First Kentucky Securities Corporation is an SEC-registered investment adviser with its principal place of business located in Louisville, Kentucky. First Kentucky Securities Corporation (hereinafter "FKSC" or "Firm" or "we") began conducting business as an investment adviser in 2007. As of September 30, 2023, assets under our Firm’s management were $261,746,894.89 of client assets on a discretionary basis, and $273,545,906.75 of client assets on a non-discretionary basis. FKSC offers the following services and programs to our clients: I. RBC Capital Markets Services (offered through our clearing Firm arrangement) 1. Consulting Solutions Program – a wrap fee program sponsored by RBC 2. RBC Unified Portfolio Program – a wrap fee program sponsored by RBC 3. Unbundled Managed Account Solutions (UMAS) - a wrap fee program sponsored by FKSC* 4. FKSC Advisory Fee Program (Non-Wrap) sponsored by FKSC II. Financial Planning Services III. Securities Rating Services IV. Consulting Services This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. *See Appendix 1: First Kentucky Securities Corp - Wrap Fee Program Brochure for details. FKSC provides continuous advice to a client based on the individual needs of the client. Through personal discussions in which goals and objectives of a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage advisory accounts on a discretionary or non-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. Our 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
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Interests in partnerships investing in real estate
• Interests in partnerships investing in oil and gas interests
• Publicly-traded master limited partnerships(MLPs)
• Designated unit investment trusts (UITs) 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. I. RBC CAPITAL MARKETS SERVICES Consulting Solutions Program Consulting Solutions is a fee-based investment advisory Program sponsored by RBC CS and made available to FKSC as an introducing-broker to RBC CS through which your account is managed by one or more professional investment managers participating in the Program. Your Financial Advisor may provide you with information on investment managers whose investment philosophy and objectives may be compatible with your risk profile, and you select the investment manager. RBC CS makes available Investment Managers who meet RBC CS’ eligibility requirements for participation in the Program. For more information about the operation of the RBC Consulting Solutions Program, please see the RBC Consulting Solutions Program Agreement, Terms and Conditions and RBC Advisory Programs Disclosure Document. RBC Unified Portfolio Program RBC Unified Portfolio is a unified managed account “UMA” program through which your Account is professionally managed by RBC CM as Overlay Manager. The Overlay Manager manages the Account through investments in mutual funds, ETPs, and/or in accordance with one or more model portfolios provided by Model Providers or RBC CS, all in a single Account. Your FKSC Financial Advisor will provide you with information on mutual funds, ETPs, and/or model portfolios representing different investment styles and strategies that will be compatible with your Risk Profile. For more information about the operation of the RBC Unified Portfolio Program, please see the RBC Unified Portfolio Program Agreement, Terms and Conditions and RBC Correspondent Services Advisory Programs Disclosure Document. The Consulting Solutions Program and RBC Unified Portfolio Program are wrap fee programs (together, the “Programs”) sponsored by RBC Capital Markets and offered through RBC Correspondent Services, a division of RBC Capital Markets Corporation, Member NYSE/FINRA/SIPC ("RBC"). FKSC may recommend and refer its clients to various third- party money managers available through the Programs. FKSC will assist clients with the identification of investment objectives through preparation of a risk profile questionnaire and will assist clients in the selection of appropriate money managers available through the Programs. Client accounts may also be invested in model portfolios provided by third party money managers available through the Programs. Clients may grant FKSC the authority to select or re-allocate client’s assets amongst third party managers on a non- discretionary basis. On at least an annual basis, FKSC will meet or speak with clients to review the performance of Client's account, investment guidelines and other relevant factors in order to assess what changes, if any should be made to the management of client's account. The money managers selected under the Programs will have discretion to determine the securities to be bought or sold within the client’s accounts subject to reasonable restrictions imposed by the client, subject to the client’s signature on the money manager’s account agreement. The Programs are wrap fee programs where custody and brokerage fees are included in the total advisory fee charged to the client, subject to the exceptions of certain fees stated in RBC's Program Brochure. Clients should refer to RBC’s disclosure brochure for additional information regarding the Program.
