The Kinney Group is no longer soliciting new clients and is in the process of transitioning current clients and staff to a new advisory firm. The remaining disclosures reflect how the Firm was working with clients and how it is working with existing clients until transitioned. The Firm provides financial planning and wealth management services. The firm’s core business objective is to learn and understand clients’ goals, concerns and risk tolerance, and to then propose and implement a mutually agreed upon, customized investment and wealth management strategy to address them. After a strategy has been implemented, it is The Kinney Group’s responsibility to then closely monitor its progress and report back regularly to the client. Prior to the rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with The Kinney Group setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). The Kinney Group has been conducting business as an investment adviser since August 2013, and is owned by The Estate of Paul W. Kinney and JoAnne J. Nishiyama. As of December 31, 2023, The Kinney Group had $92,704,760 in assets under management, all of which was managed on a discretionary basis. Paul Kinney passed away in 2022 and his interest (and the majority of the Firm) is currently owned by his estate. While this brochure generally describes the business of The Kinney Group, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s employees, officers, partners, directors (or other persons occupying a similar status or performing similar functions), or any other person who provides investment advice on The Kinney Group’s behalf and is subject to the Firm’s supervision or control. Financial Planning Services The Kinney Group offers clients a broad range of financial planning and consulting services, which include any or all of the following functions:
• Distribution and Income Planning
• Cash Flow Analysis
• Asset Allocation
• Retirement Planning
• Estate Planning
• Investment Consulting
• Charitable Giving
• Tax Minimization Strategies While each of these services is available on a stand-alone basis, they may also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (as described further below). In performing these services, The Kinney Group 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. Page 5 © MarketCounsel 2024 The Kinney Group recommends the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage The Kinney Group to provide additional services. Clients are under no obligation to act upon any of the recommendations made by The Kinney Group under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including The Kinney Group itself. 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 The Kinney Group’s previous recommendations and/or services. Wealth Management Services The Kinney Group provides clients with wealth management services which include financial planning services as well as the discretionary or non-discretionary

management of investment portfolios as appropriate. The Kinney Group allocates client assets among various independent investment managers (“Independent Managers”), fixed income, unit investment trusts (“UITs”), mutual funds, exchange-traded funds (“ETFs”), and individual equity securities as necessary to meet a client’s investment objectives. Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. The Firm has engaged an outside investment officer to help manage the Firm’s client assets. The investment officer is also affiliated with another advisory firm. This results in a conflict of interest because that investment officer has an incentive to treat the clients of the firm he is affiliated with better than those of The Kinney Group. Clients can also engage The Kinney Group to 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, The Kinney Group 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. The Kinney Group tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. The Kinney Group consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify The Kinney Group if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if The Kinney Group Page 6 © MarketCounsel 2024 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. Use of Independent Managers As mentioned above, where appropriate, The Kinney Group 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 are set forth in a separate written agreement between the designated Independent Manager and either The Kinney Group or the client. The Kinney Group evaluates various information about each Independent Manager it chooses, which may include public disclosure documents, materials supplied by the Independent Managers themselves and/or 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. The Kinney Group also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. The Kinney Group provide services relative to the discretionary selection of the Independent Managers. The Firm monitors the performance of those accounts being managed by Independent Managers on an ongoing basis, and seeks to ensure the strategies and target allocations utilized remain aligned with its clients’ investment objectives and overall best interests.