Disclosures & Policies – CFD Investments, Inc.

In the course of doing business with cfd Investments, Inc. or Creative Financial Designs, Inc., you share personal and financial information with us. We treat this information as confidential and recognize the importance of protecting access to it.

You may provide information when communicating with us in writing, electronically, or by phone. For instance, information may come from your applications, your requests for forms or literature, or your transactions with us. On occasion, such information may come from consumer reporting agencies and those providing services to us.

We do not sell information about our clients (whether current or former) to third parties. We do not disclose this information concerning clients or former clients to third parties unless it is necessary to process a transaction, service an account, or as may otherwise be legally permitted or required.

We maintain physical, electronic and procedural safeguards to protect information about our clients. Access to such information is limited to those who need it to perform their jobs, such as servicing your accounts or resolving problems or to inform you of products or services. Our Compliance Manual as well as our contracts with employees and agents restricts the use of your nonpublic personal information to those who need it to perform their jobs, such as servicing your accounts or resolving problems, and require that it be held in strict confidence.

We may share information between our two companies (Creative Financial Designs, Inc. and cfd Investments, Inc.) in the course of providing or offering products and services to best meet your investing needs. We may also share that information with companies performing administrative or marketing services for either company or with a business partner with whom we are developing or offering investment products. However, use of information about our clients in such cases is severely restricted – the other party is prohibited from sharing or using it for any other purpose.

Finally, we may share your information with another broker/dealer in order to assist in the timely transition of your account in the event that your financial adviser leaves us and becomes associated with another securities firm. If you would prefer that we not disclose your information in that circumstance, please let us know by writing to us, addressed to cfd Investments, Inc., 2704 South Goyer Road, Kokomo, IN 46902, Attn: Chief Compliance Officer. You can also call us at 800.745.7776.

These disclosures are updated periodically on our website at www.cfdinvestments.com.

CLIENT AUTHORIZATION: By authorizing CFD to submit information and materials to you, the Client, through electronic delivery, you agree to and acknowledge these Terms of Service. This document outlines the policy and procedures of cfd Investments, Inc. and Creative Financial Designs, Inc. (hereinafter, collectively referred to as “CFD”) when you have authorized CFD to provide information through electronic delivery. Your authorization includes the email address that will initially be used by you for receipt of CFD documentation. You may change the email address and/or update email preferences at any time, or may terminate the authorization through written communication to your Financial Professional or to CFD, by accessing www.cfdinvestments.com or sending correspondence to:

CFD
2704 South Goyer Road
Kokomo, IN 46902

SECURITIES REGULATIONS: Securities regulations permit electronic delivery of documentary information by CFD to a Client upon the Client’s agreement; that access is substantially equivalent to paper delivery. This means that electronic delivery via email should not be unduly burdensome for any Client. If the documents are in PDF or other formatted versions, CFD must inform the Client of the requirements necessary to download PDF files, or provide means to download. Some securities issuers electronically publish their materials in Portable Document Format (PDF). In order to view PDF documents, you must have Adobe Acrobat Reader software. This reader is available for download, free of charge, from www.adobe.com.

HARDWARE AND SOFTWARE REQUIRED TO USE THE SERVICE: CFD’s electronic delivery service requires that you provide to CFD a valid email address through which the messages will be sent. You must have a personal computer or other electronic device through which you can access email, and must have available software necessary for that purpose. CFD is not responsible for the hardware or software you need to access the emails sent by CFD.

Should you wish to print materials that have been delivered electronically, you must have access to print.

FAILURE OF EMAIL ADDRESS: If, during a distribution, your email address is identified to CFD as being invalid, electronic delivery service will be suspended and you will receive a paper copy of the communication. An invalid email address will not invalidate, terminate or suspend your authorization of electronic delivery, however the delivery service will be suspended pending you provide an alternative email address to CFD. This can be done by communicating with your Financial Professional or reaching out to the home office directly with a new email address.

OPTION TO RECEIVE HARD COPY: If you would like to receive a printed set of the documentary material, in addition to email notification, you may request a paper copy from CFD.

DISCLOSURE: CFD does not accept orders and/or instructions regarding any securities by email, voice mail, fax or any electronic means of communication. Transactional details do not supersede normal trade confirmations or statements. Email sent through the internet is not secure or confidential.

All electronic deliveries are intended only for the persons or entities to which it is addressed and may contain confidential and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is prohibited.

CFD will endeavor to send all such materials via encryption, when any confidential client information is being disseminated through use of this system. In acknowledging these terms and conditions, Client also attests that he/she has the capability to review information in this format, and understands the technological requirements for doing so, as identified above. The Client further recognizes that CFD will take steps to ensure confidentiality of this information, but that a breach on Client’s electronic device or email account may result in a breach of confidential information. A breach of Client customer data as a result of Client’s equipment or email account is not the responsibility of CFD.

These disclosures are updated periodically on our website at www.cfdinvestments.com.

The Financial Industry Regulatory Authority, Inc. (FINRA) requires member firms such as cfd Investments, Inc., to implement plans for the continuation of business in the event of a significant business disruption (SBD). A SBD refers to local or regional events such as natural disasters, fires, and power outages, acts of malice or terrorism, and technical infrastructure disruptions.

