CREATIVE FINANCIAL DESIGNS, INC.

Creative Financial Designs, Inc. DBA Creative Portfolio Management Form ADV Part 2A Disclosure Brochure December 11, 2025 Creative Financial Designs, Inc. 2704 South Goyer Road Kokomo, IN 46902 800.745.7776 765.453.9600 www.creativefinancialdesigns.com This brochure provides information about the qualifications and business practices of Creative Financial Designs, Inc. If you have any questions about the contents of this brochure, please contact us at 765.453.9600 and/or creativeportfoliomanagement.com. 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. Creative Financial Designs, Inc. is doing business as Creative Portfolio Management (CPM) Creative Financial Designs, Inc. is a Registered Investment Adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Creative Financial Designs, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. (CRD# 109032/SEC#: 801-60153)  ITEM 2: MATERIAL CHANGES This is created for Creative Portfolio Management as a Turnkey Asset Management Program under Creative Financial Designs. 2  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE.............…………………………………………………………………………………..1 ITEM 2: MATERIAL CHANGES ................................................................................... 2 ITEM 3: TABLE OF CONTENTS…………………………………………………………………………..….3 ITEM 4: ADVISORY BUSINESS ................................................................................... 5 Firm Description…...………..……………..……………………………………………………..………….……………....5 Ownership ............................................................................................................................................................5 Amount of Assets Managed by Creative ……………………………………... ..........................................................5 Investment Advisory Services Provided .................................................................................................................5 Descriptions and Account Minimums ....................................................................................................................5 General Provisions on Account Management ........................................................................................................6 Purpose Funds Description ..................................................................................................................................7 Biblical Faith Values Income Strategy Description .................................................................................................7 Biblical Faith Values Divinity ETF Description........................................................................................................8 Biblical Faith Values Harvest Growing Dividend Description .................................................................................9 Exchange Traded Fund (ETF) Description .............................................................................................................9 Five Tool Description .......................................................................................................................................... 10 Tax-Wise Strategy Description ............................................................................................................................ 10 Allocate Over Time Option Description .............................................................................................................. 11 Conditions for Managing Accounts ..................................................................................................................... 11 ITEM 5. FEES AND COMPENSATION ...................................................................... 11 Brokerage Management Custodial Fee at NFS ................................................................................................... 12 Termination Provisions ........................................................................................................................................ 12 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ............................................................................................................................................ 12 ITEM 7: TYPES OF CLIENTS ...................................................................................... 12 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................................................................................................. 12 Education, Business Standards of Persons Giving or Determining Advice ........................................................... 12 Other Business Activities ..................................................................................................................................... 13 Solicitor Activities ................................................................................................................................................ 13 ITEM 9: DISCIPLINARY INFORMATION .................................................................14 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................................................................................................................14 3  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................................................ 15 ITEM 12: BROKERAGE PRACTICES .......................................................................... 15 Choice of Broker/Dealers ............................................................................................................................................. 15 Execution of Transaction .............................................................................................................................................. 15 Soft Dollars/Referrals/Directed Brokerage ................................................................................................................... 