Overview of the Bradford Financial Center The Bradford Financial Center, LC (BFC) is an independent financial planning firms with its primary office located in Clarion, Iowa. BFC, under its current and previous business names, has been in business since 1970. BFC is wholly owned by James W. Tausz, who is also the Chief Executive Officer, Chief Financial Officer and Chief Compliance Officer of BFC. Directly and through its affiliates and other companies, BFC strives to meet its clients’ varied financial needs. BFC is an investment advisory firm that is registered with the Securities and Exchange Commission and provides services in its home state of Iowa as well as a number of other states in which it has provided the state with proper notice or in which it such requirements do not apply. BFC directly provides the following services to its investment advisory clients: Financial Planning BFC provides comprehensive financial planning services in which it provides analysis and recommendations to you in one or more of the following areas:
• business planning (may include some or all of the following): o business structure, o retirement plans, o general business planning,
• estate planning,
• tax planning,
• retirement planning,
• children’s education funding,
• pension analysis,
• deferred compensation analysis,
• estate analysis,
• conservation planning,
• specialized financial objectives, and
• life and health insurance planning. BFC’s professional staff carefully reviews your confidential data questionnaire and other documents you provide and prepares a written report that, among other things, provides you with specific recommendations of actions for you to take. Implementing the recommendations requires that you working closely with your attorney, accountant, insurance agent, and stockbroker. However, whether or not to implement our recommendations is exclusively your decision. Your financial plan and related report(s) will generally include: 1. A general discussion of the impact of taxes and inflation upon your ability to accumulate assets and attain financial security both now and in the future. 2. A summary of the assumptions that we use in preparing the financial plan and/or estate analysis. 3. A detailed discussion of your objectives and personal risk attitudes. 4. Our recommendations to you that are designed to help you attain your objectives and additional steps that you should consider as you work toward achieving financial security. Just as every client is unique, every financial plan is unique and your plan will cover those areas that are most applicable to you or that you specifically request. As of March 28, 2022 BFC managed $207.5 million in discretionary accounts and no assets in non- discretionary accounts. Watch and Manage Service BFC provides the Watch and Manage service, in which it manages your investment portfolio(s) in a manner appropriate to your investment objectives and risk tolerance levels. An Investment Advisory contract is signed which allows BFC to move your assets from an investment position to the money market when conditions warrant the move. When deemed appropriate, BFC will move your money from the money market back to an investment position. Each investment is followed and managed by sector and individually by Bradford's Watch and Manage system. The Watch and Manage service is also available for switching between the subaccounts of a variable annuity. This only applies to contracts sold more than five years ago. Watch and Manage determines a security's placement by use of a computer program. The program is designed to react to in and out market trend indicators and signals. Once a "move" signal is identified, current news regarding the security is gathered and researched before making a final move decision. If, after research, a move is postponed, the security will remain on a "special watch list" until a clear "in" or "out" sign has been realized. After a security has been moved from its investment position to the money market, the money is not necessarily reinvested in the account's original position. For example, you may have had your money invested in "Security A" and the position is sold and moved to money market due to the negative market trend of this stock. For example, if the management program identifies "Security A's" short and long term market outlook as being weak, BFC will then determine if there is a better opportunity in reinvesting the "Security A" position into a position with more positive short and long term potential, such as "Security B.” The Watch and Manage Service may help you protect your portfolio in a down market and increase your earnings in an up market. Even so, you should be aware that we cannot provide an assurance that our management service can protect against loss or guarantee a profit. Important Information about the Watch and Manage Service
• If BFC believes that the market dictates a change to your portfolio holdings, BFC may sell your positions under the Watch and Manage Service and transfer the resulting cash balances into cash or cash equivalents.
• BFC will only recommend the sale and purchase of securities in your account if it believes your investment or personal objectives can be better served.
• All transactions will be at the custodian/broker-dealers transaction charges applicable to your account and no commissions will be paid BFC or your investment adviser representative.
• If your account is not a retirement plan such as an IRA or profit sharing, pension, 401K or other tax deferred plan, you will incur long or short-term tax liabilities on any realized net profits that will reduce the net after-tax return of your account.
• When repurchasing sold securities, BFC takes into consideration the objective of the original investment.
• Should you wish to exchange the base investment, your risk may increase, decrease, or remain about the same depending on the new security position you choose.
• While Watch and Manage attempts to protect the original (base) investment from individual security and general market declines, BFC cannot guarantee this objective will be met.
• While Watch and Manage strives to enhance the possibility of profits in an ever-changing market and to secure and protect profits already made in a security position, BFC cannot guarantee that any profits will be made.
• Material facts on which BFC based a recommendation to liquidate your original investment are available upon request.
• Material facts concerning a new investment will be provided when requested. Additionally, a prospectus will be provided to you for each applicable investment by the broker/custodian or, in the case of accounts held through United Planners Financial Services of America (United Planners), your BFC Investment Advisor Representative.
• Should a Client request a completely new security any cost to transfer may need to be covered by the Investor. These costs must be identified by the Advisor before making a new purchase. Clients may provide reasonable restrictions and guidelines to BFC with respect to the management of the Client’s account. Restrictions and guidelines imposed by the client may affect the composition and performance of custom portfolios. Watch and Manage and 401k accounts BFC also provides the Watch and Manage service for certain 401k accounts held in custody at TD Ameritrade. The Plan Sponsor and/or Responsible Plan Fiduciary are responsible for the selection of the third-party administrator and the account custodian. BFC provides the following services with respect to 401k plans:
• Assists in the selection and ongoing review of plan’s investments based on the

needs and demographic profile of the company,
• Conducts enrollment meetings to encourage plan participation,
• Organizes ongoing educational sessions as needed, and
• Helps employees make informed investment decisions. SEI Asset Management Program Additionally, BFC IARs manage client portfolios through the SEI Asset Management Program (the "Program") sponsored by SEI Investments Management Corporation ("SIMC"). In this program, SIMC provides advisory services to BFC (but not to the client) involving the structure and design of asset allocation portfolios typically comprised solely of mutual funds advised by SIMC. SIMC also advises BFC with respect to reallocation and rebalancing of investments within such asset allocation programs. The Program is designed as follows: 1. Determine the investor's risk profile and investment objectives. The BFC IAR determines the investor's investment objectives, investment time horizon, and risk profile by means of an interview process and the completion of a questionnaire. This process will help the BFC IAR review the client's situation and enable the IAR to recommend an initial asset allocation based on the client's specific needs and goals. 2. Set a relevant asset allocation policy for the investor. The investor chooses one of many mutual fund asset allocation models. The investor may also purchase the individual mutual funds without choosing one of the asset allocation models. If the investor so chooses, automatic rebalancing to model allocation and recommended model allocation changes will not be available. The BFC IAR will, if appropriate, suggest modifications to these models to more adequately address the client's individual needs. The client may place reasonable restrictions on the nature of the funds held in the portfolio or the allocation among the various classes, and the IAR will assist the client in understanding and evaluating the potential impact of these restrictions on the model portfolios. 3. Diversify among asset classes and styles. The investment managers of the underlying mutual funds are selected by SIMC. SIMC utilizes institutional investment management firms. The managers are monitored by SIMC to ensure that their investment styles and performance remain consistent with the objectives of the mutual funds. 4. Rebalance the investor's portfolio. Rebalancing maintains the proper allocation to each asset class in the model. Rebalancing occurs automatically if the underlying mutual funds deviate from the prescribed quarterly allocation by greater than a specified variance. Rebalancing occurs quarterly with no transaction fees. 5. Report results. SEI Private Trust Company (a subsidiary of SEI Investments Company) acts as the transfer agent and custodian for the investor's account. SEI Private Trust Company provides reporting services including consolidated quarterly statements, quarterly performance reports, and year-end tax reports. Accounts will be monitored quarterly and, when appropriate, BFC will suggest a reallocation of the portfolio based on changing economic conditions or changes in the client's individual circumstances. BFC will manage advisory accounts on a nondiscretionary basis. As economic or market changes occur, SIMC will make a quarterly review of its model allocations and may recommend changes in these model allocations to BFC. SIMC will automatically reallocate all client holdings in model portfolios unless instructed to do otherwise by BFC. SIMC will not make any ongoing recommendations concerning portfolios which deviate from SIMC's models ("custom portfolios"); BFC is responsible for all reviews and must instruct SIMC to make any changes to such portfolios. Should the client's individual situation change, the client should notify their BFC IAR, who will assist the client in revising the current portfolio and/or reevaluate their financial situation to determine if a different model portfolio would be appropriate to the client's new situation. For more complete information concerning the SEI Program including, among other things, services and fees, please refer to the SEI Program disclosure brochure and the SEI Program Client Agreement, which is provided separately by BFC to the Client. Third-Party Investment Advisor Referral Services BFC may enter into agreements with various third-party investment advisors (TPIAs) for the management of client accounts. Under these agreements, BFC will offer clients various types of advisory programs sponsored by these advisors. All TPIAs to whom BFC will refer clients will be licensed as investment advisors in the client’s home state, registered as investment advisors with the Securities and Exchange Commission (SEC) or otherwise exempt from such licensing or registration. BFC does not accept discretionary authority to select TPIAs or TPIA programs without obtaining specific client consent. After gathering information about a client’s financial situation and investment objectives, BFC may recommend specific services or programs of TPIAs to clients that are suitable and appropriate for the client based on the clients’ individual needs and circumstances, including investment objectives and risk tolerance levels, as they have made them known to BFC. Factors that BFC takes into consideration when making such recommendations include, but are not limited to, the TPIA’s performance, methods of analysis and fees. BFC periodically reviews the TPIA and its performance for continued consistency with the client’s investment objectives and risk tolerances. At the time of the referral, clients who are referred to TPIAs will receive the respective TPIA’s Form ADV Part 2 disclosure brochure and/or other relevant disclosure documents. These documents are designed to, among other things; provide complete disclosure of the TPIA, including services rendered, frequency of billing, fee schedules, the compensation to be paid to BFC as a result of the referral and whether the client may impose restrictions on investing in certain securities or types of securities. Please see Item 5 below for additional information concerning BFC’s TPIA program. Consulting Services for Appreciated Property BFC provides custom benefit designs and approaches to structured sales of businesses, stocks, real estate, and other appreciated property with a focus on saving income and estate taxes. BFC may recommend one or more strategies that are designed to accomplish these objectives including, but not limited to:
• Structured Settlements,
• Deferred Sale Trust (DST),
• Private Annuity Trust (PAT),
• 1031 Exchanges, and
• Other specialty tax planning strategies. Fiduciary Status 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. Conflict of Interest 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. For example, if you roll over an IRA or 401k account to our firm or otherwise transfer any other account to our firm, we will charge your account and make money. If you decide to not roll over the IRA or other account to our program, we will not make money. While we therefore have a financial incentive to recommend that you to move your account to our program, we have established policies and procedures that are designed to address this conflict between our interests and yours and ensure that all recommendations made to you are in your best interest. Assets Under Management As of December 31, 2023, BFC had $209.761 million in assets under management, all on a discretionary basis.