Overview

Assets Under Management: $379 million
Headquarters: WAYZATA, MN
High-Net-Worth Clients: 21
Average Client Assets: $18 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (HUNTER KEITH DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 1.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $75,000 1.50%
$10 million $150,000 1.50%
$50 million $750,000 1.50%
$100 million $1,500,000 1.50%

Clients

Number of High-Net-Worth Clients: 21
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 99.18
Average High-Net-Worth Client Assets: $18 million
Total Client Accounts: 52
Discretionary Accounts: 21
Non-Discretionary Accounts: 31

Regulatory Filings

CRD Number: 332688
Last Filing Date: 2025-03-04 00:00:00

Form ADV Documents

Primary Brochure: HUNTER KEITH DISCLOSURE BROCHURE (2025-03-04)

View Document Text
Hunter Keith Industries, Inc. Form ADV Part 2A – Disclosure Brochure Effective: March 4, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Hunter Keith Industries, Inc. (“HKI” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (612) 204-0405. HKI is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about HKI to assist you in determining whether to retain the Advisor. Additional information about HKI and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 332688. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of HKI. For convenience, the Advisor has combined these documents into a single disclosure document. HKI believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. HKI encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last distribution to Clients. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 332688. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (612) 204-0405. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 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 Services .................................................................................................................................... 4 A. Firm Information .............................................................................................................................................................. 4 B. Advisory Services Offered ............................................................................................................................................... 4 C. Client Account Management ........................................................................................................................................... 5 D. Wrap Fee Programs ........................................................................................................................................................ 6 E. Assets Under Management ............................................................................................................................................. 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services.............................................................................................................................................. 6 B. Fee Billing........................................................................................................................................................................ 7 C. Other Fees and Expenses .............................................................................................................................................. 7 D. Advance Payment of Fees and Termination ................................................................................................................... 8 E. Compensation for Sales of Securities ............................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ....................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9 A. Methods of Analysis ........................................................................................................................................................ 9 B. Risk of Loss ..................................................................................................................................................................... 9 Item 9 – Disciplinary Information ........................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11 A. Code of Ethics ............................................................................................................................................................... 11 B. Personal Trading with Material Interest ......................................................................................................................... 11 C. Personal Trading in Same Securities as Clients ........................................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................ 12 A. Recommendation of Custodian[s] ................................................................................................................................. 12 B. Aggregating and Allocating Trades ............................................................................................................................... 13 Item 13 – Review of Accounts ............................................................................................................................. 13 A. Frequency of Reviews ................................................................................................................................................... 13 B. Causes for Reviews ...................................................................................................................................................... 13 C. Review Reports ............................................................................................................................................................. 13 Item 14 – Client Referrals and Other Compensation ........................................................................................ 14 A. Compensation Received by HKI ................................................................................................................................... 14 B. Compensation for Client Referrals ................................................................................................................................ 14 Item 15 – Custody ................................................................................................................................................. 14 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 15 Item 18 – Financial Information ........................................................................................................................... 15 Form ADV Part 2B – Brochure Supplement ....................................................................................................... 16 Privacy Policy ....................................................................................................................................................... 19 Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 3 Item 4 – Advisory Services A. Firm Information Hunter Keith Industries, Inc. (“HKI” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Minnesota. HKI is owned by Andrew McDonald Hunter III (Co-Chairman and President) and Robert Johnstone Keith, Jr. (Chairman). The Principal Officer of HKI is Todd M. Thorsen, CFA® (Chief Executive Officer and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by HKI. B. Advisory Services Offered HKI offers investment advisory services to high net worth individuals, families, trusts, estates, and businesses (each referred to as a “Client”). HKI provides a range of family office services to our client families. We can provide your family with, advice, recommendations, and/or management in the following areas: financial planning; investment management (asset allocation, portfolio construction, investment vehicle selection, portfolio monitoring and discretionary management); family governance, succession planning; service provider selection; and consolidated reporting. We work closely with you to identify your investment goals and objectives, as well as risk tolerance and financial situation in order to develop an investment approach. HKI serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. HKI’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services HKI provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing primarily discretionary investment management and related advisory services. HKI works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. HKI will then construct an investment portfolio, consisting primarily of individual stocks, individual bonds, and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize mutual funds, third party money managers (herein “Independent Managers”) and/or other investment approaches to meet the needs of the Client. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. HKI’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. HKI will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. HKI evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. HKI may recommend, on occasion, redistributing investment allocations to diversify the portfolio. HKI may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. HKI may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 4 which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Use of Independent Managers – HKI will recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client will be required to authorize and enter into an investment management agreement with an Independent Manager that defines the terms in which the Independent Manager will provide its services. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Financial Planning Services HKI will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and/or other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. HKI may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) quarters of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging HKI to provide investment advisory services, each Client is required to enter into one or more written agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – HKI, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 5 • Asset Allocation – HKI will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – HKI will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – HKI will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs HKI does not offer a wrap fee program. E. Assets Under Management As of December 31, 2024, HKI manages $379,341,058 in Client assets, $359,129,520 of which are managed on a discretionary basis and $20,211,538 of which are managed on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior quarter. Investment advisory fees range from 0.50% to 1.50% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. Certain clients may be offered a tiered fee schedule within the range above. All securities held in accounts managed by HKI will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Use of Independent Managers As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 6 Financial Planning Services HKI offers financial planning for a fixed engagement fee of $2,500. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total costs will be provided to the Client prior to engaging for these services. Consulting Services The Advisor provides non-advisory consulting services for a negotiated fee, based on the nature of the consulting services to be provided. Services are provided at an hourly rate ranging from $150 to $450 per hour or a fixed engagement fee. An estimate for total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with HKI at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review the statement provided by the Custodian, as the Custodian does not perform a verification of the Advisor’s fees. Clients provide written authorization permitting advisory fees to be deducted by HKI to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client accounts implemented through an Independent Manager, the Client’s overall fees may include HKI’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Longer duration planning engagements (greater than six (6) months for completion) may be billed in advance of each calendar quarter. Services will a duration of six months or more will be billed quarterly. Consulting Services Consulting fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the consulting services agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Ongoing consulting services are billed quarterly in advance. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than HKI, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. The fees charged by HKI are separate and distinct from these custody and execution fees. In addition, all fees paid to HKI for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of HKI, but would not receive the services provided by HKI which are designed, among other things, to assist the Client in determining Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 7 which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by HKI to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services HKI may be compensated for its investment management services in advance of the quarter in which services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non- transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set forth in the respective agreements between the Client and that Independent Manager. HKI will assist the Client with the termination and transition as appropriate. Financial Planning Services HKI may be partially-compensated for its financial planning services upon the execution of the planning agreement. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed based on the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Consulting Services HKI may be partially-compensated for its consulting services upon the execution of the consulting services agreement. Either party may terminate the consulting services agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the consulting services agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed based on the number of hours worked at the negotiated hourly rate or the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will refund any unearned, prepaid consulting fees. The Client’s consulting services agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities HKI does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person may earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by Advisory Persons are separate and in addition to our advisory fees. This practice presents a conflict of interest as the Advisory Person may have an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see Item 10 below. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 8 Item 6 – Performance-Based Fees and Side-By-Side Management HKI does not charge performance-based fees for its investment advisory services. The fees charged by HKI are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. HKI does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients HKI offers investment advisory services to high net worth individuals, families, trusts, estates, and businesses. HKI generally does not impose a minimum relationship size. However, its services are tailored to high net worth families. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis HKI primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from HKI are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that HKI will be able to accurately predict such a reoccurrence. As noted above, HKI generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. HKI will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, HKI may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. HKI will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 9 determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 10 Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information Securities laws require an advisor to disclose any instances where the Advisor or its Advisory Persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. HKI does not have any matters which require disclosure HKI values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 332688. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with HKI. As an insurance professional, an Advisory Person may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Advisory Persons or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics HKI has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with HKI (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. HKI and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of HKI’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (612) 204-0405. B. Personal Trading with Material Interest HKI allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. HKI does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. HKI does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients HKI allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 11 trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by HKI requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While HKI allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will HKI, or any Supervised Person of HKI, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] HKI typically does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize HKI to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, HKI does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where HKI does not exercise discretion over the selection of the Custodian, it does recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by HKI. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. HKI may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. HKI Partners will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), a FINRA- registered broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodian.” HKI Partners maintains an institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity. HKI Partners has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like HKI Partners in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no- load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. As described above, Fidelity provides to HKI Partners, without cost, research and trade execution services. Fidelity makes these services available to similarly situated investment advisers whose clients custody their assets with Fidelity. Access to research and trade execution services is not predicated on the execution of Client securities transactions (e.g., not “soft dollars”). HKI Partners has not entered into any formal “soft dollar” arrangements with broker-dealers. HKI Partners’ Clients may utilize qualified custodians other than Fidelity for certain accounts and assets, particularly where clients have a previous relationship with such qualified custodians. HKI Partners may charge a fee to manage such assets held away from Fidelity. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 12 Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. HKI does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - HKI does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where HKI will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). HKI will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. HKI will execute its transactions through the Custodian as authorized by the Client. HKI may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisor Persons of the Advisor and periodically by the CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify HKI if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 13 Item 14 – Client Referrals and Other Compensation A. Compensation Received by HKI HKI may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, HKI may receive non- compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in Item 12, HKI Partners has established an institutional relationship with Fidelity to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and reimbursements for various third-party service providers. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody HKI does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom HKI exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct HKI to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and compare to any reports provided by HKI to ensure accuracy, as the Custodian does not perform this review. Item 16 – Investment Discretion HKI generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by HKI. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by HKI will be in accordance with each Client's investment objectives and goals. For certain accounts, HKI does not have discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior approval from the Client. The Advisor will contact the Client and obtain approval prior to executing trades or allocating investment assets. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 14 Item 17 – Voting Client Securities HKI does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither HKI, nor its management, have any adverse financial situations that would reasonably impair the ability of HKI to meet all obligations to its Clients. Neither HKI, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. HKI is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six quarters or more in the future. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 15 Form ADV Part 2B – Brochure Supplement for Todd M. Thorsen, CFA® Chief Executive Officer and Chief Compliance Officer Effective: March 4, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Todd M. Thorsen, CFA®, (CRD# 4108429) in addition to the information contained in the Hunter Keith Industries Inc. (“HKI” or the “Advisor”, CRD# 332688) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the HKI Disclosure Brochure or this Brochure Supplement, please contact us at (612) 204-0405. Additional information about Mr. Thorsen is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4108429. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 16 Item 2 – Educational Background and Business Experience Todd M. Thorsen, CFA®, born in 1970, is dedicated to advising Clients of HKI as the Chief Executive Officer and Chief Compliance Officer. Mr. Thorsen earned a BA from Franklin & Marshall College in 1992. Mr. Thorsen also earned an MBA from Indiana University - Bloomington in 1997. Additional information regarding Mr. Thorsen’s employment history is included below. Employment History: 09/2023 to Present 03/2010 to 09/2023 Chief Executive Officer and Chief Compliance Officer, Hunter Keith Industries Inc. Senior Managing Director, Medtronic PLC Chartered Financial Analyst™ (“CFA®”) The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a trademark owned by CFA® Institute. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Thorsen. Mr. Thorsen has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Thorsen. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Thorsen. However, we do encourage you to independently view the background of Mr. Thorsen on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4108429. Item 4 – Other Business Activities Mr. Thorsen is dedicated to the investment advisory activities of HKI’s Clients. Mr. Thorsen does not have any other business activities. Item 5 – Additional Compensation Mr. Thorsen is dedicated to the investment advisory activities of HKI’s Clients. Mr. Thorsen does not receive any additional forms of compensation. Item 6 – Supervision Mr. Thorsen serves as the Chief Executive Officer and Chief Compliance Officer of HKI. Mr. Thorsen can be reached at (612) 204-0405. HKI has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of HKI. Further, HKI is subject to regulatory oversight by various Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 17 agencies. These agencies require registration by HKI and its Supervised Persons. As a registered entity, HKI is subject to examinations by regulators, which may be announced or unannounced. HKI is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 18 Privacy Policy Effective: March 4, 2025 Our Commitment to You Hunter Keith Industries, Inc. (“HKI” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. HKI (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. HKI does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 19 How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes HKI does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where HKI or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients HKI does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (612) 204-0405. Hunter Keith Industries, Inc. 681 Lake Street East, Suite 262, Wayzata, MN 55391 Phone: (612) 204-0405 Page 20