Firm Description Creative Financial Designs, Inc. (hereinafter, “the firm” or “Creative”) is a corporation formed according to the laws of the State of Indiana and an investment advisor firm registered with the SEC in 1982. The firm provides a variety of services through its investment adviser representatives. Creative is a privately owned SEC-registered investment advisor. Ownership Creative is privately owned by several parties, including Brent Owens, who owns approximately twenty-five percent, and the Mick Owens Family Trust, which owns approximately Seventy-three percent. Brent Owens is also the President of the firm and who also serves as an Investment Adviser Representative of Creative. The current trustees of the Mick Owens Family Trust are Mick Owens and Kathy Owens. Mick Owens is the founder of Creative and serves as an Investment Adviser Representative of Creative. The Mick Owens Family Trust and Brent Owens, are also significant stockholders of a related company, cfd Investments, Inc., an SEC-registered broker/dealer and member of FINRA and SIPC, and an insurance agency. (See Item 10: Other Financial Industry Activities and Affiliations). Mick Owens is also the principal owner of several other companies founded to complement the comprehensive financial planning and investment management services of Creative. Those companies include cfd Realty [owned by Mick’s wife, Kathy Owens], and cfd Insurance Planners [a life and health insurance agency]. Amount of Assets Managed By Creative Creative As of the fiscal year ending December 31, 2023, the amount of client assets the firm managed totaled $2,082,130,981. Of that total, $2,076,330,711 was managed on a discretionary basis and $5,800,270 was on a non-discretionary basis. Investment Advisory Services Provided Creative offers discretionary management and non-discretionary investment and insurance advisory services and financial planning and consulting services. Investment Managed & Advisory Account Services The firm’s investment management & advisory services are comprised of three distinct service platforms: Brokerage Management, Self-Directed Retirement Management, and Variable Annuity Management. Brokerage Management is also divided into In-House Brokerage Management and Adviser Discretionary Management. The firm also provides non-discretionary investment advisory services. When Creative provides investment advice to clients regarding retirement plan accounts or individual retirement accounts, and only under such circumstances, Creative is a fiduciary 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 Creative makes money creates some conflicts with your interests, however Creative complies with applicable legal and regulatory requirements. Under these requirements, Creative must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that Creative gives advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you information about conflicts of interest. Brokerage Management Descriptions and Account Minimums Under the In-House Brokerage Management platform, the firm manages a client’s brokerage account according to the client’s selections of the investment strategy and any allowable portfolio objective. The client will provide information to the firm, including a client’s selected portfolio objective. - Each available investment strategy is unique, and can be invested using securities such as; common and/or preferred stocks, bonds, government securities, other fixed income securities, mutual funds, exchange-traded funds, options on any of the foregoing, certificates of deposit and money market funds or other cash-like investments. This is not intended as an exhaustive list of all of the types of investments that could be used for portfolio strategies, and instead is a listing of some of the most commonly used investment types, A more detailed listing of investments is provided in connection with discussion about specific strategies, which are discussed in more detail following. In connection with certain management strategies, there may be the use of options transactions. Additionally, though the firm does not typically invest based on margin, investors may decide to make distributions utilizing margin instead of liquidating positions in order to free up cash. Though the investor may decide to use margin or options in their accounts, the use of these as part of a strategy does increase risk with the account. Also, use of a margin account would increase costs to the investor. These costs are described in the paperwork provided by the selected custodian, and are not reflected in Designs documentation. Investors are encouraged to evaluate the risks and fees associated with any investment strategy before selecting that strategy. The firm primarily uses asset-class model allocations based on research with other professional management models such as Morningstar (formerly Ibbotson), JP Morgan, Goldman Sachs, PIMCO, Northern Trust, Vanguard, etc. Creative’s models generally fall into five categories based on perceived risk models: Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive, referred to as Portfolio Objectives. Available investments are categorized according to the model guidelines and overall asset allocation is determined taking those categorizations, and investment and portfolio research into effect, in arriving at the respective model portfolio allocations. The Large Cap Growth, Large Cap Value and Global investment strategies are focused on one asset-class and not diversified across asset classes and asset types, while all other asset-class model portfolios are diversified across asset classes and asset types. The client can select from several “investment strategies” with the firm. They are as follows:
• American Funds Focused -minimum $25k account size
• Best in Class -minimum $25k account size
• Biblical Faith Values CFD4 -minimum $10k account size
• Biblical Faith Values Combination -minimum $25k account size
• Biblical Faith Values Eventide Focused
• Biblical Faith Values Funds -minimum $25k account size
• Biblical Faith Values Income -minimum $50K account size
• Biblical Faith Values Inspire Focused
• Biblical Faith Values Timothy Focused
• CFD4 -minimum $10k account size
• Combination -minimum $25k account size
• Exchange Traded Funds -minimum $25k account size
• Five Tool -minimum $25k account size
• Fundamental Opportunities -minimum $25k account size
• Funds -minimum $25k account size
• Income Strategy -minimum $50k account size
• Progressive Trends -minimum $25k account size
• Tax-Wise -minimum $100k account size For management that does not utilize multiple portfolio objectives based on Creative’s traditional asset allocation models, the following options are available:
• Global
• Large Cap Growth
• Large Cap Value Creative also provides, from time to time, customized managed account services whereby management & advisory services are provided apart from the strategies described above. These are permitted and approved by Creative’s Management Team on a case-by-case or other limited basis. For all the previously mentioned investment strategies, client accounts must be established with a registered broker/dealer. These services are available through accounts established at cfd Investments, Inc. through National Financial Services, LLC. (hereinafter, “NFS”). These services are also available through accounts established at Charles Schwab & Co., Inc. (hereinafter (Schwab”), or such other broker/dealer as selected by the client and approved by the management of Creative Financial Designs, Inc. Please note that the charges and fees applied by the broker/dealer relating to account maintenance and services are not generally described herein. Clients are encouraged to review account-opening documentation, statements, and other clearing firm documentation and related information carefully to determine other fees or charges that apply and that are assessed by their broker/dealer and/or associated clearing firms. To the extent that cfd investments is selected as the client’s broker/dealer, cfd Investments, Inc. will receive compensation for services provided, and such compensation shall be distinct from the advisory fees described herein. This compensation can include, without limitation, transaction-based compensation, asset-based compensation, compensation based on other services provided by cfd Investments and/or NFS, revenue share arrangements, and other compensation, including 12b-1 fees. Additionally, NFS provides compensation to cfd Investments, Inc. based on customer’s selections to have documents provided to them electronically, instead of through the mail. In conjunction with Creative, cfd Investments, has prepared a Reg Best-Interest Disclosure that identifies material conflicts of interest relating to its practice. The Conflicts of Interest Disclosure is also considered a disclosure of Creative, and is meant to augment and further clarify this Form ADV2a. With respect to accounts established at NFS, and to the extent that funds can be deposited into cash equivalents, such funds will be deposited through use of the FDIC sweep program or similar type vehicles, subject to a contrary election made by the client. Discussion about the details of that can be found on the firm’s website (www.creativefinancialdesigns.com). cfd Investments will receive compensation for FDIC insured deposits through the program, subject to the terms and conditions of the program. cfd Investments will also receive compensation for money market sweeps. cfd Investments and NFS coordinate to set the interest rate that customers make under the FDIC Insurred program, and compensation to cfd Investments is affected by the interest rate selected, so that the compensation to cfd Investments increases if the interest rate to the client is lower. This creates a conflict of interest between Creative and clients. The amount of compensation to cfd Investments, Inc. differs between the FDIC insured deposits and the money market sweep programs. Additionally, performance differs between these programs. With respect to all standard (non-custom) strategies, Creative sets as the default option to have cash positions swept into the FDIC insured deposits, subject to availability of the program. This selection is made, as under certain market conditions, money market positions could be valued less than $1 per share (meaning that a client could lose money on the position) or may be subject to limited liquidity. Though these market circumstances are rare, it is the intention that the cash portion of a portfolio should be guaranteed by FDIC. Investors can opt out of this default option, at their election. Additionally, different custom strategies may not follow this default. For funds utilized through the FDIC program, neither cfd Investments nor Creative selects the banks that will be utilized. Clients may request that funds be deposited into money market funds instead of the FDIC sweep program. If a client’s managed brokerage account falls below the account minimum, the firm reserves the authority to change the chosen strategy to one that is more conducive to the management of assets at that level, or to discontinue management in its entirety (e.g. client had $80k in the combination strategy, and then withdrew $65k from the account. Creative could move the assets to the CFD4 strategy or some other suitable strategy or terminate management on the account). Creative reviews accounts for adherence to the account minimum requirements at the end of each calendar year or as distributions happen, or at such other time as Creative may desire. Upon review, Creative will make strategy changes accordingly. Clients can choose to change their strategies at any time, by providing written notice to Creative, as long as the client’s investment in the strategy meets the stated minimums for the strategy selected. Adviser Discretionary Management Under the Brokerage Management Platform, approved investment adviser representatives may manage client accounts directly, and may do so based on consultation with the client as to their needs and objectives. Portfolios are managed by the Investment Adviser Representative in accordance with the firm’s policies and guidelines, and consistent with the client’s selected portfolio objective. The descriptions of strategies and trading in this FORM ADV do not describe each investment adviser representative’s individual trading and management style. General Provisions on Account Management Unaffiliated custodians hold all client securities with Creative. (By way of clarification, assets maintained in accounts with cfd Investments, Inc., an affiliate of Creative, are maintained at custodians that are not affiliated with Creative or cfd Investments, Inc.) Securities are held in the client’s name, or the name of the applicable custodian or trust, in the case of qualified accounts. Clients can select the custodian that they use for the establishment of an account, subject to limitations imposed by Creative. The choice of custodian will affect what investment options are available to a client, and the costs associated with a particular investment, and the availability of specific investment. As such, model portfolios maintained by Creative differ based on the custodian chosen by the customer. Product issuers may issue investments in varying share classes that often include differences in internal expenses. Not all products are available through each custodian that Creative utilizes. As a result, the same investment strategies as maintained through different custodians may have different holdings. Creative does not guarantee that the products’ lowest-cost share classes will be available through each custodian utilized by Creative. Creative attempts to select for client the lowest-cost available share class when engaging in mutual fund transactions on behalf of the client. When it becomes known that lower cost share classes are available than the product held by the client, the firm engages in a process to convert the selected shares to the lowest-cost share-class available through the applicable custodian. To the extent possible, Creative will attempt to conduct such transactions at no cost to the client, and without any taxable event to the client. All conversions are subject to the policies and procedures of the applicable account custodian. Additionally, different custodians have different policies and procedures, and they may affect many items relating to the customer including, without limitation: transaction fees, custodial fees, and other fees and expenses. Additionally, such differences may also affect availability of investments and lowest share class options. Clients are encouraged to discuss this matter with their financial professional so as to understand these differences when selecting a custodian. There are costs that are paid by investors in connection with their selection of a custodian, and those costs vary between and among custodians. Services also differ between and among custodians. Clients are responsible for all fees and expenses charged by the custodian regarding their investment holdings. For a list of fees and expenses, refer to information created by the respective custodians. Clients may request to place reasonable restrictions on certain aspects of the management of their accounts. For instance, clients may elect to retain certain securities in their managed account and not have those assets be subject to sale in the course of Creative’s management of the account. Clients may also elect, in some circumstances, to have capital gains “distributed” to be taken over a specified period of time. Creative charges its management fee inclusive of such assets because of the additional work and considerations that must be afforded in accommodating such client-imposed restrictions. The client can move any of the said assets to another non-managed account if desired to avoid additional fees. Creative may, at times, allow additional special requests of the client regarding the management of the client’s account. Creative has several investment strategies whose titles include the word ‘Focused’. The term ‘Focused’ is used to let investors know such strategies will be using the listed investment company’s investments more than in the strategy options not identified as “Focused”. The actual holding in funds of the particular fund family will vary, and the concentration level of the focused fund family will fluctuate over time. It is the goal that at all times the Focused strategy will maintain a higher concentration of the subject issuer’s products than the corresponding non- focused strategies. Because of a concentration within one company’s investments, this decreases diversification and additional risk may occur including additional investment overlap. American Funds Focused -- Description The American Funds Focused investment strategy is a diversified strategy focusing on the use of American Funds investments as the base of the diversified portfolio. The strategy uses American Funds mutual funds and ETFs along with other mutual funds and ETFs to fill in the completed allocation helping fully diversify and add additional asset classes that American Funds may lack or that the management team feels is better to use in place of an American Funds investments. The screening process generally consists of in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry standard software tools as well as through needed communication with the fund’s managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 10 to 15 mutual funds and ETF’s are employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. This strategy likely has additional investment risk with the higher concentration in one fund family. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Best in Class – Description The Best in Class investment strategy is a diversified strategy focusing on the use of ETFs and likely few mutual funds and individual stocks. The strategy uses US News investment research along with others to help determine the best investment choices for each portfolio. The addition of using a limited number of individual stocks, likely increases the overall portfolio risks. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. The screening process for the Best-in-Class investment strategy focuses on historical ETF performance, very low internal investment cost, and a goal of overall lower portfolio risk and volatility. This information, along with an analysis of the overall economic health to determine appropriate portfolio objective risk, filtered through independent investment research companies of U.S. News and Morningstar, Inc. U.S. News and Morningstar updates the investment information monthly and the strategy compares investments on a monthly basis and makes changes as necessary. The strategy looks to have 10-15 investments inside each portfolio objective. The actual number of holdings varies by portfolio objective and overall current investment strategy goals. The Best in Class strategy monitors non-qualified account trading differently than qualified accounts. The team analyzes trading more extensively in non-qualified accounts to potentially reduce taxable gains. This means that qualified accounts and non-qualified accounts may have different allocations and trading. Also, for smaller accounts (under $25,000) in Best in Class strategy, different holdings may be utilized and thus the allocations within larger accounts and smaller accounts may differ. Biblical Faith Values – CFD4 – Description The Biblical Faith Values CFD4 strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a Biblical Responsible Investing (BRI) strategy. Under this strategy, Creative utilizes certain, independent third-party asset screening programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investments in companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 4 to 7 BRI mutual funds and ETF’s may be employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more- diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. exclude any and all companies that could be excluded based on the criteria above, however, this strategy attempts to substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. The Biblical Faith Values CFD4 investment strategy attempts to invest in accordance with the Biblical Faith Values limitations described prior, and to create a likely simpler diversified portfolio based on mutual fund & ETF positions. This strategy likely uses up to four asset classes (may be less or more given the portfolio objective selected) and holding perhaps as few as four investments, however, the firm’s Management reserves the right to increase and decrease each, as it sees fit. Additional portfolio risk in this strategy occurs with less diversification and investments and this strategy can be more volatile than other further diversified strategies. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Certain ETFs have additional market risks in that they are not always highly traded and thus have less volume daily. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are loosely modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Combination -- Description The Biblical Faith Values Combination strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify an investment’s risk characteristics, performance metrics, management quality (mutual funds/ETFs), and fundamental attributes (stocks). These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ and the companies’ management. The investment management team seeks to optimize the risk/return profile of the portfolio and maximize the benefits of diversification by selecting categorically top-ranked funds and high-quality stocks. In a given portfolio, approximately 10 to 15 mutual funds/ETFs and 3 to 6 stocks are employed to achieve the strategy’s objective. The actual numbers vary by portfolio objective and are based on asset class exposure. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more- diversified strategy. Certain ETFs have additional market risks in that they are not always highly traded and thus have less volume daily. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. The Biblical Faith Values Combination investment strategy attempts to invest in accordance with the Biblical Faith Values limitations described prior, and to create a diversified portfolio based on a combination of mutual funds, ETFs, and individual equity positions. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. From time to time, not all of these categories will be reflected in the portfolio. The firm’s management reserves the right to use or not use at any given time the three prior mentioned investment vehicles. The addition of using a limited number of individual stocks, likely increases the overall portfolio risks. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Eventide Focused -- Description The Biblical Faith Valued Eventide Focused strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The ETF’s and funds selected are typically those that perform at the top of their category in terms of the analytical metrics examined. In a given portfolio, up to approximately 15 BRI funds and ETF’s are employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. Due to a limited pool of available investments in certain management strategies, Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. attempt to follow the models established by Creative Financial Designs. The Eventide Focused investment strategy is centered on using the Eventide companies’ mutual funds. Eventide has several mutual funds that attempt to filter Biblically. Many of Eventide’s equity mutual funds have an increased concentration in the health-care sector and this may increase risk in the portfolio. The Eventide mutual funds will typically be a sizeable portion of the portfolio and Creative’s Management Team uses other mutual funds and possibly ETF’s also BRI filtered to make up the entire portfolio allocation to maximize diversification. The Eventide Focused investment strategy will have additional market risks in that the BRI ETF’s may not always be as highly traded and thus have less volume as other ETF’s might have. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. This strategy likely has additional investment risk with the higher concentration in one fund family. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Funds – Description The Biblical Faith Values Funds strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 8 to 15 BRI mutual funds and ETF’s may be employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more- diversified strategy. Certain ETFs have additional market risks in that they are not always highly traded and thus have less volume daily. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. The Biblical Faith Values Funds investment strategy attempts to invest in accordance with the Biblical Faith Values limitations described above, and to create a diversified portfolio based on mutual funds & ETF positions. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Income Strategy – Description The Biblical Faith Values Income strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The Biblical Faith Values Income Strategy is designed to provide a diversified income portfolio solution for clients. These portfolios are focused on generating income with the goal of providing relatively stable yield given most market conditions. The selection of the portfolio objective determines the percentage of the portfolio that is in fixed income versus equities. The Income Strategy uses individual stocks for equity exposure as needed given the portfolio objective and mutual funds, and ETF’s, and in rare occasions individual bonds, for fixed income exposure. The fixed income portion of the portfolios structured in such a way when possible to provide regular interest/dividend income, stagger fixed income maturities, take advantage of prevailing market trends, and provide top-tier investments with regard to quality. Bond yield is maximized through security type, purchase methodology, bond issue features, and overall through portfolio structuring and research. For equity exposure, stocks yielding dividends are selected with independent software ValueLine and specifically filters such as: Financial Strength, Safety, and Price Stability ratings, current dividend yield, and historical dividend increases and growth. Likely 8-25 investments are held depending on the portfolio objective. The equity portion of the portfolios (all but the Conservative portfolio, as it does not include equities) are primarily focused on large cap and giant large cap value/blend stocks. Creative uses Bloomberg, ValueLine, Dorsey Wright, and Morningstar (and possibly other resources) to help search, identify, price, rank and determine the diversified equities to use in any given account. The firm’s goal is to find price stability using several key matrices such as and not limited to: financial strength, safety ratings, yield, sectors, price points, dividend stability, etc. The number of equity holdings are limited by the account size. The individual holdings and the number of equities may vary from account to account and are diversified through various sectors. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive). Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. If used, holding individual bonds can also lead to additional risk given the economic conditions. Owning fewer asset classes will produce less diversification in a portfolio. Biblical Faith Values – Inspire Focused -- Description The Biblical Faith Values Inspire Focused strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The ETF’s and funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 8 to 15 BRI funds and ETF’s are employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. attempt to follow the models established by Creative Financial Designs. The Inspire Focused investment strategy is centered on using the Inspire companies’ ETFs. Inspire has several index ETFs (with plans to increase their ETF offerings) that attempt to filter Biblically. The Inspire ETFs will typically be a sizeable portion of the portfolio and Creative’s Management Team uses other mutual funds and possibly ETFs also BRI filtered to make up the entire portfolio allocation to maximize diversification. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. The Inspire Focused investment strategy will have additional market risks in that the ETFs are not always highly traded and thus have less volume as other ETFs might have. This strategy likely has additional investment risk with the higher concentration in one fund family. This creates additional risk when buying and selling these ETFs in larger amounts. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Tax-Wise Strategy -- Description The Biblical Faith Values Tax-Wise strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The ETF’s and funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 15 BRI funds and ETF’s are employed to achieve

the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. The Biblical Faith Values Tax-Wise Investment Strategy is available for non- qualified brokerage accounts and primarily uses ETFs and municipal mutual funds available through custodians, though the firm may also choose to use other investments to build the diversified portfolios. Muni mutual funds and ETF’s are usually used for fixed income areas and ETF’s for the equity for the available portfolios. The screening process generally consists of analyzing the tax implications of a fund in addition to an in-depth analysis to identify its risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the fund’s managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 10 - 15 ETFs and mutual funds are employed to achieve the strategy’s objective. The goal for the strategy is to reduce the amount of taxable income, dividends, and capital gains for the account. Using ETFs helps Creative use investments that historically allow clients to keep more and reduce the potential amount of capital gains passed through to accounts. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Holdings will likely vary from account to account due to client’s capital gains concerns. attempt to follow the models established by Creative Financial Designs. Biblical Faith Values – Timothy Focused -- Description The Biblical Faith Values Timothy Focused strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The ETF’s and funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 8 to 15 BRI funds and ETF’s are employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. attempt to follow the models established by Creative Financial Designs. The Timothy Focused investment strategy is centered on using the Timothy Plan Mutual Funds and ETFs. The portfolios in this strategy will likely include a larger amount of Timothy investments along with other ETFs and/or mutual funds also BRI filtered to make up the entire portfolio allocation to help further diversify portfolios. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. Timothy investments, especially the ETFs, will have additional market risks in that the ETFs are not always highly traded and thus have less volume as other ETFs might have. This creates additional risk when buying and selling these ETFs in larger amounts. This strategy likely has additional investment risk with the higher concentration in one fund family. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. CFD4 -- Description The CFD4 brokerage investment strategy uses mutual funds and ETFs likely using as few or fewer than four asset classes (may be less or more given the portfolio objective selected) and holding perhaps as few as four investments. Creative’s Management reserves the right to increase and decrease each however. Additional portfolio risk in this strategy occurs with less diversification and investments and this strategy can be more volatile than other further diversified strategies. The screening process generally consists of in-depth analysis to identify a fund’s risk characteristics, performance metrics, overall diversification and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the fund’s managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 4 to 7 mutual funds and ETF’s may be employed to achieve the strategy’s objectives. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are loosely modeled after Creative Financial Designs’ overall diversified asset class models. Combination -- Description The Combination investment strategy focuses on diversification by using a combination of mutual funds, ETFs, and limited individual equities to build the respective investment portfolios. From time to time, not all of these investment types will be reflected in the portfolio. Creative’s Management Team selects the investments and investment types from the said categories based on internal research. The screening process generally consists of in-depth analysis to identify an investment’s risk characteristics, performance metrics, management quality (mutual funds/ETFs), and fundamental attributes (stocks). These groups of data are gathered utilizing industry standard software tools as well as through needed communication with the funds’ and the companies’ management. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. The investment management team seeks to optimize the risk/return profile of the portfolio and maximize the benefits of diversification by selecting categorically top-ranked funds and high-quality stocks. In a given portfolio, approximately 10 to 15 mutual funds/ETFs and 3 to 6 stocks are employed to achieve the strategy’s objective. The actual numbers vary by portfolio objective and are based on asset class exposure. The firm’s management reserves the right to use or not use at any given time of the three prior mentioned investment vehicles. The addition of using a limited number of individual stocks, likely increases the overall portfolio risks. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Exchange Traded Funds (ETF) – Description The ETF investment strategy is focused on using Exchange Traded Funds to allocate a well-diversified portfolio within the given investment portfolios. Creative Investment Team may add mutual funds to complete the allocation and if asset classes are not available or do not meet the Team’s research requirements. The screening process generally consists of in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. The focus of the ETF strategy is low cost with primarily passive ETF’s and well-diversified portfolios. This group of data is gathered utilizing industry standard software tools as well as needed communication with the fund’s managers. The investments selected typically are those that perform at the top of their category in terms of our analytical metrics. The actual number of ETFs employed in a given portfolio is approximately 10 to 15 investments. This varies on the level of asset class exposure primarily depending on portfolio objective. ETFs are normally a passive investment holding with potentially lower than average internal expenses compared to actively traded mutual funds. Passive investments have a tendency to track the indices they are modeled after. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Five Tool – Description The Five Tool brokerage investment strategy is designed to give clients a rules- based, well-diversified management option while looking to maximize returns given the selected portfolio objective. This strategy likely uses all nine asset-class boxes for portfolio objectives Moderate, Moderate Plus, Moderately Aggressive, Aggressive, and Aggressive Plus. The strategy will likely use fewer asset classes in the Conservative and Moderately Conservative portfolio objectives, however, the goal is to remain well–diversified. The strategy often opportunistically over- weighs investments in tech, health care, or other selected more aggressive sectors in order to bolster potential returns. This increased concentration does increase risk in the portfolio. This strategy uses actively managed mutual funds and potentially ETF’s to fill in the allocations of each portfolio objective with defined rules to help filter for each style box, finding the best mutual fund investments available through the applicable custodian. The screening process for the Five Tool investment strategy is a rules-based standard that focuses on historical performance, lower internal investment cost, and superior historical returns compared to its industry peers. This information, and more, is filtered through independent investment research company Morningstar, Inc. Morningstar updates the investment information monthly and the strategy compares investments on a monthly basis and makes changes as necessary, sometimes just providing a portfolio rebalance. The strategy looks to have 15-20+ active mutual funds and/or ETFs inside each portfolio objective with the typical holding targeting 5%. The actual number of mutual fund and/or ETF holdings varies by portfolio objective and asset class exposure. The strategy attempts to use such mutual funds and/or ETFs that meet a 10-year track record, initially ranked as a five-star according to Morningstar at the time of purchase, Morningstar analyst rated as a gold, silver, or bronze, is highly ranked compared to its appropriate asset class piers, and is lower trending in its internal investment expense compared to other active mutual funds in the same asset- class. Seven portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderate Plus, Moderately Aggressive, Aggressive and Aggressive Plus) and allocations are determined by data analysis. Fundamental Opportunities -- Description The Fundamental Opportunities investment strategy is focused on using active mutual funds and ETFs, but stocks and other investments (including some non- traditional investments) can also be used. This strategy relies on macro-economic analysis and forecasting to determine a tactical investment approach including which asset classes, sectors, etc. to over and under-weight in the portfolio. The Fundamental Opportunities strategy has significant flexibility to achieve its portfolio objective. Its objective is to provide risk-adjusted returns that are superior to the equivalent risk tolerance index. The process of this strategy is to use the top active managers in every asset class to make each individual security selection. Macro- economic forecasting provides a framework to determine which asset classes to over or under weight in the portfolio. The vetting of each asset class manager consists of both a quantitative and qualitative analysis of their process. Portfolios are still usually diversified, however do not have to be, given economic data although at times may not be as diversified as other firm strategies. More active trading can also occur in this strategy depending on market and economic data. Taxable accounts are treated differently in that they are likely traded less than qualified accounts, thus attempting to reduce capital gains especially short- term gains. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and allocations are determined by data analysis. Funds -- Description The Funds Investment Strategy is focused on using mutual funds & ETFs that are available from the respective custodians to allocate a well-diversified portfolio within the given portfolio objectives. The screening process generally consists of in-depth analysis to identify mutual fund and ETF risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry standard software tools as well as through needed communication with the funds’ managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics examined. In a given portfolio, approximately 10 to 15 mutual funds and ETF’s are employed to achieve the strategy’s objectives. The actual number varies by account size, portfolio objective, and is based on asset class exposure. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ other diversified asset class models. Global – Description The Global investment strategy uses mutual funds available through custodians that focus in the international and global asset categories. The strategy is concentrated in the asset category listed and as a result brings more risk because of such. The strategy is also only available under one portfolio objective and that is 100% equities. The strategy does not diversify with fixed income holdings. The screening process for the Global investment strategy focuses on active mutual funds within the large-cap or mega large-cap global and international asset- classes. The investment management team focuses on future value and growth potential, historical performance, lower internal investment cost, and historical superior returns compared to its industry peers and indices. The team also compares stock holdings inside the eligible mutual funds to examine the portfolio overlap and attempt to limit such overlap. This allows for multiple manager philosophies, strategies, and all within the asset-class strategy. The strategy looks to hold 7-12 active mutual funds in the portfolio and make investment selection changes as it feels necessary. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. With the strategy being asset-class limited, volatility would be expected to be higher than a fully diversified portfolio and thus, recommended as a secondary or satellite portfolio to an overall investment portfolio. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. As a result of the above, the strategy is best fit for clients looking to be aggressive in said asset category or as a secondary investment strategy for the Client’s investments. Income Strategy -- Description The overall goal of the Income Strategy is to provide a diversified income portfolio solution for clients. These portfolios are focused on generating income with the goal of providing relatively stable yield given most market conditions. The selection of the portfolio objective determines the percentage of the portfolio that is in fixed income versus equities. The firm offers two options within the Income Strategy: Core and Core/Plus. The differences in the two options relates solely to the fixed income portion of the portfolio as described below. The Income Strategy uses individual stocks for equity exposure as needed given the portfolio objective and individual bonds, mutual funds, and ETF’s for fixed income exposure. The fixed income portion of the portfolios structured in such a way when possible to provide regular interest/dividend income, stagger fixed income maturities, take advantage of prevailing market trends, and provide top- tier investments with regard to quality. Bond yield is maximized through security type, purchase methodology, bond issue features, and overall through portfolio structuring and research. For equity exposure, stocks yielding dividends are selected with independent software ValueLine and specifically filters such as: Financial Strength, Safety, and Price Stability ratings, current dividend yield, and historical dividend increases and growth. Likely 8-25 investments are held depending on the portfolio objective. In the Core option, the fixed income portion focuses on higher-quality income- based mutual funds and ETFs, however, individual corporate and/or municipal bonds can be utilized to build a portfolio designed to generate income. When individual bonds are used, they are initially rated A or better. Creative’s Management Team looks for higher credit quality bonds while also focusing on durations, maturities, diversification across sectors (and if necessary across multiple states for municipals), and of course yield. The client has the option to select tax-exempt municipal bonds for their account, in order to harvest tax-exempt gains. Individual bond holdings if used will vary from account to account. In the Core/Plus option, the fixed income portion focuses on income-based mutual funds and ETFs of varying quality, however, individual corporate and/or municipal bonds can be utilized to build a portfolio designed to generate income. When individual bonds are used, they are initially rated BBB+ or better. Bonds are selected on durations, maturities, diversification across sectors (and if necessary across multiple states for municipals), and of course yield. A small amount of cash will also be held and the potential for a small mutual fund holding for small residual amounts of investments. The client has the option to select tax-exempt municipal bonds for their account, in order to harvest tax-exempt gains. The equity portion of the portfolios (all but the Conservative portfolio, as it does not include equities) are primarily focused on large cap and giant large cap value/blend stocks. Creative uses Bloomberg, ValueLine, Dorsey Wright, and Morningstar (and possibly other resources) to help search, identify, price, rank and determine the diversified equities to use in any given account. The firm’s goal is to find price stability using several key matrices such as and not limited to: financial strength, safety ratings, yield, sectors, price points, dividend stability, etc. The number of equity holdings are limited by the account size. The individual holdings and the number of equities may vary from account to account and are diversified through various sectors. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive). Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. If used, holding individual bonds can also lead to additional risk given the economic conditions. Owning fewer asset classes will produce less diversification in a portfolio. Large Cap Growth – Description The Large Cap Growth investment strategy uses mutual funds available through custodians that focus on the large cap growth category. The strategy is concentrated in the asset category listed and as a result brings more risk because of such. The strategy is also only available under one portfolio objective and that is 100% equities. The strategy does not diversify with fixed income holdings. The screening process for the Large Cap Growth investment strategy focuses on active mutual funds within the large-cap growth or mega large-cap growth asset-classes. The investment management team focuses on future growth potential, historical performance, lower internal investment cost, and historical superior returns compared to its industry peers and indices. The team also compares stock holdings inside the eligible mutual funds to examine the portfolio overlap and attempt to limit such overlap. This allows for multiple manager philosophies, strategies, and ideas all within the asset-class strategy. The strategy looks to hold 7-12 active mutual funds in the portfolio and make investment selection changes as it feels necessary. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. With the strategy being asset-class limited, volatility would be expected to be higher than a fully diversified portfolio and thus, recommended for a secondary or satellite portfolio to an overall investment portfolio. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. As a result of the above, the strategy is best fit for clients looking to be aggressive in said asset category or as a secondary investment strategy for the client’s investments. Large Cap Value – Description The Large Cap Value investment strategy uses mutual funds available through custodians that focus on the large cap value category. The strategy is concentrated in the asset category listed and as a result brings more risk because of such. The strategy is also only available under one portfolio objective and that is 100% equities. The screening process for the Large Cap Value investment strategy focuses on active mutual funds within the large-cap value or mega large- cap value asset-classes. The investment management team focuses on future value and growth potential, historical performance, lower internal investment cost, and historical superior returns compared to its industry peers and indices. The team also compares stock holdings inside the eligible mutual funds to examine the portfolio overlap and attempt to limit such overlap. This allows for multiple manager philosophies, strategies, and ideologies all within the single asset-class strategy. The strategy looks to hold 7-12 active mutual funds in the portfolio and make investment selection changes as it feels necessary. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. With the strategy being asset-class limited, volatility would be expected to be higher than a fully diversified portfolio and thus, recommended as a secondary or satellite portfolio to an overall investment portfolio. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. The strategy does not diversify with fixed income holdings. As a result of the above, the strategy is best fit for clients looking to be aggressive in said asset category or as a secondary investment strategy for the client’s investments. Progressive Trends - Description The Progressive Trends investment strategy is a diversified portfolio strategy focusing on ETFs, however some mutual funds and other investments (including non-traditional investments) may also be utilized. This strategy operates differently with respect to the more conservative accounts than it does for aggressive and moderately aggressive accounts. With respect to the conservative, moderately conservative and moderate portfolios, the equity portion within the portfolios look to use and potentially overweight investments where the underlying managers seek to use market-timing, buffer, market-neutral, etc. investments. These investments use investment strategies that normally attempt to lessen losses during market volatility or weakening economic conditions. These investments attempt to decrease equity exposure or equity exposure based losses during such determined times by moving to fixed income, cash, cash equivalents, transferring to what may be considered safer stocks, option trading or any mixture of such listed and unlisted strategies. With respect to the moderately aggressive and aggressive portfolios, the strategy attempts to enhance returns by including sector-focused investments in the portfolio. Sector investments look to find sectors attractive given economic, financial, and international conditions, as well as other factors. Fixed income holdings within the portfolios are also determined by market, economic, and global conditions. The use of such investments and investment strategies designed for market timing or sector specific may not always be successful in their attempt to decrease potential losses or volatility, nor guarantee gains, and can actually limit market gains and even increase risk of losses. Also, this investment strategy will not be as diversified as standard diversified firm portfolios. This strategy likely has additional investment risk with the higher concentration in fund families that focus on such type of investment goals, sector specific, and increased internal investment cost. In a given portfolio, approximately 7 to 15 mutual funds and ETF’s may be employed to achieve the strategy’s objectives. The Progressive Trends investment strategy will have additional market risks in that the ETFs are not always highly traded and thus have less volume as other ETFs might have. This strategy likely has additional investment risk with the higher concentration in one fund family. This creates additional risk when buying and selling these ETFs in larger amounts. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models, except with respect to the more focused areas as discussed herein. Tax-Wise Strategy -- Description The Tax-Wise Investment Strategy is available for non-qualified brokerage accounts and primarily uses ETFs and municipal mutual funds available through custodians, though the firm may also choose to use other investments to build the diversified portfolios. Muni mutual funds and ETF’s are usually used for fixed income areas and ETF’s for the equity for the available portfolios. The screening process generally consists of analyzing the tax implications of a fund in addition to an in-depth analysis to identify its risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the fund’s managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 10 - 15 ETFs and mutual funds are employed to achieve the strategy’s objective. The goal for the strategy is to reduce the amount of taxable income, dividends, and capital gains for the account. Using ETFs helps Creative use investments that historically allow clients to keep more and reduce the potential amount of capital gains passed through to accounts. Given the more limited holdings, there may be less diversification in this portfolio than in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Holdings will likely vary from account to account due to client’s capital gains concerns. Optional Cash Allocation (OCA) -- Description With respect to all of the strategies described in this section, Creative makes the Optional Cash Allocation (OCA) available to its clients. Under OCA, a client may select an additional portion of their funds (above the parameters in the associated strategy) to be held in money markets or other cash equivalents. This can be added in or removed by the client at any time, and can be used to hedge against a potential market downturn. Fees will be charged on the cash allocation of the portfolio. Client may move all or part of their account to a non-managed account at any time. It is the firm’s recommendation that the use of this allocation should be for a relatively short-term period, and should reflect client’s concerns about market instability over the short term. That said, it is intended as the client’s choice, and the firm will not put any specific time limitation on how long a client may hold a portion of their accounts under the OCA option. Allocate Over Time Option -- Description With respect to all of the strategies described in this section, Creative makes the Allocate Over Time option available for accounts greater than $50,000. If selected by the client, Creative will not likely invest all of the client funds into the selected model portfolio immediately. Instead, Creative will allocate the account more slowly, usually over a 4 to 8-month timeframe, with the intention of investing funds during pullbacks and in different months. Of course, pull-backs do nott always occur, and it is not always possible or feasible to limit purchases to periods of pull- backs. Under such market conditions, Creative tries to invest based on the 4 to 8 month timeframe. During this transition period, the account may not be invested according to the model portfolio, or selected portfolio objective, and may have fewer and less-diversified holdings than would be normally the case in the same portfolio. This does not guarantee a profit and could actually be detrimental to the portfolio growth especially over the short-term. The Allocate Over Time option is available for accounts valued at $50,000 or more. Self-Directed Retirement Management Platform -- Description The firm’s models generally fall into five portfolio objectives based on perceived risk: Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive. Available plan investments are categorized according to the Model guidelines, and overall asset allocation is determined taking those categorizations into effect in arriving at the model portfolio allocations. In the Self- Directed Retirement Management platform, Creative’s investment management staff manages the assets held in clients’ 401k, 403b, 457, or other company retirement plan assets for the individual employee. The Creative Team attempts to build diversified portfolios within the client’s available investment options that can be restrictive in types of investments available. Creative likely has no control over the available individual investment choices within the plan options and will be limited to such limited options when building a client’s portfolio. The firm has developed asset class based model allocations based on research from other professional management models such as Morningstar (formerly Ibbotson), JP Morgan, Goldman Sachs, , Northern Trust, etc. The Self-Directed Retirement Management Strategy attempts to analyze clients’ available investment plan options on a quarterly basis and to perhaps reallocate or rebalance quarterly (or as it sees necessary). Creative uses portfolio management system to review for misallocations or changes needed for an account. Variable Annuity Management Platform -- Description The firm’s models generally fall into five portfolio objectives based on perceived risk: Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive. Available investments are categorized according to the model guidelines and overall asset allocation is determined taking those categorizations into effect in arriving at the model portfolio allocations. Under the Variable Annuity Management platform, Creatives’ Management staff will actively manage within the underlying subaccount options of the clients’ variable annuity contracts/products. The service is not available with respect to all issuers’ variable annuities. Creative likely has no control over the individual investment available within a given variable annuity contract. Portfolios will be built based on the available options and will be limited as a result of the available investment options. Creative manages the investments to build diversified portfolios within a client’s variable contract. Creative has no part in the selection of the product, riders, etc. The firm has developed asset class based model allocations based on research from other professional management models such as Morningstar (formerly Ibbotson), JP Morgan, Goldman Sachs, Blackrock, Northern Trust, etc. Creative takes precautions designed to prevent the benefits of an annuity contract (e.g. income benefits, withdrawal benefits, etc.) from being negatively impacted by the management of the contracts, however, it is up to the client to determine what effects, if any, will apply to a contract based on the management of the contract/product. Creative can perform management services for a variety of variable annuity contracts, including variable annuity contracts that are commissionable. If a commissionable variable annuity contract that is otherwise available for management under this program has paid a commission to cfd Investments, Inc. and/or the investment adviser representative associated with the proposed account, Creative will not provide investment management services with respect to the variable annuity contract within two years of the inception date of the applicable contract. Biblical Faith Values Strategy – Variable Annuity -- Description The Biblical Faith Values Variable Annuity strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a Biblical Responsible Investing (BRI) strategy. Under this strategy, Creative utilizes software and asset screening programs of unaffiliated third parties in order to limit investment in the stock of companies that engage in certain industries or support certain activities or lifestyles, or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered contrary to Biblical standards. Due to a lack of investments in certain management strategies, it is likely not possible to exclude all investments that violate some of the standards that are described above. Also, the avoidance of some industries, lifestyles, companies, etc. are subjective. Additionally, Variable Annuities have limited sub-accounts, and those sub-accounts can change from time-to-time. These limitations can restrict application of this strategy, and this strategy cannot be effectively carried out for any Variable Annuity that does not have a sufficiently diversified selection of sub- accounts that meet the selection criteria. Due to these limitations, this strategy is only available within the Nationwide Monumental Advisor Variable Annuity or upon approval from the Creative Management Team for other such products as the firm selects. Five investment portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ other diversified asset class models. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this Strategy will attempt to substantially reflect Biblical Values, and will otherwise attempt to follow the models established by Creative Financial Designs. Hybrid Strategy -- Description Available in only the Jackson National Life Elite variable annuity, unless approved by Creative’s Management Team to use with other products, the Hybrid variable annuity investment strategy looks to build a diversified portfolio using both alternative type and historical available asset class subaccounts. Five investment portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ other diversified asset class models. Depending on the product and the portfolio objective chosen, Creative’s Management Team determines the amount of each investment type to use, however, focusing on reducing investment portfolio volatility. The goal of the strategy is to reduce the overall portfolio risk using alternative investments along with traditional investments; however, there is no guarantee that this objective will be achieved. Non-Discretionary Advisory Services -- Description Creative provides non-discretionary advisory services to its clients whereby clients may have variable annuity, insurance contract, brokerage or other such account. Such non-discretionary investment advice is provided for a fee charged to the client or contract/account. There are different methods used for the billing of fees, and these differences are dependent upon the issuer of the underlying product. Certain product issuers will collect fees in accordance with their policies and procedures, which may mean that they are billed in arrears, and not in advance, or may be billed other than quarterly, or may relate to average daily balance, or the value at the end or the quarter, etc. These methods are based on the policies and procedures of the underlying product issuer. To the extent that Creative is billing for the fees, fees are billed based on end of the calendar quarter values and in advance. In certain instances, fees may be charged to the contract/account, to the client directly, through another managed account if allowed, via a bank or credit card all at the client’s option. Charging fees to a contract may negatively affect certain benefits/riders of a given contract, and it is up to the client to determine what effects, if any, the payment method selected by the client will affect the contract/product. As this is a non-discretionary advisory service, all transactions are directed by the client. Conditions for Managing Accounts Creative may make exceptions to the minimum account size requirements in some instances. Those exceptions may be made for a variety client-specific reasons, which may include, but are not limited to such situations as a client having multiple managed accounts with the firm, an anticipation of the client adding additional assets at a future point in time, or such other circumstances as the firm may deem applicable. For the managed Self-Directed and Variable Annuity investment management programs, the investment options are limited based on factors beyond the control of Creative Financial Designs, and the management of those accounts is strictly limited to the investment options available under the products being managed. The fees charged by Creative for the Account is in addition to the fees charged by the underlying investments, product fees, account fees, any custodial fees, etc. To the extent that a client intends to restrict Creative from selling particular investments for an extended period of time, regardless of whether the asset is deposited into the account or purchased into the account, it may be more economical for the client to hold the investment in a non-managed account. Clients are advised that holding such restricted assets in the Account will result in an obligation to pay management fees, transaction fees and custodial fees, as applicable. In addition, no fee adjustments are made during any calendar quarter for appreciation or depreciation in the value of the Account. Additional fees may, however, be assessed if cumulative deposits during a quarter equals or exceeds 10% of account value, and, a refund of fees will occur if a withdrawal equals or exceeds 10% of account value. Clients are advised that they may be able to purchase similar services separately from other service providers and the cost of such services may be more or less than the program fee charged by Creative. Financial Planning Services Creative offers financial planning and consulting services. Creative provides Comprehensive Financial Planning services and Modular Financial Planning services. Comprehensive Financial Planning includes in-depth fact-finding interviews that are conducted and clients may elect to receive advice and/or services on a variety of topics other than securities (e.g. budget analysis, etc.). The purpose of this approach is to address a client's entire financial picture, rather than just one or a few select items. Clients desiring a less comprehensive financial plan can choose to have a "Mini" or "Modular" Plan created for them. It may consist of one or more of the following services: Estate Analysis, Medicaid Planning, Government Benefit Planning, Business Financial Plan, Investment Analysis, Tax Analysis, Income Funding Analysis, Insurance Analysis, Education Funding Analysis, Retirement Analysis, Accumulation Funding Analysis, Budget Construction/Analysis, Credit Negotiation, and Special Project Work. Advisory services can also be provided on an Ad-hoc or ongoing basis, and can be paid through an hourly fee, or through a retainer fee arrangement. Creative may provide advice regarding particular investments and securities, and these may include investments currently owned by the client, or investments that the firm or its Affiliates may have recommended to a client. The client is under no obligation to effect securities or insurance transactions through Creative’s affiliates or related persons if they choose to act on or otherwise implement any recommendations made in either a Comprehensive Financial Plan or other Modular Plan.