15 ITEM 13: REVIEW OF ACCOUNTS AND FINANCIAL PLANS ............................. 15 Review of Accounts ................................................................................................................................................... 16 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ........................ 16 Client Solicitation ................................................................................................................................................ 16 Third Party Asset Managers ................................................................................................................................ 16 ITEM 15: CUSTODY ....................................................................................................... 16 ITEM 16: INVESTMENT DISCRETION ..………………….....………………………….. ........... 16 ITEM 17: VOTING CLIENT SECURITIES .................................................................. 16 ITEM 18: FINANCIAL INFORMATION…................................................................... 16 4  ITEM 4: ADVISORY BUSINESS FIRM DESCRIPTION: Creative Financial Designs, Inc. doing business as Creative Portfolio Management, (hereinafter referred to as, “the firm” or “CPM”) is a corporation formed according to the laws of the State of Indiana and an investment advisor firm registered with the SEC in 1982. The firm provides a variety of services through its solicitors. CPM is a privately owned SEC-registered investment advisor. OWNERSHIP: CPM is privately owned by several parties, including Brent Owens, who owns approximately twenty-five percent, and the Mick Owens Family Trust, which owns approximately seventy-three percent. Brent Owens is also the President of the firm and who also serves as a solicitor of CPM. The current trustees of the Mick Owens Family Trust are Mick Owens and Kathy Owens. Mick Owens is the founder of CPM and serves as a solicitor of CPM. The Mick Owens Family Trust and Brent Owens, are also significant stockholders of a related company, cfd Investments, Inc., an SEC-registered broker/dealer and member of FINRA and SIPC, and an insurance agency. (See Item 10: Other Financial Industry Activities and Affiliations). Mick Owens is also the principal owner of cfd Insurance Planners, a life and health insurance agency, and cfd Tax Preparation and Bookkeeping Services, Inc., an accounting practice. Additionally, cfd Realty, a real estate agency, is owned by Mick’s wife, Kathy Owens. AMOUNT OF ASSETS MANAGED BY CREATIVE FINANCIAL DESIGNS, INC.: As of the fiscal year ending December 31, 2024, the amount of client assets the firm managed totaled $2,478,773,967. Of that total, $2,425,358,045 was managed on a discretionary basis and $53,415,922 was on a non-discretionary basis. INVESTMENT ADVISORY SERVICES PROVIDED: CPM offers discretionary investment management to clients introduced to the firm through co-advisory relationships established with unaffiliated investment advisers. The firm provides its investment management services through brokerage accounts maintained at third-party custodians, such as Charles Schwab. DESCRIPTIONS AND ACCOUNT MINIMUMS: The firm manages a client’s brokerage account according to the client’s selections of the investment strategy and any allowable portfolio objective. The client will provide information to the firm, including a client’s selected portfolio objective. Each available investment strategy is unique and can be invested using securities such as common and/or preferred stocks, bonds, government securities, other fixed income securities, mutual funds, exchange-traded funds, options on any of the foregoing, certificates of deposit and money market funds or other cash-like investments. This is not intended as an exhaustive list of all of the types of investments that could be used for portfolio strategies and instead is a listing of some of the most commonly used investment types. A more detailed listing of investments is provided in connection with discussion about specific strategies, which are discussed in more detail following. CPM does not typically engage in option or margin strategies. Though the investor may decide to use margin or options in their accounts, the use of these as part of a strategy does increase risk with the account. Also, use of a margin account would increase costs to the investor. These costs are described in the paperwork provided by the selected custodian and are not reflected in CPM’s documentation. Investors are encouraged to evaluate the risks and fees associated with any investment strategy before selecting that strategy. The firm primarily uses asset-class model allocations based on research with other professional management models such as Morningstar (formerly Ibbotson), JP Morgan, Goldman Sachs, PIMCO, Northern Trust, Vanguard, etc. CPM’s models generally fall into five categories based on perceived risk models: Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive, referred to as Portfolio Objectives. Available investments are categorized according to the model guidelines and overall asset allocation is determined taking those categorizations, and investment and portfolio research into effect, in arriving at the respective model portfolio allocations. The Large Cap Growth, Large Cap Value and Global investment strategies are focused on one asset-class and not diversified across asset classes and asset types, while all other asset-class model portfolios are diversified across asset classes and asset types. The client can select from several In-House investment strategies with the firm. They are as follows: • Purpose Funds -minimum $25k account size 5  • Biblical Faith Values Income -minimum $50k account size • Biblical Faith Values – Divinity ETF -minimum $25k account