A. Description of the Advisory Firm CFI is a Registered Investment Adviser with the SEC, and Broker-Dealer, member FINRA and SIPC. CFI commenced operations in 1992 with the corporate headquarters being located in Anaheim, California. The principal owner of CFI is the Federation of Financial Services (“FFS”), owning more than 75% of the Firm. CFI offers a variety of advisory services through Investment Adviser Representatives (“IARs”) who are associated with the Firm. IARs are independent contractors who are registered to provide advisory services through CFI. IARs are also Registered Representatives of CFI and may also be licensed insurance agents. B. Advisory Services Offered The services provided by IARs primarily include financial planning and consulting, asset allocation, investment management and the utilization of Third-Party Money Managers (“TPMMs”) to manage client assets as deemed suitable. IARs may provide advisory services on a non-discretionary or discretionary basis. Clients who choose a non- discretionary advisory arrangement must be contacted by their IAR and provide authorization prior to the execution of any trades in their account(s). Clients who choose a discretionary advisory arrangement authorize their IAR to supervise and direct the portfolio management of the account(s) without prior consultation and approval by the client. CFI offers the following advisory services:
• CLASSIC Plus Programs CLASSIC Plus is a fee-based advisory program through which IARs manage client accounts or, depending on the program selected, may choose from approved TPMMs to manage their assets within an account for an annual advisory fee. CLASSIC Plus allows clients to invest in various types of securities, such as, but not limited to:
• Stocks • Exchange Traded Funds (ETFs)
• Mutual Funds • Unit Investment Trusts (UITs)
• Bonds • Alternative Investments
• Options • Cash and/or Cash Equivalents CLASSIC Plus offers multiple clearing and custodial options depending on the program selected. After consultation with their IAR, a client may select a CLASSIC Plus program appropriate for their objectives, goals, financial situation and risk tolerance, and will enter into an investment advisory agreement with CFI for those services. In selecting a desired CLASSIC Plus program, the client will authorize CFI to open an account with the available custodian at the time the client enters into the investment advisory agreement. Specifics of each program, including the minimum investment, available custodian, fees, expenses and other important information, are disclosed in the investment advisory agreement for each available program.
• CLASSIC Plus – Morningstar® Managed PortfoliosSM CFI offers Morningstar® Managed PortfoliosSM (“MMP”) through the Firm’s custodial relationship with Pershing. MMP offers professional guidance and access to strategies that can help investors reach their financial goals. The broad lineup of stock, ETF and mutual fund managed portfolios is designed to help meet the needs of clients at each stage of their lifetime. MMPs are offered by Morningstar Investment Services LLC, a Registered Investment Adviser and subsidiary of Morningstar Investment Management LLC. MMPs are intended for citizens or legal residents of the United States or its territories and can only be offered by a Registered Investment Adviser, or IAR. Portfolio construction and Centaurus Financial, Inc. 5 of 23 V. 07/28/2023 ongoing monitoring and maintenance of the portfolios within the program are provided on Morningstar Investment Services’ behalf by Morningstar Investment Management LLC, a Registered Investment Adviser and subsidiary of Morningstar, Inc. Morningstar Investment Services LLC and its affiliates are not affiliated with CFI or its affiliates.
• CLASSIC Plus – FlexUMA CFI offers CLASSIC Plus – FlexUMA (“FlexUMA”), which is a unified managed account investment program, through the Firm’s relationship with multiple custodians. FlexUMA features investment overlay manager Adhesion Wealth Advisor Solutions (“Overlay Manager”). FlexUMA consists of model portfolio strategies comprising individual equity securities, mutual funds and/or exchange-traded funds (“ETFs”) and also provides clients with access to a variety of approved TPMMs. Clients will not have a direct contractual relationship with Overlay Manager, or any other third-party strategist and/or third-party manager (collectively, “Third-Party Service Providers”), through the program, and will work directly with their IAR through CFI. Prior to investing in the FlexUMA program, clients will consult with their IAR and enter into an investment advisory agreement with CFI for those services. Depending on the management services selected, clients will grant the IAR discretionary or non-discretionary authority to manage the account through a selection of Third-Party Service Providers. In addition, clients will authorize the applicable custodian to follow instructions given by the IAR, CFI or Overlay Manager to effect transactions, deliver securities, deduct fees and take other actions with respect to the account. Tax Overlay Management (“Tax Overlay”) services are also available for an additional fee. If elected, Overlay Manager will develop a tax strategy for the account based on the information and instructions provided by the IAR or CFI on behalf of the client. Overlay Manager does not provide general tax advice, tax return preparation or tax- planning services. Overlay Manager will seek to reduce the overall tax burden of the account while seeking to maintain the risk and return characteristics of the model portfolios received from Third-Party Service Providers on the account. Overlay Manager will seek to avoid short-term gains where possible, but long-term gains are not limited unless the client has requested a mandate to limit realized long-term gains. Overlay Manager will provide Tax Overlay with the assumption that those services will be provided to the account for an entire tax year. Termination or removal of the Tax Overlay before the completion of an entire tax year may result in adverse tax consequences, including without limitation, realization of short-term capital gains. Regardless of the account size or other factors, CFI highly recommends that clients consult with their CPA or tax adviser regarding the election or removal of the Tax Overlay service on their account. It is important that clients review the Form ADV Part 2A Brochures for Overlay Manager and other disclosure documents prior to, or at the time of, opening a FlexUMA account.