In accordance with FINRA’s rules, cfd Investments, Inc. has developed and implemented a Business Continuity Plan (BCP). Among other steps, we have created secondary business locations as back-ups to our normal business location and have arranged for back-up electronic storage of certain firm records. We have also arranged for alternative communication resources for both our internal associates and our external customers, financial advisers, and vendor partners.

The purpose of our Firm’s BCP is to ensure that we are able to continue our business activities and continue serving our financial advisers and our customers with the least possible impact in the event of any of the disruptive events described above actually occurring or in the case of other unforeseen circumstances.

Upon request, we will provide additional information about cfd Investments, Inc.’s BCP. Please contact us at 1-800-745-7776 if you have any questions.

Platinum¹

Corebridge Financial
Ash
Fidelity Investments (NFS)
Nationwide
Timothy Plan
Jackson

Gold²

Annexus
Eventide
Inspire

Silver³

Athene
Lincoln Financial
Prudential
GuideStone Funds
Tarkenton Financial
Sammons Retirement Solutions
Praxis Mutual Funds

Bronze⁴

Capital Group
Catalyst Funds
AssetMark
Brighthouse Financial
GBU Life
Western & Southern Life
Faith Investor Services
Transamerica
Goldman Sachs
Protective
Ave Maria
Alger
First Trust

¹ Platinum sponsors are our top-tier of sponsors, who make a payment in the amount of $25,000 or more annually. This payment may be in the form of a fixed payment, a payment based on the amount of business produced or the amount of assets retained, or a combination of these. The sponsorship provides the sponsor with:

List of Financial Professionals, updated quarterly
Platinum Sponsor one-day event at the home office annually
Booth space at CFD’s Spring and Fall Conference
Guaranteed Speaking time at the Fall Conference
Guaranteed Speaking Time at CFD’s Presidential Adviser’s Trip and Emerging Adviser’s Trip
Invitation to Fall Adviser Dinner
Listing on Corporate Sponsorship Board and Website
Ability to communicate with our financial professionals quarterly through a blast email

²Gold sponsors are among our high-level sponsors, who make a payment in the amount of $15,000 or more annually. This payment may be in the form of a fixed payment, a payment based on the amount of business produced or the amount of assets retained, or a combination of these. The sponsorship provides the sponsor with:

List of Financial Professionals, updated quarterly
Booth space at CFD’s Spring and Fall Conference
Guaranteed Speaking time in optional sessions at the Fall Conference
Guaranteed Speaking Time at CFD’s Presidential Adviser’s Trip and Emerging Adviser’s Trip
Invitation to Fall Adviser Dinner
Listing on Corporate Sponsorship Board and Website
Ability to communicate with our financial professionals quarterly through a blast email

³Silver sponsors are our mid-level sponsors, who make a payment in the amount of $7,500 or more annually. This payment may be in the form of a fixed payment, a payment based on the amount of business produced or the amount of assets retained, or a combination of these. The sponsorship provides the sponsor with:

List of Financial Professionals, updated quarterly
Booth space at CFD’s Spring and Fall Conference
Invitation to Fall Adviser Dinner
Listing on Corporate Sponsorship Board and Website
Ability to communicate with our financial professionals quarterly through a blast email

⁴Bronze sponsors are our mis-level sponsors, who make a payment in the amount of $2,500 or more annually. The sponsorship provides the sponsor with:

List of Financial Professionals, updated semi-annually
Booth space at CFD’s Fall Conference
Listing on Corporate Sponsorship Board and Website
Ability to communicate with our financial professionals semi-annually through a blast email

Conflicts of Interest related to Corporate Sponsorship

The Corporate Sponsorship program is designed to provide income to the firm to pay for events associated with providing education, resources and support to our financial professionals and overall marketing support. This is typically provided through the firm’s many training events and conferences.

Regardless of the method of payment, or the purpose of the funds, the receipt of the funds does create a conflict of interest, in that the firm receives additional income and/or good will from corporate sponsors as the firm makes additional recommendations to use the products or services provided by the corporate sponsors. The firm’s responsibility is to act in the best interest of the client regardless of any such conflict of interest, and has mitigated this conflict in that the recommendations are made at the representative level, and the compensation described herein regarding corporate sponsorship is not shared with financial professionals, though they do receive benefit from that indirectly through the events that they may attend. Regardless, recommendations are not made based on whether the product issuer is a corporate sponsor, but instead are made based on the best interests of the client, given the client’s needs and objectives.

Best Interest

We operate in the best interest of the client, always putting you and your investment objectives first.

FINRA and SEC

The CFD companies are members of both FINRA and SEC.

Client First

We intend to recruit and retain Advisers committed to placing the needs of their clients before their commission needs.

Firm of Integrity

Our key strengths include our commitment to being a firm of integrity regardless of circumstances, our commitment to helping our advisers serve their clients in the manner we would like to be served if we were in their circumstances, and our commitment to placing our mission of helping people achieve their goals and objectives before the commission earned by our Advisers.