis, will recommend that qualified clients consider
allocating a portion of their investment assets to the affiliated private funds, where
appropriate. The terms and conditions for participation in the affiliated private funds,
including management and incentive fees, where applicable, are set forth in the fund’s
offering documents. KF Advisors’ clients are under absolutely no obligation to consider or
make an investment in a private investment fund(s). In addition, as further described in
Item 11 and in Item 12, in the paragraph headed Trade Aggregation and Allocation, KF
Advisors’ officers, Members and other employees (“Employees”), and their immediate
family members and certain other persons and entities associated with those Employees
(“Related Persons”) are permitted to invest alongside these funds, provided that such
investments are consistent with KF Advisors’ Code of Ethics and Insider Trading Policy and
Trade Allocation Policies and Procedures, which, in relevant part, among other things,
require (i) the pre-clearance of private investments by Employees and certain Related
Persons, (ii) the participating private funds to receive a right of first refusal, and (iii) that
KF Advisors’ clients’ interests are placed ahead of KF Advisors Employees and certain
Related Persons.
Please Note: As further described in Item 8, private investment funds generally involve
various risk factors, including, but not limited to, potential for complete loss of principal,
liquidity constraints and lack of transparency. Unlike liquid investments that a client may
maintain, private investment funds do not provide daily liquidity or pricing. Each
prospective client investor will be required to complete a Subscription Agreement. Please
Also Note: Conflict Of Interest: Because KF Advisors can earn compensation from the
affiliated private funds that in certain instances exceeds the fee that the KF Advisors would
earn under its standard asset based fee schedule referenced in Item 5 below, the
recommendation that a client become an affiliated private fund investor presents a conflict
of interest.
Miscellaneous
Financial Planning and Non-Investment Consulting/Implementation Services. To the
extent specifically requested by the client or when we think appropriate, KF Advisors
provides financial planning services and assists in the development of detailed financial
plans and strategies,
including non-investment related matters, such as estate planning,
insurance, etc. Neither KF Advisors, nor any of its representatives, serves as an attorney,
accountant, or insurance agent, and no portion of KF Advisors’ services should be
construed as such. To the extent requested by a client or when we think appropriate, KF
Advisors recommends the services of unaffiliated professionals for certain non-investment
implementation purposes (i.e. attorneys, accountants, insurance, etc.). KF Advisors does
not receive any direct or indirect compensation from clients’ use of any recommended
professionals. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from KF
Advisors. Please Note: If the client engages any unaffiliated recommended professional,
and a dispute arises thereafter relative to such engagement, the client agrees to seek
recourse exclusively from and against the engaged professional. Please Also Note: It
remains the client’s responsibility to promptly notify KF Advisors if there is ever any
change in his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/revising KF Advisors’ previous recommendations and/or services.
PLEASE NOTE: RETIREMENT ROLLOVERS-No Obligation/Conflict of Interest: A client
leaving an employer typically has four options (and could engage in a combination of these
options): i) leave the money in his former employer’s plan, if permitted, ii) roll over the
assets to his new employer’s plan, if one is available and rollovers are permitted, iii)
rollover to an IRA, or iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). KF Advisors can recommend an investor
roll over plan assets or an Individual Retirement Account (IRA) to an IRA managed by KF
Advisors. As a result, KF Advisors and its representatives will earn an asset-based fee (see
Please Note below). In contrast, a recommendation that a client or prospective client leave
his or her plan assets with his or her old employer or roll the assets to a plan sponsored by
a new employer, or alternatively to leave his or her IRA with its current adviser or roll the
IRA to another adviser, will generally result in no compensation to KF Advisors (unless the
client engages KF Advisors to monitor and/or manage the account while maintained in an
employer plan). KF Advisors has an economic incentive to encourage an investor to roll
plan assets or IRA assets into an IRA that KF Advisors will manage or to engage KF Advisors
to monitor and/or manage plan assets while maintained at your employer.
When we provide investment advice to you regarding your retirement plan account or IRA,
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, as set forth above, 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.
There are various factors that KF Advisors will consider before recommending a rollover,
including but not limited to: i) the investment options available in the plan or IRA versus
the contemplated investment options available in an IRA managed by KF Advisors, ii) fees
and expenses in the plan or IRA versus the fees and expenses in the proposed IRA; which
analysis may include consideration of factors such as the long-term impact of any increased
costs; and why the rollover is appropriate notwithstanding any additional costs; iii)
whether the employer pays for some or all of the plan’s administrative expenses; iv) the
different levels of services and investments; including, among others, the need for help
with investments or financial planning; the relationship with financial adviser; and the
investment flexibility available under the plan and the IRA; v) pre-retirement distribution;
vi) potential tax issues; and vii) other issues, including, among others, the desire to
consolidate investment assets and bankruptcy protection. With respect to the plan, KF
Advisors will consider all of the investments in the plan’s line-up, and not solely the client’s
current investments. KF Advisors’ determination of a recommendation of a rollover of plan
assets can be limited by the availability of information about the client’s employer plan
alternatives. No client is under any obligation to rollover plan or IRA assets to an IRA
managed by KF Advisors or to engage KF Advisors to monitor and/or manage the plan
assets while maintained at your employer.
Client Obligations. In performing its services, KF Advisors shall not be required to verify
any information received from the client or from the client’s other professionals, and is
expressly authorized to rely thereon. Moreover, each client is advised that it remains his/
her/its responsibility to promptly notify KF Advisors if there is ever any change in
his/her/its financial situation or investment objectives for the purpose of
reviewing/evaluating/ revising KF Advisors’ previous recommendations and/or services.
Please Note: Investment Risk. Different types of investments involve varying
degrees of risk, and it should not be assumed that future performance of any specific
investment or investment strategy (including the investments and/or investment
strategies that are recommended or undertaken by KF Advisors) will be profitable or
equal any specific performance level(s).
We provide investment advice to clients with respect to other types of investments or
other financial matters.
Our investment advisory clients can terminate their investment advisory agreement
with us immediately by providing written notice to us requesting termination; or at
such time as is otherwise mutually agreed upon in writing by the client and us. KF
Advisors can resign as adviser to an account with notice, after five business days.
Assets Under Management
As of December 31, 2023, we managed Regulatory Assets Under Management
calculated in accordance with the guidelines of Form ADV Part 1:
• 1301 Discretionary and Non-Discretionary accounts, valued at $4.6 Billion
($4,590,005,998]), including:
o 1,272 Discretionary accounts, valued at $3.9 Billion ($3,890,405,679); and
o 29 Non-Discretionary accounts, valued at $699.6 Million ($699,600,319).