• CLASSIC Plus – Adviser-Directed CFI provides an additional service for client held-away accounts that are maintained at independent third-party custodians. When this additional service is elected by a client, CFI utilizes the Pontera order management system to implement asset allocation or rebalancing strategies on behalf of the client for these held-away accounts. These are primarily employer-sponsored retirement plan accounts, 529 plans and other assets primarily maintained by the client.
• CLASSIC Plus – Advisory Annuity & Variable Life Management CFI offers the CLASSIC Plus Advisory Annuity (“AA”), and Variable Life (“VL”) management programs. IARs manage the sub-account assets within a client’s annuity or variable life policy directly with the issuing insurance company. IARs may provide this service on a non-discretionary or discretionary basis. Prior to providing this service, client Centaurus Financial, Inc. 6 of 23 V. 07/28/2023 will consult with their IAR and enter into an agreement with CFI for those services, if the client deems that the management of their annuity or variable life policy is appropriate. Management of annuity or variable life sub-accounts is limited to the sub-accounts available and offered by the issuing insurance company for the specific policy. If a commission is earned by the IAR upon the purchase of a specific policy to be managed, an advisory fee is not imposed for at least twelve months from the original purchase date.
• CLASSIC Plus – Alternative Investments and Direct Participation Programs CFI generally does not allow its clients to hold alternative investments or direct participation programs in fee-based advisory accounts. However, at our discretion, CFI may hold alternative investments or direct participation programs (DPPs) such as non-traded REITs, non-traded BDCs, private real estate investments and certain other direct participation programs in advisory accounts held at various custodians at a client’s request, under certain circumstances. Alternative investments or direct participation programs are generally not traded on a national securities exchange and therefore have no readily available market value. In some cases, holding these assets in an advisory account may allow clients to avoid additional custodial fees or account maintenance costs that might be incurred if the asset were held elsewhere. In some cases, customers may wish to consolidate accounts for simplicity and request that CFI hold otherwise “excluded” assets as an accommodation. The discretion to grant such requests rests solely with CFI. However, with the exception of a limited list of perpetual life, non-traded REITs, most illiquid, alternative investment or direct participation programs are excluded by CFI from fee-based advisory accounts for purposes of calculating the asset-based fee assessed to the account. CFI has determined that most alternative investments cannot be managed or administered on a fee basis (due to their illiquidity, long-term holding period and infrequent valuations); therefore, most alternative investments are only offered by CFI on a commission basis through our affiliated Broker-Dealer. However, if such an asset

is held in a fee-based account as an accommodation or otherwise, CFI has adopted policies and procedures to ensure such assets are excluded from the calculation of the asset-based fee charged to the account. Although many alternative investment products are made available by the investment sponsor/issuer for purchase “net of commission” to clients who pay an ongoing asset-based fee, CFI generally prohibits such net-of-commission purchases for the reasons previously provided. However, CFI does approve a select list of direct participation programs for use in advisory accounts net of commission or at net asset value as discussed in more detail below. Therefore, a CFI client who wishes to purchase an alternative investment/DPP that is not made available through CFI’s fee-based platform may not be able to purchase such an investment on a fee basis. In those instances, CFI will typically only make such an investment available through its affiliated Broker-Dealer and will require that if the IAR wishes to offer such an investment, he/she does so in his/her capacity as a registered representative, if appropriate. If the IAR acts in his/her capacity as a registered representative, he/she will typically be compensated through the receipt of his/her share in the commission paid by the product and, depending on the selected share class, may be paid ongoing distribution fees. It is possible that other Registered Investment Advisory firms could offer the same investment net of commission on a fee basis based on their own policies, and CFI clients have no obligation to purchase this type of investment (or any investment) through CFI’s affiliated Broker-Dealer. If a purchase is made on a commission basis through a registered representative, such commissions and fees are outlined in the prospectus or offering memorandum of the particular offering and should also be discussed directly with the representative. If a representative receives a commission based on the sale of an alternative investment/DPP, CFI has policies and procedures in place to ensure that a fee is not assessed on that asset if it is moved to a fee-based account. As stated above, CFI has made certain non-traded investments available for purchase and management in its fee- based accounts. Typically, such investments are approved for fee-based accounts based on distinguishing characteristics of the particular investment, such as more frequent valuations, enhanced liquidity or opportunity for management of the investment through more frequent buy or sell opportunities (redemptions). These investments are approved to be recommended at net asset value (NAV) and therefore up-front commissions are not charged to clients. CFI typically only allows non-traded investments to be held in its fee-based accounts and Centaurus Financial, Inc. 7 of 23 V. 07/28/2023 included in the calculation of the asset-based fee of the account if the particular non-traded investment has policies in place or has indicated the ability to establish a reliable valuation process. CFI does not participate in the third-party valuation process.