• Wrap Fee Programs may not be suitable for all investment needs, and any decision to participate in a Wrap Fee Program should be based on the client’s individual financial circumstances and investment goals.
• The benefits under a Wrap Fee Program depend, in part, upon the size of a client’s account and the number of transactions likely to be generated in the account. For example, Wrap Fee Accounts may not be suitable for accounts with little activity. Participating in a Wrap Fee Program may cost more or less than the cost of purchasing such services separately from a broker-dealer.
• FKSC receives compensation as a result of the client’s participation in the Programs which may be more than what FKSC would receive if the client paid separately for investment advice, brokerage and other services.
• FKSC may have a financial incentive to recommend the Programs over other programs and services. In determining whether to establish a Program account, a client should be aware that the overall cost to the client may be higher or lower than

the client might incur by purchasing separately the types of securities available in the Program. Unbundled Managed Account Solutions (UMAS) – FKSC Wrap Fee Program sponsored by FKSC The FKSC Wrap Fee Program offers portfolio management services to clients as the sponsor and portfolio manager of the FKSC Wrap Fee Program. A wrap fee program is an investment management program that provides the client with advisory and brokerage execution services for an inclusive fee which incorporates charges for advisory services, custody, clearing, transaction execution and account reporting. For more information regarding the Program, including the fee schedule and other important considerations, clients should refer to Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure. FKSC Advisory Fee Program (Non-Wrap) sponsored by FKSC The FKSC Advisory Fee Program seeks to help clients develop and reach financial goals through a thoughtful combination of technology, expertise and the use of financial investments. In consultation with a client, information is gathered related to client’s current and future financial needs, existing resources, goals, and risk tolerance. A proposal to the investment approach is presented, and if accepted, implemented and monitored according to the client’s objectives. The adviser may propose investment portfolios consisting of mutual funds, exchange traded funds (ETFs), individual stocks and bonds, or other suitable securities. If a client agrees to engage our services, we will work to open new accounts, move assets to our clearing Firm RBC Correspondent Services, and begin executing on our annual service model. Any changes to a client’s personal or financial situation must be communicated immediately so we can take that information into consideration. The FKSC Advisory Fee Program offers investment management services on a non-discretionary basis, meaning that client authorization is obtained before entering any buy or sell orders in a client account. The terms and conditions under which a client shall engage our investment practice for advisory services shall generally be set forth in an agreement between the client and our Firm. Clients may terminate these contracts at any time upon written notification (see Termination of the Advisory Relationship under General Information). II. FINANCIAL PLANNING SERVICES We provide 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: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze 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: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide 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 six 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. All recommendations are of a generic nature. III SECURITIES RATING SERVICES First Kentucky Securities Corporation, doing business as First Credit Advisors (FCA), provides timely and in-depth company-specific or security-specific equity research for institutional clients including, among others, investment managers or other advisers to hedge funds or other private funds, investment companies and pension or profit-sharing plans. FCA's research and analysis is widely available to institutional advisers and others through web-based, broker research sites. In addition, we may distribute research reports directly to clients that have done business with our Firm in the past twelve-month period. We conduct research regarding issuers or securities through competition and market analysis, economic modeling, earnings forecasts and valuation, among other factors. FCA generally provides research and analysis for equities of predominantly U.S. issuers in the technology, media, telecommunications, and consumer goods sectors. FCA analyzes fundamental data taken from original sources and/or publicly available reports. As appropriate, our information- gathering process may include on-site inspections of company operations, manufacturing, retail outlets and/or interviews with senior-level management. FCA will also formulate a buy, hold or sell recommendation and price target based on its investment philosophy focusing, primarily, on an issuer's prospects for long-term growth taking into consideration its market share, competitive position and anticipated consumer demand for products or services, capital strength, profitability and appropriate valuations. Once we have initiated coverage of a particular issuer or security, we will provide regular updates regarding the status of such issuer or security including any changes in inventory or resource access or supply, demand, competition or technology, among other factors, that could impact our outlook or valuation. I.V. CONSULTING SERVICES Clients can also receive investment advice on a more focused basis. This includes advice on only an isolated area of concern such as estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding investment and financial concerns of the client. Consulting recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature.