THE KIECKHEFER GROUP

ITEM 1 COVER PAGE THE KIECKHEFER GROUP 1323 W Towne Square Road Mequon, WI 53092 www.kieckhefergroup.com 414.704.3826 DATE: March 6, 2025 This brochure provides information about the qualifications and business practices of The Kieckhefer Group. If you have any questions about the contents of this brochure, please contact us at 414-704-3826. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration (e.g. “registered investment advisor”) does not imply a certain level of skill or training. Additional information about The Kieckhefer Group also is available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 2 MATERIAL CHANGES Pursuant to SEC rules, The Kieckhefer Group will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, The Kieckhefer Group will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. Clients and prospective clients can always receive the most current disclosure brochure for The Kieckhefer Group at any time by contacting their investment advisor representative. This is a new brochure as of March 6, 2025. Since our last update on September 17, 2024, we have made the following updates: Clarified the negotiability of our fees, please see Item 5 for more information Added information and risks regarding Options, please see Item 8 for more information. 2  ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ..................................................................................................................... 1 ITEM 2 MATERIAL CHANGES ......................................................................................................... 2 ITEM 3 TABLE OF CONTENTS ........................................................................................................ 3 ITEM 4 ADVISORY BUSINESS ........................................................................................................ 4 ITEM 5 FEES AND COMPENSATION ............................................................................................... 5 ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT........................................ 6 ITEM 7 TYPES OF CLIENTS ............................................................................................................ 6 ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS.............................. 7 ITEM 9 DISCIPLINARY INFORMATION .......................................................................................... 13 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................... 13 ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ................................................................................................................. 14 ITEM 12 BROKERAGE PRACTICES ............................................................................................... 14 ITEM 13 REVIEW OF ACCOUNTS ................................................................................................. 18 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION ......................................................... 18 ITEM 15 CUSTODY ...................................................................................................................... 19 ITEM 16 INVESTMENT DISCRETION ............................................................................................. 19 ITEM 17 VOTING CLIENT SECURITIES .......................................................................................... 20 ITEM 18 FINANCIAL INFORMATION ............................................................................................. 20 3  ITEM 4 ADVISORY BUSINESS Firm Description The Kieckhefer Group (“KG” the “Firm,” or “Advisor”) is an SEC-registered investment advisor founded in July 2013 The Principal Owner of KG is Robert “Rob” Kieckhefer. The Chief Compliance Officer of KG is David “Dave” Reichert. Types of Advisory Services The Firm offers a large variety of services, including portfolio management and investment analysis for individuals and high net worth individuals. The Firm offers these services to clients or prospective clients (“Client” or “Clients”). Prior to providing any investment advisory services, the Firm requires a written financial services agreement (“FSA”) be executed by client. The FSA will outline the services available to the client and the fees the client will incur. Discretionary Investment Advisory Services The Firm offers discretionary portfolio management services. The Firm’s investment advice is tailored to the Client’s needs and investment objectives. Clients who participate in KG’s portfolio management services are required to grant KG discretionary authority to manage their account. Subject to a grant of discretionary authorization, KG has the authority and responsibility to formulate investment strategies on the Client’s behalf. Discretionary authorization allows KG to determine the specific securities and the amount of securities to be purchased or sold for the Client’s account without obtaining the Client’s approval prior to each transaction. Discretionary authority is typically granted through the FSA, a power of attorney, or trading authorization forms. Clients may limit KG’s discretionary authority (for example, limiting the types of securities that can be purchased or sold for and accounts) by providing KG with your restrictions and guidelines in writing. Services Tailer to Client’s Needs Services are provided based on a Client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the Client regarding the 4  Client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with the available information. Assets Under Management As of December 31, 2024, the Firm has the following assets under management: Discretionary assets: $184,624,588 Non-discretionary assets: $0 ITEM 5 FEES AND COMPENSATION Individually Managed Accounts Fees for individually managed accounts are tier priced as follows: Account Size $0 to $1,000,000 $1,000,001 to $5,000,000 $5,000,001 or greater Fee (Annual percentage)* 1.5% 1.25% 1% All asset-based fees are deducted by the qualified custodian of record quarterly in advance, or as otherwise indicated in the FSA. The advisory fee paid to the Firm is calculated using the value of the assets in the Account on the last business day of the prior billing period. Upon termination, for any unearned asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365) The management fee is negotiable at the Firm’s discretion. When negotiating a fee, the Firm will take into consideration criteria including, but not limited to, future earning capacity, anticipated future additional assets, related accounts, complexity of the engagement, anticipated services to be rendered, and competition. Client statements for prior deductions will be provided on a quarterly basis. All fees paid to the Firm for investment advisory services are separate and distinct from the expenses charged by third-party managers and investment companies to their shareholders. These fees and expenses are described to the client in separate disclosures. These fees will generally include third-party management fees, an investment company management fee, other fund expenses, and in some situations a possible distribution fee. 5  The Firm will provide investment advisory services and portfolio management services but will not provide custodial or other administrative services. At no time will the Firm accept or maintain custody of a client’s funds or securities except for authorized fee deduction. The Client may contact the Custodian directly for disbursements, or account record changes, and may also do so in writing to the custodian. The Firm may act to facilitate such written communications to the Custodian, provided that such action is not construed to be custody of client assets. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. Fees paid to KG are separate and distinct from the custodian and execution fees. Clients may request to terminate their FSA with KG, in whole or in part, by providing advance written notice. Client’s advisory agreement with the Advisor is non-transferable without Client’s consent. Right of Cancellation In addition to the right to terminate an agreement pursuant to its terms, a Client may cancel an agreement with the Firm within five (5) business days of first receiving a copy of this disclosure brochure and supplement without penalty or fee. ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The Firm does not charge performance fees and so does not use side-by-side management. ITEM 7 TYPES OF CLIENTS The Firm provides investment advisory services to many types of Clients, including individuals, high net worth individuals, and businesses. The Firm requires a minimum account balance of $50,000. However, this requirement may be waived at the discretion of KG in certain circumstances. 6  ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis The Firm may use the following methods when considering investment strategies and recommendations. Charting Review Charting is a technical analysis that charts the patterns of stocks, bonds, and commodities to help determine buy and sell recommendations for Clients. It is a way of gathering and processing price and volume information in a security by applying mathematical equations and plotting the resulting data onto graphs in order to predict future price movements. A graphical historical record assists the analyst in spotting the effect of key events on a security’s price, its performance over a period of time, and whether it is trading near its high, near its low or in between. Chartists believe that recurring patterns of trading, commonly referred to as indicators, can help them forecast future price movements. Fundamental Review A fundamental analysis is a method of evaluating a company or security by attempting to measure its intrinsic value. Fundamental analysis attempts to determine the true value of a company or security by looking at all aspects of the company or security, including both tangible factors (e.g., machinery, buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g., management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the security's current price with the aim of determining what sort of position to take with that security (e.g., if underpriced, the security should be bought; if overpriced the security should sold). Fundamental analysis uses real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for many types of securities. Technical Review Technical analysis is a method of evaluating securities that analyzes statistics generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value, but instead uses past market data and statistical tools to identify 7  patterns that can suggest future activity. Historical performance of securities and the markets can indicate future performance. Cyclical Review A cyclical analysis assumes the market reacts in reoccurring patterns that can be identified and leveraged to provide performance. Cyclical analysis of economic cycles is used to determine how these reoccurring patterns, or cycles, affect the returns of a given investment, asset, or company. Cyclical analysis is a time-based assessment which incorporates past and present performance to determine future value. Cyclical analyses exist because the broad economy has been shown to move in cycles, from periods of peak performance to periods of low performance. The risks of this strategy are two-fold: (1) the markets do not always repeat cyclical patterns; and (2) if too many investors begin to implement this strategy, it changes the very cycles of which they are trying to take advantage. Economic Review An economic analysis determines the economic environment over a certain time horizon. This involves following and updating historic economic data such as U.S. gross domestic product and consumer price index as well as monitoring key economic drivers such as employment, inflation, and money supply for the world’s major economies. Investment Strategies When implementing investment advice to Clients, the Firm may employ a variety of strategies to best pursue the objectives of Clients. Depending on market trends and conditions, the Firm will employ any technique or strategy herein described, at the Firm’s discretion and in the best interests of the Client. The Firm does not recommend any particular security or type of security. Instead, the Firm makes recommendations to meet a particular Client’s financial objectives. There is inherent risk to any investment and Clients may suffer a loss of all or part of a principal investment. Long-Term Purchases Long-term purchases are securities that are purchased with the expectation that the value of those securities will grow over a relatively long period, generally greater than one year. Long-term purchases may be affected by unforeseen changes in the company in which a Client is invested or in the overall market. Long-term trading is designed to capture market rates of both return and risk. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Due to its nature, the long-term strategy can expose Clients to various other types of risk that will typically surface at various intervals during the time the Client owns the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest rate risk, economic risk, and political/regulatory risk. 8  Options An option is a financial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a: Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option. Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the specified strike price on or before a specified date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase above a specified price on or before the expiration date. If the underlying stock's price closes above the specified strike price on the expiration date, the put option writer's maximum profit is achieved. Conversely, a put option holder would only benefit from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price. Short-Term Purchases Short-term purchases are securities that are purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short-term trading generally holds greater risk. Frequent trading can affect investment performance due to increased brokerage fees and other transaction costs and taxes. Strategic Asset Allocation Asset allocation is a combination of several different types of investments; typically, this includes stocks, bonds, and cash equivalents among various asset classes to achieve diversification. The objective of asset allocation is to manage risk and market exposure while still positioning a portfolio to meet financial objectives. 