Center for Financial Planning Inc.

24800 Denso Drive Suite 300 Southfield, MI 48033 Telephone: (248) 948-7900 Facsimile: (248) 948-1008 www.CenterFinPlan.com Firm Brochure (Part 2A of Form ADV) This Form ADV Part 2A brochure (the “Brochure”) pro vides information about the qualifications and business practices of Center for Financial Planning, Inc. (also referred to herein as “we”, “us”, “The Center” or the “Adviser”). If you have any questions about the contents of this Brochure, please contact Timothy Wyman, Chief Compliance Officer (also referred to as “CCO”) at (248) 948-7900. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Center for Financial Planning, Inc. is available on the SEC website at www.adviserinfo.sec.gov. Center for Financial Planning, Inc. is an SEC registered investment adviser. Registration as an investment adviser does not imply any certain level of skill or training. Effective Date: April 16th, 2026  Item 2: Material Changes Since our last brochure update on March 18, 2025, we have updated our policy of billing on cash balances that are over 20% of the account. The firm no longer bills on cash balance that exceeds 20% of the account when the balance has exceeded that level for two consecutive quarters now instead of three consecutive quarters. See Item 5 for more details. Kali Hassinger has been admitted to partnership as of 01/01/2026. If you have question or if you would like a copy of our Brochure, please contact us at 24800 Denso Drive, Suite 300, Southfield, MI 48033 or by telephone at (248) 948-7900. Page 2  Item 3: Table of Contents Item 4: Advisory Business. ........................................................................................................ 4 Item 5: Fees and Compensation ........................................................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management ................................18 Item 7: Types of Clients ...........................................................................................................18 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss.......................... 18 Item 9: Disciplinary Information ...........................................................................................19 Item 10: Other Financial Industry Activities and Affiliations ............................................20 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .....................................................................................................................20 Item 12: Brokerage Practices.............................................................................................. 21 Item 13: Review of Accounts ................................................................................................22 Item 14: Client Referrals and Other Compensation ........................................................23 Item 15: Custody ..................................................................................................................... 23 Item 16: Investment Discretion .......................................................................................... ..24 Item 17: Voting Client Securities ......................................................................................... 24 Item 18: Financial Information ...........................................................................................24 Page 3  Item 4: Advisory Business Firm Description Center for Financial Planning, Inc. is a C corporation with its principal place of b usiness in Southfield, Michigan. We began conducting financial planning services including managing securities accounts for clients in 1985. We have been registered with the SEC as an investment adviser since January 2006. Our firm’s owners include: Timothy Wyman (owning 25% or greater), Sandra Adams, Nick Defenthaler, Angela Palacios, Matthew Trujillo, Lauren Adams, Kali Hassinger and Michael Brocavich (each owning less than 25%). To describe the individual adviser you choose to work with, we use the following terms interchangeably: “IAR” (Investment Adviser Representative), “Registered Representative,” “Planner”, “Associated Person”, “Adviser”. In turn, we use the terms: “you,” “your,” and “client” to refer to you as either a client or prospective client of our firm. As of February 27, 2026 The Center had the following assets under management of approximately: $ 1,936,327,046 Discretionary $ 33,632,530 Non-Discretionary $ 1,969,959,576 Total Types of Advisory Services Center for Financial Planning, Inc. engages in Financial Planning & Investment Management Services. Clients who elect to retain our firm for these services are charged a fee, which is further explained under the Fees and Compensation section of this Brochure. Assets under our direct management are held independently by Raymond James & Associates (“RJA”), member NYSE/SIPC. We do not act as a custodian of client assets. We place trades for clients under a limited power of attorney when discretionary authority is provided. We maintain relationships with certain affiliates of Raymond James Financial Services, Inc., including Raymond James Financial Services, Inc. (“RJFS”), a broker dealer and member FINRA/SIPC, and Raymond James Bank, N.A. (“RJ Bank”). For purposes of this brochure, Raymond James Advisor (“RJA”), RJFS, and RJ Bank are collectively referred to as “Raymond James.” Financial Planning Services Our financial planning services include matters such as: goal planning, taxation analysis, retirement and college planning, investment analysis, charitable planning, estate planning, longevity planning, cash flow analysis and insurance analysis. An evaluation of each client's initial situation is provided verbally and/or via written observations and recommendations. Clients that chose to retain The Adviser in subsequent years are provided ongoing advice via meetings, phone calls or electronic communications. The financial plan addresses a wide range of topics tailored to the client’s circumstances, which may include, but are not limited to, a net worth statement; a cash flow statement; an evaluation of investment accounts and asset allocation with related repositioning recommendations; strategic tax planning; a review of retirement accounts and employer-sponsored plans with accompanying recommendations; an assessment of insurance coverage; one or more retirement projections; estate planning observations and recommendations; longevity planning; and education funding recommendations. Implementation of any financial planning recommendations remains solely at the discretion of the client. Page 4  Investment Management Services We provide on-going advice to the Client regarding investment of Client funds based on the individual needs of the Client. After reviewing their financial plan, investment experience, risk tolerance and other relevant issues, we assign an asset allocation. Adviser will manage advisory accounts on a discretionary (limited power of attorney to execute transactions) and/or non-discretionary basis. Account management is guided by the stated objectives of the Client (i.e., capital appreciation, income, growth, preservation or speculation). Clients may impose restrictions on investing in certain types of securities or from selling certain holdings. We incorporate these holdings into the asset allocation (or hold outside of the allocation) to facilitate overall planning and investment management services. In certain situations, we offer to our clients a number of Raymond James Consulting Services (RJCS) managed wrap programs, including Freedom and RJCS Managed Programs under a sub advisory agreement with RJA. Our advisers work with our clients to choose an appropriate program and help the client to select the managers, strategies, or disciplines within the programs, as applicable. We will regularly monitor the management of such accounts. Client would sign additional agreements related to any such account that would include a description of any fees to be paid related to these accounts. Both RJA (and its affiliates and agents, and other sub advisers, as applicable) and Center for Financial Planning, Inc. receives a portion of the advisory fee paid by the client (as described below). Tailored Relationships Our advisory services are tailored to the individual needs of clients. Client goals and objectives are clarified in meetings, telephone calls, and correspondence, and are used to determine the course of action for each individual client. The goals and objectives are documented in a variety of manners such as our client relationship management system, financial planning software, and client files, either hard copy or electronic. Clients have the option to impose restrictions on investing in certain securities or types of securities. Agreements cannot be assigned without written client consent. Determining Suitability In establishing a new client relationship, The Center will obtain the following investment parameters about the prospective client(s) and record such information on a suitability questionnaire: 1. Birth year and employment status, including occupation; 2. Investment objectives; 3. Level of the client's risk tolerance; 4. Time horizon; 5. Income and net worth, excluding the value of primary residence; Each Associated Person, prior to rendering investment advice to a client, must ensure that their advice is suitable, considering that client’s investment parameters. The Associated Person should, at a minimum, base that recommendation on the most current information available to the Company regarding the client’s investment parameters. Contact will be made on a periodic basis (at intervals not greater than 36 months) to update the suitability information provided by each client. Page 5  Regulation Best Interest (Reg. BI) The best interest standard explicitly applies to recommendations of types of accounts. An Associated Person must have a reasonable basis to believe that a recommendation of a securities account type (e.g., brokerage or advisory, or among the types of accounts offered including IRAs) is in your best interest at the time of the recommendation and does not place the financial or other interests of The Center or the Associated Person ahead of your interest. In general, when considering recommendations of types of accounts, The Center takes into consideration: (a) services and products provided in the account; (b) projected cost of the account; (c) alternative account types available; (d) financial planning services you request; and (e) your investment profile With regard to IRAs, in addition to the factors above, The Center takes into consideration: fees and expenses; level of services available; (a) (b) (c) ability to take penalty-free withdrawals; (d) application of required minimum distributions; (e) protections from creditors, scams and legal judgments; (f) holdings of employer stock; and (g) any special features of the existing account When we provide investment advice to you regarding your retirement plan account or IRA, we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours (Reg. BI). The Center and your IAR have a financial incentive for you to rollover to an IRA because of the compensation we receive when you transfer funds from an employer- sponsored retirement plan or from another IRA. If you decide to open a brokerage or advisory account, we will be paid on those assets, through commissions or advisory fees. You should be aware that any commissions or advisory fees charged will be higher than those fees you paid through your employer- sponsored retirement plan, and there could be additional expenses associated with the account. Please refer to Item 5 (Fees and Compensation) below. Conflicts of Interest We must be sensitive to various conflicts of interest that arise when selecting programs, account types (i.e., brokerage vs. fee-based advisory accounts), and broker-dealers to execute client trades. Conflicts of interest can arise when rendering financial planning advice such as determining if a mortgage should be paid off or claiming social security sooner or later as this can affect the asset balance we are compensated on through commissions or advisory fees. Moreover, The Center and its Associated Persons must have a reasonable basis for determining or recommending an investment transaction or an investment strategy. Prior to implementing transactions, selecting a program, or making a recommendation, each Associated Person must: • Review and understand the client’s financial situation, objectives, and risk tolerance; • Follow an investment strategy with respect to that client, which is approved by The Center and that is appropriate for the client in light of the information obtained; • Communicate to the client the basis for the recommendations; and • For “non-discretionary” accounts, obtain the client’s specific consent Page 6  the CCO/CCO delegate will work directly with Recommendations made by Associated Persons will be periodically reviewed by the CCO or CCO delegate to ensure that such recommendations are consistent with the best interests and/or instructions of the client. If any inconsistencies are noted, the Associated Person to determine whether there was an oversight, mistake, or reason for the particular recommendation or action in the client’s account. If remedial action is necessary, the CCO will ensure that appropriate documentation of any remedial action taken is noted in the client file and the Associated Person’s personnel file as applicable. Wrap Fee Programs A wrap fee program combines asset management, advisory services, and trade execution for a single fee. We do not sponsor or manage any wrap fee programs. Please see Item 5 below for information regarding additional fees and Item 12 below for further information on brokerage practices, fees, and transaction costs. Clients should note that recommended third party programs may be offered as wrap fee programs. For detailed information regarding these programs, please carefully review the disclosure documents provided by the relevant third-party sponsor/manager of such third-party programs. Item 5: Fees and Compensation Financial Planning Services Fees Financial Planning Fees are charged or waived depending on the client situation. The exact fee is determined on a client-by-client basis and is dependent on the nature and complexity of each circumstance. These fees are mutually agreed upon in advance of entering into an agreement between Adviser and client. Fees are not based on the capital gains or appreciation of an investment account. Payment for services is expected at the time the investment adviser representative delivers the written plan or upon completion of the service (in person, via regular mail, email, or other transmission). Though not required, clients will have an option to pay in advance. Under no circumstances will The Center earn fees in excess of $1,200 more than six months in advance of services rendered. In the event the fees have been pre-paid and either party terminates the contract, such fees will be pro-rated based upon the number of days contract was in effect and any unused fee will be refunded. Planning Fee: Clients are charged a fixed fee (commonly ranging from $2,500 to $4,000) for our Financial Planning advice, which is generally based on the amount of time required by the advisory team in the design of your financial plan. The fee for a financial plan is predicated or waived upon the facts known at the start of the engagement. Clients will be billed directly for fees incurred. Page 7  Investment Advisory Services Fees Ambassador Account: Managed by the Adviser The Ambassador Account is an investment advisory account, administered by RJA, which offers clients, on a discretionary or non-discretionary basis, the ability to pay an advisory fee based on the assets in their account in lieu of a commission or sales charge for each transaction. The fees for Ambassador Accounts are as follows: QUARTERLY FEE ANNUALIZED FEE ACCOUNT VALUE First $500,000 Next $1,500,000 ($500,000-1,999,999) Next $2,000,000 ($2,000,000-3,999,999) Next $1,000,000 ($4,000,000-4,999,999) Next $5,000,000 ($5,000,000-9,999,999) Next $5,000,000 ($10,000,000-14,999,999) Amounts over $15,000,000 .30% .225% .20% .15% .125% .10% .075% 1.20% 0.90% 0.80% 0.60% 0.50% 0.40% 0.30% Current client relationships exist where the fees are higher or lower than the Current Fee Schedule above. The Adviser, in its sole discretion, can charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). If either of the below programs are selected by the client, RJA is appointed as a discretionary investment adviser under the appropriate advisory agreement. In this way, RJA acts as a sub adviser directly (or indirectly through other sub advisors) managing client’s assets through the selected program. RJA also monitors performance of the account, provides accounting and other administrative services, and may assist portfolio managers with certain trading activities. Based upon client financial needs and investment objectives, the IAR will assist in selecting and monitoring an appropriate manager(s). The Center receives a portion of the fee. Raymond James Consulting Services (RJCS) Program: Managed by Others The RJCS program is a wrap-fee program. The RJCS’s annual management fee is negotiable with each client up to 3%. We will provide the percentage-based fee to each client based on both the nature and total dollar asset value of that account(s). The fee will be stated in the fee schedule which must be signed by both The Center and the client. Additionally, the RJCS fee covers RJA’s advisory services, and the trade execution fees charged by the broker/dealer. Freedom Account: Managed by Others The Freedom Account is an investment advisory account which allocates your assets, through discretionary mutual fund or exchange traded fund (“ETF”) management, based upon your financial objectives and risk tolerances. Page 8  The Freedom Account is a wrap-fee program. The Freedom Account’s annual management fee is negotiable with each client up to 3%. We will provide the percentage-based fee to each client based on both the nature and total dollar asset value of that account(s). The fee will be stated in the fee schedule which must be signed by both The Center and the client. Additionally, the Freedom Account’s management fee covers RJA’s advisory services, and the trade execution fees charged by the broker/dealer. A conflict of interest must be noted. We are able to keep a larger percentage of the fees charged for the Ambassador Account; therefore, we have a financial incentive for recommending the Ambassador account over other advisory programs. For further information, refer to the RJA Wrap Fee Program Brochure. The Brochure can be accessed through this link: https://www.raymondjames.com/-/media/rj/dotcom/files/legal-disclosures/rja-wrap-fee-program.pdf. Please read it thoroughly before investing. Client will be required to execute the applicable Raymond James Account Agreement that provides further details. Calculation of fees Fees for client accounts are calculated and billed in advance of each period (quarterly). When an account is opened, the fee is billed for the remainder of the current billing period and is based on the initial contribution. Thereafter, the quarterly fee is paid in advance, is based on the account asset value as of the last business day of the previous calendar quarter and becomes due the following business day. Billing account asset value may differ from the value provided on the account statement provided by the custodian. Margin or debit balances are not subtracted from account value as an example. If cash or securities, or a combination thereof, amounting to at least $100,000, are deposited to or withdrawn from your account on an individual business day in the first two months of the quarter, Raymond James Financial Services, Inc. (“RJFS”), is a member FINRA/SIPC will: (i) assess asset-based fees based on the value of the assets on the date of deposit for the pro rata number of days remaining in the quarter, or (ii) refund prepaid asset- based fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the quarter. No additional asset-based fees or adjustments to previously assessed asset-based fees will be made in connection with deposits or withdrawals that occur during the last month of the quarter unless requested by you. Our clients authorize and direct RJA, as custodian, to deduct asset-based fees from the client's account. Our clients’ brokerage statements will show the amount of the asset-based fee, the value of the assets on which the fee was based, and the specific manner in which the fee was calculated. While we have designed reasonable controls to monitor for the accuracy of advisory fees, it is your responsibility to verify accuracy of your fees, including the advisory fee rate applied to your account(s). If client desires to pay asset-based fees directly they can opt to be billed for these fees. We have retained and will compensate RJA to provide various administrative services, which include producing a monthly account statement for detailing account assets, account transactions, receipt and disbursement of funds, interest and dividends received and account gain or loss reporting for the total account. Additional expenses not included in the Asset-based fees In addition to The Center’s advisory fees, our clients may incur charges for other account services provided by RJA not directly related to the execution and clearing of transactions. These include, but are not limited to: Page 9  • • • • • IRA custodial fees Safekeeping fees Interest charges on margin loans or security-based lending (SBL) loans Fees for legal or courtesy transfers of securities Transaction fee collected to recoup fees paid by Raymond James to an exchange or self- regulatory organization in connection with the sale of certain securities, such as equities, options, and other ee varies and is determined periodically by the covered securities. The amount of the f • exchange or self-regulatory organization that assessed the transaction fee in accordance with Section 31 under the Securities Exchange Act of 1934 (The Center does not receive any portion of this fee). Short term redemption fees are imposed by certain funds if the shares are not held for a specified time, or may block purchases or exchanges for a specific time frame following a redemption. (The Center does not receive any portion of this fee). Transfer or Foreign taxes • Certain dealer-markups • Odd lot differentials • • Offering concessions and related fees for purchases of public offerings of securities as more fully disclosed in the prospectus. The Client should review all fees charged by the Center, mutual funds, brokers, and custodians to fully understand the total amount of fees to be paid by the Client. For a complete list of account service charges charged by Raymond James, visit the public website: https://www.raymondjames.com/ client-resources/client-account-fees-and-charges Additional Disclosures regarding AMBASSADOR Accounts: Administrative-Only Assets Certain securities are held in Ambassador Accounts and designated as “Administrative-Only Investments.” There are two primary categories of Administrative-Only Investments: Client- designated and Raymond James-designated (also referred to as “RJ-designated”). Client-designated Administrative- Only Investments are designated by IAR(s) that do not wish to collect an advisory fee on certain assets, while RJ-designated Administrative-Only Investments are designated by custodian (per firm policies). Administrative-Only Investments will not be included in a client’s account value when calculating applicable asset-based advisory fee rates. For example, a client’s Ambassador account holds $750,000 of cash and securities that includes $150,000 of Administrative-Only Investments will only have the asset-based fee rate assessed based on a $600,000 account value. Please Note: The designation of Client-designated Administrative-Only Investments and the maintenance of such positions in the client’s account are not permissible in Ambassador retirement accounts (such as IRAs and employer sponsored retirement plans). Adviser has elected to preserve the ability for clients to designate assets as Client-designated Administrative-Only in their taxable and non- discretionary Ambassador retirement accounts in order to maintain client choice and avoid the need to maintain a separate account to hold these securities or cash. Page 10  Asset-based Fee Aggregation Clients can be entitled to discounted asset-based fees if they maintain one or more eligible “Related Accounts.” Related Accounts are accounts of an individual, his or her spouse, and their children under the age of 21. The term includes individually owned accounts, individual retirement accounts (IRAs), self- directed accounts (i.e., directed by individual participants) under an employee benefit plan (ERISA plan) and ERISA plan accounts in which an individual is the sole participant. Thus, Related Accounts are aggregated for advisory fee purposes, so that each account will pay a fee that is calculated based on the total of all Related Accounts. It is the client’s responsibility to identify all Related Accounts for purposes of qualifying for an aggregated account fee discount. While we attempt to identify related accounts, we will not be responsible for failing to consider any related accounts not listed by you. Billing on Cash Balances The Center will assess advisory fees on cash sweep balances (“cash”) held in Ambassador accounts, provided the cash balance does not exceed 20% of the total account value. If the cash balance is greater than 20% of the account value as of the last business day of the quarter (the “valuation date”), we will bill on the full cash balance provided cash did not comprise greater than 20% of the billable Account Value for two (2) consecutive quarterly valuation dates. If the cash balance exceeded 20% of the Account Value for two (2) consecutive quarterly valuation dates, the amount in excess of 20% is excluded from billing. For example, an Ambassador account that held 30% of the Account Value for two (2) consecutive billing valuation dates (March 31st and June 30th) would have the amount in excess of 20% excluded from the account value in which advisory fees are applied. For simplicity of illustration, assuming an a ccount was valued at $100,000 for all two (2) quarterly billing periods, with $30,000 held in cash, the June 30th valuation date would exclude $10,000 of the cash from the Account Value when assessing the advisory fee. Clients should understand that the portion of the account held in cash will experience negative performance if the applicable advisory fee charged is higher than the return received on the cash sweep balance. For Ambassador accounts, this fee billing provision (or “Cash Rule”) poses a financial disincentive to the Adviser, as the portion of cash sweep balances more than 20% for long enough as outlined above will be excluded from the asset-based fee charged to the account. The Adviser has a conflict of interest in reallocating a client account from cash to advisory fee eligible investments, including money market funds, or to recommend against raising cash, in order to avoid the application of this provision and therefore receive a fee on the full account value. Clients that have delegated investment discretion to the Adviser can direct the Adviser to raise cash by selling investments or hold a predetermined percentage of their account in cash at any time. The Cash Rule is applicable only to cash sweep balances and, therefore, non-sweep money market funds would not result in excess “cash” balances being excluded from the asset based advisory fee calculation. Cash balances are generally expected to be a small percentage of the overall account value in the Freedom and RJCS accounts and therefore these accounts are not subject to the Cash Rule. Page 11  Mutual Fund and ETF considerations Advice offered by the Center involves investments in mutual funds and ETFs. Clients hereby advised that all fees paid to The Center for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds (as described in each fund's prospectus) to their shareholders. There may be transaction charges involved when purchasing or selling securities. The Center does not share in any portion of the brokerage fees/ transaction charges imposed by RJFS. Certain open-end mutual funds, in addition to assessing fee for management and fund administrative services, internally assess a distribution fee pursuant to section 12(b)-1 of the Investment Company Act of 1940, or an administrative or service fee ("trail"). Such fees are included in the calculation of operating expenses of a mutual fund and are disclosed in the fund prospectus. Where 12b-1 share classes are used, Adviser does not receive any 12b-1 fees during the period the asset(s) are held within the Ambassador/Freedom/RJCS account structure. 12b-1 fees are credited bi-monthly to the client’s accounts, after they are received by Raymond James. However, 12b-1 fees received by Raymond James on share classes that are not subject to the advisory fee, such as Class C shares designated as Administrative-Only Investments, will not be credited to the client's account as described above but instead will be paid to the Adviser. Clients should understand that the annual advisory fees charged in the AMBASSADOR/Freedom/RJCS programs are in addition to the management fees and operating expenses charged by open-end, closed-end and exchange- traded funds. To the extent the client intends to hold fund shares for an extended period of time, it may be more economical for you to purchase fund shares outside of these programs. If desired, you can purchase mutual funds directly from their respective fund families without incurring our advisory fee. When purchasing directly from fund families, clients could incur a front or back- end sales charge, you should review the fund prospectus. Clients should also understand that the shares of certain mutual funds offered in these accounts impose short- term trading charges (typically 1%-2% of the amount originally invested) for redemptions generally made within short periods of time. These short-term charges are imposed by the funds to deter "market timers" who trade actively in fund shares. Clients should consider these short-term trading charges when selecting the program and/or mutual funds in which to invest. These charges, as well as operating expenses and management fees, increase the overall cost to you by 1%-2% (or more). More information is available in each fund's prospectus. You should be aware that exchange traded funds ("ETFs") incur a separate management fee, typically 0.05%-0.40% of the fund's as sets annually (al though individual ETF s have higher or lower expense ratios), which is assessed by the fund directly. This management fee is in addition to the ongoing advisory fee assessed by The Center. The mutual funds and ETFs available in the AMBASSADOR/Freedom/RJCS programs could be purchased directly. Therefore, clients could avoid the second layer of fees by not using the above account type and making their own decisions regarding the investment. Page 12 Page 12  Clients should be aware that only those mutual fund companies which RJFS has a selling agreement with will be available for purchase within the AMBASSADOR/Freedom/RJCS and are generally limited to those fund companies that provide RJFS and its affiliates marketing service and support fees. As a result, not all mutual funds available to the investing public will be available for investment. If client is considering transferring mutual fund shares to or from RJFS they should be aware that if the Firm from or to which the shares are to be transferred does not have a selling agreement with the fund company, you must either redeem the shares (paying any applicable contingent deferred sales charge and potentially incurring a tax liability) or continue to maintain an investment account at the Firm where the fund shares are currently being held. Clients should inquire as to the transferability, or "portability", of mutual fund shares prior to initiating such a transfer. Mutual fund companies can also pay Raymond James to provide shareholder liaison services to you. These shareholder services could include responding to client inquiries and providing information on client’s investments. Raymond James may receive these shareholder services fees in amounts not to exceed 0.25% annually of the assets invested in a particular mutual fund. Alternative Investments Considerations Alternative Investments refers to securities products that serve as alternatives to more traditional asset classes and include but aren’t limited to investment products such as hedge funds, private equity funds, private real estate funds and structured products. It is important for you to work with The Center to evaluate how a particular alternative investment and its features fit your individual needs and objectives. A vital component of the selection process includes carefully reading the accompanying offering document(s) and/or prospectus prior to making a purchase decision. The offering documents contain important information that will help you make an informed choice. As part of the review process, you should consider the fees and expenses associated with a particular alternative investment, along with the fact that advisory representatives that are also registered representatives of RJFS may receive compensation related to any such purchase. It is important to note that the fees and expenses related to alternative investments are often higher than those of more traditional investments. We will answer any questions regarding the applicable fees and expenses and the initial and ongoing compensation. While each investment will differ in terms of both total fees and expenses and how those fees and expenses are calculated, the following section will discuss the primary categories of fees and expenses that are common to many alternative investments and the different ways that The Center and it’s IARs that are also registered representatives of RJFS would be compensated. Alternative investments often have limited liquidity, intermittent pricing and values based on appraisal- based pricing versus market-based pricing. Additionally, if an alternative investment is reflected on your statement, the value reflected is often an estimate subject to revision by the investment manager. One or a combination of these issues impact the value on which you are charged when your investment is eligible for asset-based advisory fees. For some products we receive compensation on Clients' investments in alternative investments, most typically based on the amount of committed capital and based on the duration of time for which a given fund will be open and invested. In cases where an adviser is permitted to charge an upfront commission or sales load, The Center typically declines to charge and/or receive any upfront commission or sales load. These positions may also be held as an Administrative-only asset for some or all of its life. Each investment is unique and the offering paperwork should be reviewed and discussed with adviser to understand costs. Page 13  Other Investment Considerations Client should also understand that certain no-load variable annuities may be offered in the Ambassador program. The annual advisory fees charged for these no-load variable annuities are in addition to the management fees and operating expenses charged by the insurance companies offering these products. Further information regarding fees assessed is available in the appropriate prospectus, which we can provide upon request. Client should understand that certificates of deposit ("CD"s) from Raymond James Bank may be purchased with a commission, in the Ambassador program. These CDs are considered non-billable assets for one year if there is a commission. This presents a conflict of interest because certain associated persons are dually registered as a registered representative with RJFS and Raymond James Bank is a wholly owned subsidiary of Raymond James Financial, Inc. A client’s total cost of each of the services provided through these programs, if purchased separately, could be more or less than the costs of each respective program. Cost factors may include the client’s ability to: • Obtain the services provided within the programs separately with respect to the selection of mutual funds, • Invest and rebalance the selected mutual funds without the payment of a sales charge, and • Obtain performance reporting comparable to those provided within each program When making cost comparisons, clients should be aware that the combination of multiple mutual fund investments, advisory services, and custodial and brokerage services available through each program may not be available separately or requires multiple accounts, documentation, and fees. If an account is actively traded or the client otherwise does not qualify for reduced sales charges for fund purchases, the fees may be less expensive than separately paying the sales charges and commissions. If an account is not actively traded or you otherwise would qualify for reduced sales charges, the fees in these programs may be more expensive than if utilized separately. The Client’s IAR has a financial incentive to recommend a fee-based advisory program rather than paying for investment advisory services, brokerage, performance reporting and other services separately. A portion of the annual advisory fee is paid to the client’s IAR, which may be more than the IAR would receive under an alternative program offering or if the client paid for these services separately. Therefore, the client’s IAR has a financial incentive to recommend a particular account program over another. IARs do not receive a financial incentive to recommend and sell proprietary mutual funds versus non-proprietary funds. However, because compensation structures vary by product type, IARs may receive higher compensation for certain product types. In addition, your IAR receives incentive compensation for utilizing a particular account program. Direct Indexing strategies seek to replicate the performance of a market index by directly holding the individual securities, or a representative sample of the individual securities, that make up the index. Direct indexing can provide a more tax efficient means of investing, and allows for more customized investment allocations, than investing in a fund or other commingled product that seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be realized if a client does not take advantage of tax planning or impose account restrictions, such as account level security or sector-based restrictions or customizations based on specific tax, Environmental, Societal, and Governance or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher than the fees and expenses associated with alternative index products. Higher fees and expenses could adversely impact account performance. The size of the account and the number of securities in the index the account seeks to replicate also limit the ability of the account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking error relative to the index and can cause a portfolio to underperform the index, including as a result of customization. Page 14  Buying Securities on Margin and Margin Interest When clients purchase securities, they either pay for the securities in full or borrow part of the purchase price from Raymond James & Associates, member NYSE/SIPC as the account custodian. Clients that choose to borrow funds for purchases must open a margin account with Raymond James, upon approval based on the firm's analysis of, among other things, the client's creditworthiness, and the suitability of margin use by the client. The securities purchased on margin are the firm's collateral for the margin loan. If the securities in the client's account decline in value, so does the value of the collateral supporting the margin loan, and as a result, Raymond James acts, such as to issue a margin call and/or sell securities in the account, to maintain the required equity. It is important that clients fully understand the risks involved in trading securities on margin (including selling short). Upon approval, where applicable, clients will receive a Truth in Lending Statement from Raymond James disclosing such risks, as well explaining the details and other conditions of the margin account. With respect to short sales, the client will be assessed asset-based advisory fees based on the value of the security sold short, but not on the proceeds received upon initiation of the short sale. Client should also understand that more sophisticated investment strategies such as short sells and margins are offered in the Ambassador programs. Fees for advice and execution on these securities are based on the total asset value of the account. While a negative amount may show on your statement for the margin security as the result of a lower net market value, the amount of the fee is based on the absolute market value. This creates a conflict of interest where the IAR has an incentive to encourage the use of margin to create a higher market value and therefore receive a higher fee. The use of margin also results in interest charges in addition to all other fees and expenses associated with the security involved. In cases where margin debit interest is charged to your account, advisory representatives that are also registered representatives of RJFS may receive a portion of the interest charged as a Controlled Asset Fee, presenting a potential conflict of interest. In the event of such margin credit extension, the costs incurred by the client, as well as the compensation received by the client's financial adviser and Raymond James, will generally increase as the size of the outstanding margin balance increases. Clients that purchase securities on margin should understand: 1) the use of borrowed money will result in greater gains or losses than otherwise would be the case without the use of margin, and 2) there will be no benefit from using margin if the performance of their account does not exceed the interest expense being charged on the margin balance plus the additional advisory fees assessed on the securities purchased using margin. On occasion trading results in a margin interest charge that wasn’t intentional as a temporary debit is created. We allow the margin interest to be charged by the custodian and then rebate the cost to the account within the 30 days following. Securities backed Lines of Credit (SBLOCs) SBLOCs are non-purpose loans where you pledge assets in your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or trade securities. Depending on your objectives, we can assist in your application for a SBLOC. This can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business opportunity, or a personal goal, any of which could trigger capital gains taxes. While we do not receive a fee for arranging these loans, our assistance in this process presents a conflict of interest, as we have an incentive for you to maintain these assets in your account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for managing your account. To address this conflict, we only make recommendations to obtain such loans when we believe obtaining a SBLOC is in the best interests of clients. Clients should note that they retain the ultimate decision to retain such loans. Some of the primary risks associated with obtaining an SBLOC can be as follows: Page 15  • • • • • Interest rate payments on the principal balance of the loan are not fixed and may increase; If the value of the securities pledged as collateral decrease, you will be liable for any deficiency; The lender can force the sale or liquidation of securities held as collateral without contacting you in advance to meet collateral requirements and you are not entitled to choose which securities are liquidated or sold; You are only entitled to draw on the line to the extent there is credit availability; and There may be additional risks when money funds or similar investments may produce less interest income or other yield than the interest you are paying on the loan We urge you to carefully read all disclosures and agreements prior to entering into an SBLOC or non-purpose agreement loan. While we can assist in the application process, we are not involved with the approval process. Compensation for the Sale of Securities or Other Investment Products The Center may receive normal and customary commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products in a brokerage account. IARs of The Center can select or recommend a retail brokerage account, and in some instances will select or recommend, mutual fund investments in share classes that pay 12b-1 fees and/or upfront sales charges when clients are eligible to purchase share classes of the same funds that do not pay such fees and are less expensive if they were to purchase through an advisory account. Compensation earned by these persons in their capacity as a registered representative may increase based on this recommendation. Thus, a conflict of interest exists between your interest and the interest of someone associated with The Center. As stated above, in the event The Center or any of its registered representatives receives this fee, either (i) such fee will be rebated against any advisory fee received by The Center from such account or (ii) no advisory fee will be received for such account. See item 10 for description of brokerage accounts. Some individuals associated with The Center are licensed as independent insurance agents. These persons will earn commission-based compensation for selling certain insurance products, including insurance products they sell to the client. Insurance commissions earned by these persons are separate and in addition to our advisory fees. The insurance products sold are transacted with a variety of insurance companies on a commission basis and are intended to complement our advisory services. You are under no obligation to purchase or apply for insurance or to use individuals associated with The Center for insurance product purchases. If client decides to purchase or apply for insurance, or use individuals associated with The Center as the broker for insurance products, a conflict exists between client’s interest and that of such associated person. We address this conflict of interest by recommending insurance products only where we, in good faith, believe that it is appropriate for the client’s particular needs and circumstances and only after a full presentation of the recommended insurance product to our client. In addition, we explain the insurance underwriting process to our clients to illustrate how the insurer also reviews the client’s application and disclosures prior to the issuance of a resulting agreement. Page 16  Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments only and are not available for cash surrender or in a death benefit unless specified in the annuity contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates and returns mentioned on any program presented are subject to change without notice. Insurance products are subject to fees and additional expenses. In certain circumstances, the client may wish to enter into a loan agreement with Raymond James Bank, a wholly- owned subsidiary of Raymond James Financial and an affiliate of Raymond James and utilize the assets in the client’s investment management or other custodial account(s) as collateral for the loan (also known as pledging) under a Security Based Lending program. In these situations, the loan cannot be used to acquire additional securities. The client is responsible for independently evaluating whether: (i) the loan is appropriate for their needs; (ii) the terms on which RJ Bank is willing to lend are acceptable; and (iii) the loan will have adverse tax, investment, accounting or other implications for the client and the account. The fees related to a securities-based loan are separate from the advisory fees charged to a client’s account(s). Additionally, RJ Bank compensates Raymond James for the IARs referral and for other services performed by Raymond James margin department such as, but not limited to, the monitoring of margin levels, calls, and liquidations as needed. The additional compensation received by Raymond James, typically shared with the financial adviser, results in a conflict of interest. Clients should explore this subject thoroughly with their financial adviser in order to be able to determine whether a securities-based lending arrangement is appropriate for their needs. The Center believes the charges and fees offered within each fee-based program are competitive with alternative programs available through other firms and/or investment sources yet makes no guarantee that the aggregate cost of a particular program is lower than that, which may be available elsewhere. Clients are under no obligation to implement investments through individuals associated with The Center or RJFS. Commissions may be higher or lower at RJFS than other broker/dealers. Termination of Agreement A client (or Adviser) can terminate any of the aforementioned agreements at any time by notifying Adviser (or client) in writing and paying the rate for the time spent on the investment advisory engagement prior to notification of termination. If the client made an advance payment, Adviser would refund any unearned portion of the advance payment. Clients that terminate the advisory agreement(s) within the first five (5) business days of entering into the advisory agreement will have any advisory fees that were charged refunded back to them. Page 17  Item 6: Performance-Based Fees & Side-By-Side Management Center for Financial Planning does not have performance-based fees or utilize side-by-side management. The only fees charged to the Client are noted under Item 5 “Fees and Compensation.” Item 7: Types of Clients Our clients generally are individuals, pension and profit -sharing plans, trusts, estates, or charitable organizations. Client relationships vary in scope and length of service. We do not impose absolute minimum dollar value of assets or other conditions for establishing a financial planning engagement or investment management service. We find that many clients meet at least one of the following financial criteria: liquid assets greater than $500,000, net worth greater than $1 million dollars, or income in excess of $200,000. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Method of Analysis Security analysis methods include charting, fundamental analysis, technical analysis, and cyclical analysis. The main sources of information that Adviser uses include (but aren’t limited to) Morningstar Direct and Raymond James research, and publicly available news sources. Other sources of information include financial newspapers and magazines, inspections of corporate activities, research materials prepared by others, corporate rating services, timing services, annual reports, prospectuses, SEC filings, and company press releases. The Center does not represent, warrant, or imply that the services or methods of analysis employed by our firm can or will predict future results, successfully identify market tops or bottoms, or insulate Clients from losses due to market corrections or declines. Investment Strategies Our investment strategy for a specific client is based upon the objectives stated by the client during the financial planning process. The client can change these objectives at any time. Investment objectives are developed by the client and adviser together that express their desired investment strategy. Our primary investment strategy used in client accounts is diversification through strategic asset allocation. We utilize stocks, bonds, cash, actively managed mutual funds and exchange traded funds as our core investment vehicles to build a globally diversified portfolio. Other strategies may include managed accounts, structured notes, hedge funds, margin transactions, and alternative investments such as private equity funds. The client’s cash needs are taken into consideration when devising an appropriate portfolio. Page 18  Risk of Loss All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Although there is no way to list all risks involved with investing, investors should be prepared to bear the following common investment risks: • Interest-rate and Inflation Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates and inflation will erode purchasing power. • Market, Business and Political Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security's particular underlying circumstances. Business risk is focused on a particular company. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. Some alternative investments may have limited or no liquidity. This would be disclosed ahead of investing are require separate client approval. • Credit Risk: Generally, bonds with a lower credit rating indicate a higher potential for financial risk and will generally command a higher offering yield. • Cybersecurity and AI Risk: With the increased use of technologies such as the Internet to conduct business, Adviser and its clients are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber incidents affecting Adviser and its service providers (including, but not limited to, accountants, law firms, custodians, and financial intermediaries) have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, impediments to trading and the inability of clients and/or investors to transact business. Similar adverse consequences could result from cyber incidents affecting issuers of securities in which a client invests, counterparties with which a client engages in transactions, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and other service providers for result, clients could be negatively impacted. Certain ETFs and alternative investments may be classified as partnerships for U.S. federal income tax purposes, which may result in unique tax treatment, including Schedule K-1 reporting. Additional information is also available in the ETF prospectus, which is available upon request. Item 9: Disciplinary Information Center for Financial Planning and its IARs have no disciplinary history. The information in this report is not the only resource you can consult. You can access additional information about The Center and our management personnel on the SEC’s website, located at www.adviserinfo.sec.gov, as well as FINRA’s website, at www.finra.org/brokercheck. Page 19  Item 10: Other Financial Industry Activities and Affiliations Securities Brokerage Our IARs are registered representatives of RJFS, which is a wholly owned subsidiary of Raymond James Financial, Inc. RJFS clears its securities transactions on a fully disclosed basis through RJA, which is also a wholly owned subsidiary of Raymond James Financial, Inc. Notwithstanding the fact that our IARs are registered representatives of RJFS, we are solely responsible for investment advice rendered. Our advisory services are provided separately and independently of the broker/dealer. Clients are under no obligation to use the services of our IARs in this separate capacity or to use RJFS and can select any broker/dealer you wish to implement securities transactions. The commissions charged by RJFS may be higher or lower than those charged by other broker/dealers. To the extent requested by a client, The Center recommends the services of other professionals for certain non- investment implementation purposes (i.e., attorneys, accountants, insurance, etc.). The client is under no obligation to engage the services of any such recommended professional, and The Center receives no compensation or referral fees if the client chooses the services of the outside professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from The Center. Timothy W. Wyman is an attorney who provides document preparation and estate planning services on behalf of some clients. These services include but are not limited to trust, wills, power of attorney and durable power of attorney for health care decisions. Mr. Wyman will not be named the power of attorney agent in regard to advisory clients. This service is separate from The Center. The Center does not receive compensation for this service. The client has no obligation to use these services and is free to seek legal services wherever they choose. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our employees have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The purpose of the Code of Ethics is to ensure employees of The Center maintain high standards, the intention of which is to protect Client interests at all times and to demonstrate our commitment to fiduciary duties of honesty, good faith, and fair dealing with clients. In addition, The Center maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by our firm or any person associated with it. All associated persons are expected to adhere strictly to these guidelines, as well as to the procedures set forth in the Code of Ethics and Compliance Manual. Any employee not observing our policies is subject to sanctions up to and including termination. Participation or Interest in Client Transactions Adviser and its employees buy or sell securities that are also held by clients. A conflict of interest exists because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither The Center nor persons associated with The Center shall have priority over your account in the purchase or sale of securities. Personal Trading At times, The Center and/or its Advisory Representatives may take positions in the same securities as clients. This is considered a conflict of interest with clients. The Center and its Advisory Representatives will generally be blocked with client trades, so all receive the same price on the same trading day. Page 20  We will uphold our fiduciary responsibilities to our clients to ensure no front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (e.g., a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Mutual fund purchases are not subject to these policies because the transactions are executed at NAV at the end of the trading day. Where client accounts are managed by a sub adviser, the firm and persons associated with the firm would not necessarily be aware of timing of trades being considered prior to the transaction. However, where the firm and/or its Associated Persons are aware that a sub adviser is considering specific transactions for clients’ accounts on a specific trading day where there is a potential material conflict, they will make every effort to be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades. Item 12: Brokerage Practices Selecting Brokerage Firms The Center does not maintain custody of client assets; assets will be held with a qualified custodian, which is typically a bank or broker-dealer. The Center recommends that investment accounts be held in custody by Raymond James & Associates (RJA), Member NYSE/SIPC. The Center is independently owned and operated and is not affiliated with RJA. RJA will hold the Client’s assets in a brokerage account and buy and sell securities when instructed to, in accordance with our agreement with Client(s). While the Center recommends that Clients use RJA as custodian/broker, the Client will decide whether to do so and open an account with RJA by entering into an account agreement directly with them. The Center does not open the account for the client, although The Center may assist the client in doing so. How we select brokers/custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including both quantitative (Ex: costs) and qualitative (execution, reputation, service) factors. Our IARs may be registered representatives of RJFS, a registered broker-dealer with FINRA, and may recommend RJA to advisory clients for brokerage and custodian services. Registered representatives of RJFS are subject to FINRA Conduct Rule 3280 that restricts them from conducting securities transactions away from RJFS. All client assets directly managed by the Adviser are held at RJA as our chosen qualified custodian based on their proven integrity and financial responsibility, best execution of orders at reasonable rates, and the quality of client service. Therefore, clients are advised that our IARs are limited to conducting securities transactions through RJFS. RJFS can charge a higher or lower fee than another broker charges for a particular type of service, such as transaction fees. Clients have the right to utilize the broker dealer of their choice and have no obligation to purchase or sell securities through RJFS. However, if the client does not use RJFS, the IAR will reserve the right not to accept the account. The Adviser benefits from electronic delivery of client information, electronic trading platforms and other services provided by the custodian for the benefit of clients. The Adviser also benefits from other services provided by the custodian, such as research, continuing education, conferences, and practice management advice. These benefits are standard in a relationship with a custodian and are not in return for client recommendations or transactions. The selection of RJA as a custodian for clients is not affected by these nominal benefits. The availability of these services from RJA benefits us because we do not have to produce or purchase them. We don’t have to pay for RJA’s services. These services are not contingent upon us committing any specific amount of business to RJA in trading commissions or assets in custody. Page 21  We have an incentive to recommend that you maintain your account with RJA, based on our interest in receiving RJA’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of RJA as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of RJA’s services and not RJA’s services that benefit only us. Soft Dollars Economic Benefits From Our Relationship with Raymond James and product vendors From time to time, we receive compensation in the form of sponsorship fees for seminars, meetings or conferences from product sponsors such as mutual funds, insurance companies, limited partnerships, and annuity sponsors. Such sponsorship fees generally entitle the sponsor to an allotted presentation to representatives of The Adviser. The selection of products and investment strategies for clients is not affected by these nominal benefits. Order Aggregation The Center will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple clients' accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading allows The Center to execute trades in a timelier, equitable manner and to reduce overall commission charges to Clients. We combine multiple orders of the same securities purchased for discretionary accounts; however, we do not combine orders for non-discretionary with discretionary accounts. Accordingly, non- discretionary accounts are bought or sold at different times than aggregated orders; therefore, such transactions may be executed at different prices and/or incur different execution costs. If you enter into non-discretionary, non-wrap fee arrangement with The Center, you pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary and/or wrap-fee arrangement with our firm. Item 13: Review of Accounts Periodic Reviews Clients engaged with The Center under financial planning and investment management services will have account reviews that are performed at least annually by one or more of our financial planners and a member of the investment department. Account reviews are performed more frequently when market conditions dictate, at the request of the client or notification from the client of a change in circumstances, a change in financial planning opportunities, and when cash or securities are deposited into or withdrawn from an account. Reviewers are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Page 22  Regular Reports In addition to periodic statements and confirmations from the custodian, clients receive periodic written or verbal updates from The Center which could include a net worth statement, financial planning updates, performance, and a summary of objectives and progress towards meeting those objectives. A client portal is available from Custodian with daily updated information regarding the accounts under advisement including asset allocation, performance, and transactions. Clients engaging in fee for financial planning services only will receive no regular reports from The Center except as contracted for and agreed upon at the inception of the advisory relationship. Item 14: Client Referral s and Other Compensation We have been fortunate to receive many client referrals over the years. The referrals come from current clients, estate planning attorneys, accountants, and other similar sources. The Center does not compensate referring parties for these referrals. We may receive commissions as a result of clients choosing to purchase variable products through their IAR in his or her capacity as an insurance agent and registered representat ive, commissions will be earned by the IAR as described in Item 5. In addition to the fee-based compensation we receive for providing advisory services, we earn commissions for transactional business in accordance with RJFS published commission schedule. At the conclusion of each year, qualifying advisers are awarded membership in RJFS' recognition clubs, which provide for travel expenses and fees for attendance at industry conferences on behalf of The Center. Qualification for the recognition clubs is based upon a combination of the annual production (both advisory and transactions), total client assets under administration with RJFS, and the professional certifications acquired through educational programs. We do not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Item 15: Custody The Center does not have physical custody of any Client funds and/or securities. However, The Center can be deemed to have custody over Client funds and/or securities because of the fee deduction authority granted by the Client and in certain situations where The Center accepts signed standing letters of authorization at the request of a client to transfer assets to a specific third party on their behalf. Our registered broker/dealer, Raymond James, maintains custody of your securities. For IRA accounts, Raymond James Trust of New Hampshire is custodian and RJA is sub-custodian. When acting as custodian, Raymond James & Associates, member NYSE/SIPC will deliver, not less than quarterly, an account statement to you detailing your account’s securities holdings, cash balances, dividend and interest receipts, account purchases and sales, contributions and distributions from the account and the realized and unrealized gains or losses associated with securities transactions affected in your account. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account. You should carefully review account statements for accuracy. If you have questions regarding your account or if you did not receive a statement from your custodian, please contact our firm at (248) 948-7900. You are urged to review and compare all account statements and other reports provided by Raymond James & Associates, member NYSE/SIPC and The Center’s client portal and outside custodians (if applicable). If your account assets are held by a custodian other than RJA, the prices shown on your account statements provided by the custodian can be different from the prices shown on statements and reports provided by RJA due to the use of different valuation sources (pricing vendors) or reporting methodologies (trade date versus settlement date, accrued income, long or short margin balances, etc.) by the custodian and RJA. Page 23  Clients are frequently provided with net worth statements at annual review meetings. Net worth statements contain approximations of bank account balances provided by the client, as well as the value of land, hard-to- price real estate, and other illiquid assets. Note these balances are not to be considered a replacement of consolidated statements you may receive from RJFS. The net worth statements are used for long-term financial planning where the exact values of assets are not material to the financial planning tasks. Item 16: Investment Discretion Discretionary Authority for Trading Adviser accepts accounts on both a discretionary and non-discretionary basis on behalf of clients. For discretionary accounts, Adviser has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client can override the Firm’s investment authority concerning specified investment objectives, guidelines and/or conditions imposed by the client. Discretionary trading authority facilitates placing trades in your accounts on your behalf to implement the investment strategy you have discussed with your Adviser. In general, changes to accounts managed on a non-discretionary basis by the Adviser will occur after those managed on a discretionary basis due to the required prior approval process. Limited Power of Attorney A Limited Power of Attorney provides trading authorization within discretionary accounts that is signed by the client. Item 17: Voting Client Securities The Center does not vote proxies with respect to the issuers of securities held in client accounts. The final decision of how to vote the proxy rests with the client. The Center will not take action or render advice with respect to any securities held in client accounts that are named in or are subject to class action lawsuits. Should The Center receive written or electronic proxy material/information, or notice of a class action lawsuit, settlement, or verdict affecting securities owned by a Client, we will forward all notices, proof of claim forms, and other materials to the client so they may handle if they choose. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The Center cannot give any advice or act with respect to the voting of these proxies. Item 18: Financial Information Center for Financial Planning, Inc. has not been subject to bankruptcy and is unaware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments. Page 24