• CLASSIC Plus – Performance Reporting In addition to account statements provided by the account custodian, clients may also have access to quarterly performance reports noting fees, holdings, account performance and other account-related information. Performance reports are provided for informational purposes only and are not official records of CFI. Reports are prepared using sources and information believed to be reliable and are not a guarantee of positions owned or of the market value of such positions. Although great effort is taken to provide accurate information, these reports should not be used for tax or legal purposes. Clients should compare performance reports against statements received from the account custodian and should bring any inconsistencies or questions to the immediate attention of their IAR or CFI. CFI has entered into an agreement with Orion Advisor Services, LLC (“Orion”) and Overlay Manager to provide, among other things, account reconciliation, reporting, securities pricing and valuation, and fee calculation services for client accounts. In computing the market value of any security or other investment in the account, each security listed on a national securities exchange will be valued by Orion and/or Overlay Manager, as of the valuation date, at the closing price on the principal exchange on which it is traded, or as determined by Orion and/or Overlay Manager. Any other security or investment in the account will be valued based on prices obtained or provided by Orion and/or Overlay Manager.
• Third-Party Money Management (TPMM) Programs IARs may also recommend the services of approved TPMM programs. These programs are typically managed on a discretionary basis, and each TPMM may offer different types of investment programs and/or services. TPMM programs offer access to a variety of investment portfolio models and strategies with varying levels of risk. After consultation with their IAR, a client may select a TPMM investment management program appropriate for their objectives, goals, financial situation and risk tolerance. Clients will then enter into a separate investment advisory agreement with the TPMM for those services. TPMMs are separately Registered Investment Advisers and are not affiliated with CFI.
• Retirement Plan Services CFI, through its IARs, may also provide advisory services to ERISA-qualified plans, such as pensions, 401(k) plans, profit-sharing plans and other retirement saving vehicles (the “Plan”). IARs will review with the client the expectations, goals and attributes of the Plan to determine the course of action to be taken. Such services are further outlined in a separate ERISA Plan Disclosure. IARs may serve as the Plan’s investment adviser pursuant to §3(21) of ERISA by formulating and presenting recommendations to the Responsible Plan Fiduciary (“RPF”) for his/her approval. IARs will evaluate the demographics of the Plan’s participants to help select investment options that are appropriate for their retirement needs based upon ERISA §404(c)’s requirement that participant-directed retirement plans offer a “broad range” of investment options. IARs may prepare a summary of services recommended, including employee plan enrollment, employee education seminars and assisting the RPF with service provider selection and review. In providing advice to ERISA-qualified Plans, IARs are not permitted to have discretion or management authority over plan assets, nor can they be a “named fiduciary.” As such, IARs are limited to providing non-discretionary services. IARs may recommend placing assets with a TPMM who may be given additional authority by the Plan. Any such services provided by a TPMM are subject to a separate agreement executed between the Plan and the TPMM. Centaurus Financial, Inc. 8 of 23 V. 07/28/2023 When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours.
• Financial Planning and Consulting Services CFI provides clients with a broad range of financial planning and consulting services which may include, but are not limited to:
• Investment Planning • College Planning • Insurance Planning
• Retirement Planning • Estate Planning • Health/Medical Planning
• Income Planning • Business Planning • Social Security Planning After consultation with their IAR, a client may request financial planning and consulting services appropriate for their financial situation and will enter into a financial planning and consulting services agreement with CFI for those services. The IAR will gather information regarding the client’s investment objectives and financial situation, which may include current investments and assets, tax status, insurance coverage, liquidity, risk tolerance, retirement goals, time horizon, and estate needs, among other things. After completion of the fact- gathering process, the IAR will use the data to develop recommendations and will present them to the client.
• Other Professional Services In addition to financial planning and consulting, some IARs may be licensed or able to provide other professional services such as legal, real estate or accounting services. Such services, if provided to the client, will be provided under a separate agreement and are not related to any services provided through CFI. C. Tailored Advisory Services While this Brochure discusses the general services offered through CFI, each individual client works with an IAR to determine the necessary advisory services to be provided based on the uniqueness of each client's investment objectives, goals, financial situation, risk tolerance and needs. D. Wrap Fee Programs The fees paid for any associated wrap fee program cover the advisory fee, brokerage commissions and, depending on the specific program, other trading and transaction-based costs placed through the program’s custodian. CFI receives and retains a portion of the wrap fee for the Firm’s services. E. Assets Under Management As of 04/30/23, CFI had the following amount of Assets Under Management (“AUM”) on a discretionary and non- discretionary basis.
• $1,680,801,400.00 on a discretionary basis
• $3,531,199,929.00 on a non-discretionary basis Centaurus Financial, Inc. 9 of 23 V. 07/28/2023