9  Risk of Loss Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. The Firm does not provide any representation or guarantee that the financial goals of Clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of ETFs (i.e., exchange-traded funds), may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. 10  Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. We may use certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model related results as part of our investment-decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by the Firm plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Options Risk. The potential risks associated with these transactions are that (1) all options expire. The closer the option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move very quickly. Depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by the Firm may be affected by the risk that currency devaluations affect Client purchasing power. 11  Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisors. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. 12  Tax Risks. Tax laws and regulations applicable to an account with the Frim may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisors and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of any particular account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. The Firm and its representatives are not responsible to any account for losses unless caused by the Firm breaching our fiduciary duty. Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. ITEM 9 DISCIPLINARY INFORMATION Neither KG nor its representatives have any history of discipline that is required to be disclosed. ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Registration as a Broker-Dealer or Broker-Dealer Representative The Firm is not registered and does not have an application pending to register as a broker-dealer or broker-dealer representative. Registration as a Futures Commission Merchant or Commodity Pool Operator Neither KG nor its representatives are registered and do not have an application pending to register as a futures commission merchant or commodity pool operator. Selection of Other Advisors The Firm does not recommend or select other investment advisors for its Clients. 13  ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Fiduciary Status According to federal and state law, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its Clients. The Firm and its representatives have a fiduciary duty to all Clients. The fiduciary duty of the Firm and its representatives toward its Clients is considered the core underlying principal for the Firm’s Code of Ethics and represents the expected basis for all dealings our representatives have with our Clients. The Firm has the responsibility to ensure that the interests of its Clients are placed ahead of its own investment interests, as well as the investment interests of its representatives. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to Clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect their duty of complete loyalty to our Clients. Representatives of KG may buy or sell securities for themselves that they also recommend to Clients. Where a transaction for a representative, or an account related to a representative, is contemplated, a Client’s transaction is given priority. The Firm has developed a Code of Ethics applicable to all persons who have access to confidential Client records or to recommendations being made for Client accounts. The Code of Ethics is designed to prevent conflicts of interest between the financial interests of Clients and the interests of KG’s staff by requiring access persons to obtain preapproval of certain securities transactions and to report transaction quarterly, and to report all securities positions in which they have a beneficial interest at least annually. ITEM 12 BROKERAGE PRACTICES Selection and Recommendation The Firm has a duty to select brokers, dealers, and other trading venues that provide best execution for Clients. The duty of best execution requires an investment advisor to seek to execute securities transactions for Clients in such a manner that the Client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account 14  all relevant factors. The lowest possible commission, while very important, is not the only consideration. It is the policy of the Firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. The standards and procedures governing best execution are set forth in several written policies. Generally, to achieve best execution, the Firm considers the following factors, without limitation, in selecting brokers and intermediaries: • Financial responsibility of the • Execution capability; • Order size and market depth; • Availability of competing markets and liquidity; • Trading characteristics of the security; • Availability of accurate information broker-dealer; • Confidentiality; • Reputation and integrity; • Responsiveness; • Recordkeeping; • Ability and willingness to commit comparing markets; capital; • Quantity and quality of research received from the broker dealer; • Available technology; and • Ability to address current market conditions. The Firm evaluates the execution, performance, and risk profile of the broker-dealers it uses at least quarterly. Research and Other Soft Dollar Benefits Soft dollar practices are arrangements whereby an investment advisor directs transactions to a broker‐dealer in exchange for certain products and services that are allowable under federal and state law. Client commissions may be used to pay for brokerage and research services and products as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets forth a “safe harbor,” which provides that an investment advisor that has discretion over a Client account is not in breach of its fiduciary duty when paying more than the lowest commission rate available if the advisor determines in good faith that the rate paid is commensurate with the value of brokerage and research services provided by the broker‐dealer. We typically recommend Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. The Kieckhefer Group is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as a custodian, you will decide whether to 15  do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. Products and services available to the Firm from Schwab Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. Schwab provides The Kieckhefer Group and our clients with access to institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services described below are generally available on an unsolicited basis (i.e., we do not have to request them) and at no charge to us. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Directly Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit each client. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit a specific client. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to client account data (such as trade confirmations and account statements); • Facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • Provides pricing and other market data; • Facilitates payment of our fees from our clients’ accounts; and • Assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include (among others) the following: • Educational conferences and events • Technology, compliance, legal, and business consulting 16  • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants and insurance providers Schwab will provide some of these services itself or will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third-party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab's Services The availability of the services described above from Schwab benefits us because we do not have to produce or purchase them. They are not contingent upon The Kieckhefer Group committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as a custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality and price of Schwab’s services, and not Schwab’s services that benefit only us. Brokerage for Client Referrals The Firm does not receive Client referrals from third parties for recommending the use of specific broker-dealer brokerage services. Directed Brokerage The Firm does not allow client-directed brokerage. Order Aggregation The Firm may, at times, aggregate sale and purchase orders of securities (“block trading”) for advisory accounts with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the Client. Clients also benefit relatively from better purchase or sale execution prices, or beneficial timing of transactions or a combination of these and other factors. Aggregate orders will be allocated to Client accounts in a systematic non-preferential manner. The Firm may aggregate or “bunch” transactions for a Client’s account with those of other Clients in an effort to obtain the best execution under the circumstances. 17  Trade Error Policy The Firm maintains a record of any trading errors that occur in connection with investment activities of its Clients. Both gains and losses that result from a trading error made by the Firm will be borne or realized by the Firm. ITEM 13 REVIEW OF ACCOUNTS Periodic Reviews The Firm regularly reviews and evaluates Client accounts for compliance with each Client’s investment objectives, policies, and restrictions. The Firm analyzes rates of return and allocation of assets to determine model strategy effectiveness. Such reviews are conducted by the Chief Compliance Officer of the Firm and shall occur at least once per calendar year. Intermittent Review Factors Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the Client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify the Firm promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. Reports Clients may receive confirmations of purchases and sales in their accounts and will receive, at least quarterly, statements containing account information such as account value, transactions, and other relevant information. Confirmations and statements are prepared and delivered by the custodian. ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION The Firm does not pay another person or entity for referring or soliciting Clients for KG. The firm receives an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from these products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. These 18  products and services, how they benefit us, and the related conflicts of interest are described above in Item 12 Brokerage Practices. ITEM 15 CUSTODY Custodian of Assets Custody means holding, directly or indirectly, Client funds or securities or having any authority to obtain possession of them. The Firm does not have direct custody of any Client funds and/or securities. The Firm will not maintain physical possession of Client funds and securities. Instead, Client funds and securities are held by a qualified custodian. While the Firm does not have physical custody of Client funds or securities, payments of fees may be paid by the custodian from the custodial brokerage account that holds Client funds pursuant to the Client’s account application. In certain jurisdictions, the ability of the Firm to withdraw its management fees from the Client’s account may be deemed custody. Prior to permitting direct debit of fees, each Client provides written authorization permitting fees to be paid directly from the custodian. As part of the billing process, the Client’s custodian is advised of the amount of the fee to be deducted from that Client’s account. On at least a quarterly basis, the custodian is required to send to the Client a statement showing all transactions within the account during the reporting period. The custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of the Firm’s advisory calculation. Therefore, it is important for Clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact The Firm directly if they believe that there may be an error in their statement. ITEM 16 INVESTMENT DISCRETION The Firm may exercise full discretionary authority to supervise and direct the investments of a Client’s account. This authority will be granted by Clients upon completion of the Firm’s FSA. This authority allows the Firm and its affiliates to implement investment decisions without prior consultation with the Client. Such investment decisions are made in the Client’s best interest and in accordance with the Client’s investment objectives. Other than agreed upon management fees due to the Firm, this discretionary authority does not grant the Firm the authority to have custody 19  of any assets in the Client’s account or to direct the delivery of any securities or the payment of any funds held in the account to the Firm. The discretionary authority granted by the Client to the Firm does not allow the Firm to direct the disposition of such securities or funds to anyone except the account holder. ITEM 17 VOTING CLIENT SECURITIES The Firm does not perform proxy voting services on the Client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the Client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, Clients have the ultimate responsibility for making all proxy voting decisions. ITEM 18 FINANCIAL INFORMATION Balance Sheet Requirement The Firm is not the qualified custodian for Client funds or securities and does not require prepayment of fees of more than $1,200 per Client for six months or more in advance. Financial Condition The Firm does not have any financial impairment that would preclude the Firm from meeting contractual commitments to Clients. Bankruptcy Petition The Firm has not been the subject of a bankruptcy petition at any time during the last 10 years. 20