size • Biblical Faith Values- Harvest Growing Dividend -minimum $25k account size • Exchange Traded Funds -minimum $25k account size • Five Tool -minimum $25k account size • Tax-Wise -minimum $100k account size GENERAL PROVISIONS ON ACCOUNT MANAGEMENT: Generally, in relation to managed accounts, client accounts must be established with a registered broker/dealer. Please note that the charges and fees applied by the broker/dealer relating to account maintenance and services are not specifically or exhaustively described herein. Clients are encouraged to review account-opening documentation, statements, and other clearing firm documentation and related information carefully to determine other fees or charges that apply and that are assessed by their broker/dealer and/or associated clearing firms. If a client’s managed brokerage account falls below the account minimum, the firm reserves the authority to change the chosen strategy to one that is more conducive to the management of assets at that level, or to discontinue management in its entirety (e.g. client had $100k in a higher minimum strategy, and then withdrew $65k from the account, leaving $35K in the account. CPM could move the assets to a strategy with a lower account minimum or terminate management on the account. Under such an instance, client will still have access to account with the custodian.) CPM reviews accounts for adherence to the account minimum requirements at the end of each calendar year, as distributions happen, or at such other time as CPM may desire. Upon review, CPM will make strategy changes accordingly. Clients can choose to change their strategies at any time, by providing written notice to CPM, as long as the client’s investment in the strategy meets the stated minimums for the strategy selected. Unaffiliated custodians hold all client securities with CPM. Securities are held in the client’s name, or the name of the applicable custodian or trust, in the case of qualified accounts. Clients can select the custodian that they use for the establishment of an account, subject to limitations imposed by CPM. The choice of custodian will affect what investment options are available to a client, and the costs associated with a particular investment, and the availability of specific investment. As such, model portfolios maintained by CPM differ based on the custodian chosen by the customer. Product issuers may issue investments in varying share classes that often include differences in internal expenses. Not all products are available through each custodian that CPM utilizes. As a result, the same investment strategies as maintained through different custodians may have different holdings. CPM does not guarantee that the products’ lowest-cost share classes will be available through each custodian utilized by CPM. CPM attempts to select the lowest-cost available share class when engaging in mutual fund transactions on behalf of the client. When it becomes known that lower cost share classes are available than the product held by the client, the firm engages in a process to convert the selected shares to the lowest-cost share-class available through the applicable custodian. To the extent possible, CPM will attempt to conduct such transactions at no cost to the client, and without any taxable event to the client. All conversions are subject to the policies and procedures of the applicable account custodian. Additionally, different custodians have different policies and procedures, and they may affect many items relating to the customer including, without limitation: transaction fees, custodial fees, and other fees and expenses. Additionally, such differences may also affect availability of investments and lowest share class options. Clients are encouraged to discuss this matter with their financial professional so as to understand these differences when selecting a custodian. There are costs that are paid by investors in connection with their selection of a custodian, and those costs vary between and among custodians. Services also differ between and among custodians. Clients are responsible for all fees and 6  expenses charged by the custodian regarding their investment holdings. For a list of fees and expenses, refer to information created by the respective custodians. Clients may request to place reasonable restrictions on certain aspects of the management of their accounts. For instance, clients may elect to retain certain securities in their managed account and not have those assets be subject to sale in the course of CPM’s management of the account. Clients may also elect, in some circumstances, to have capital gains “distributed” to be taken over a specified period of time. CPM charges its management fee inclusive of such assets because of the additional work and considerations that must be afforded in accommodating such client-imposed restrictions. The client can move any of the said assets to another non-managed account if desired to avoid additional fees. CPM may, at times, allow additional special requests of the client regarding the management of the client’s account. PURPOSE FUNDS – DESCRIPTION: The Purpose Funds strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Purpose Funds Values series of available strategies is a Biblically Responsible Investing (“BRI”) strategy. Under this strategy, CPM utilizes certain software and independent third-party asset screening programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics CPM examines. In a given portfolio, approximately 8 to 15 BRI mutual funds and ETFs may be employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Certain ETFs have additional market risks in that they are not always highly traded and thus have less volume daily. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical values and will otherwise attempt to follow the models established by CPM. The Biblical Faith Values Funds investment strategy attempts to invest in accordance with the Biblical Faith Values limitations described above, and to create a diversified portfolio based on mutual funds & ETF positions. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Portfolio Management’s overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values and will otherwise attempt to follow the models established by Creative Financial Designs. BIBLICAL FAITH VALUES – INCOME STRATEGY – DESCRIPTION: The Biblical Faith Values Income strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third-party asset screening 7  programs and communicates with fund companies in order to limit investments in companies that engage in certain industries or support certain activities or lifestyles or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The Biblical Faith Values Income Strategy is designed to provide a diversified income portfolio solution for clients. These portfolios are focused on generating income with the goal of providing relatively stable yield given most market conditions. The selection of the portfolio objective determines the percentage of the portfolio that is in fixed income versus equities, with more equity exposure for the more aggressive portfolio objectives. The equity portion of the Income Strategy prioritizes individual stocks, but may include ETFs or other funds, given the client’s selected portfolio objective. The fixed income portion of the Income Strategy uses mutual funds, and ETFs, and in rare occasions individual bonds. The fixed income and the equity portions are described in more detail below. The fixed income portion focuses on higher-quality income-based mutual funds and ETFs; however, individual corporate and/or municipal bonds can be utilized to build a portfolio designed to generate income. When individual bonds are used, they are initially rated A or better. Creative’s Management Team looks for higher credit quality bonds while also focusing on durations, maturities, diversification across sectors (and if necessary, across multiple states for municipals), and of course yield. Individual bond holdings if used will vary from account to account. The equity portion of the portfolios (all but the Conservative portfolio, as it does not include equities) are primarily focused on large cap and giant large cap value/blend stocks. Creative uses Bloomberg, ValueLine, Dorsey Wright, and Morningstar (and possibly other resources) to help search, identify, price, rank and determine the diversified equities to use in any given account. The firm’s goal is to find price stability using several key matrices such as and not limited to: financial strength, safety ratings, yield, sectors, price points, dividend stability, etc. The number of equity holdings are affected by the account size, but typically consist of approximately 15-25 investments. The individual holdings and the number of equities may vary from account to account and are diversified through various sectors. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive). As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical values and will otherwise attempt to follow the models established by CPM. Given the more limited equity exposure, there may be less diversification in this strategy than in other diversified strategies. This could add risk to the portfolio. If used, holding individual bonds can also lead to additional risk given the economic conditions. Owning fewer asset classes will produce less diversification in a portfolio. BIBLICAL FAITH VALUES – DIVINITY – DESCRIPTION: The Biblical Faith Values Divinity strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third-party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The screening process generally consists of the initial Biblically based moral values screen, followed by in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the funds’ managers. The ETF’s and funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 8 to 15 BRI funds and ETFs are employed to achieve the strategy’s objectives. The actual number varies by portfolio objective and is based on asset class exposure. 8  As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical values and will otherwise attempt to follow the models established by CPM. The Divinity strategy is centered on using the Inspire companies’ ETFs. Inspire has several index ETFs that attempt to filter Biblically. The Inspire ETFs will typically be a sizeable portion of the portfolio and Creative’s Management Team uses other mutual funds and possibly ETFs also BRI filtered to make up the entire portfolio allocation to maximize diversification. The investments selected are typically those that perform at the top of their category in terms of analytical metrics the firm examines. The Divinity strategy will have additional market risks in that the ETFs are not always highly traded and thus have less volume as other ETFs might have. This strategy likely has additional investment risk with the higher concentration in one fund family. This creates additional risk when buying and selling these ETFs in larger amounts. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. As BRI, by its nature, restricts certain investment options, it is considered a less diversified strategy. There may be more risk and fees associated with the BRI strategy than a more-diversified strategy. Investors are encouraged to consider this potentially higher level of risk and fees when selecting the strategy. Due to a limited pool of available investments in certain management strategies, governance requirements, etc., it is not always possible to exclude all investments that might violate some of the standards that are described in the prior paragraph. The firm does not make any claim that the investments in the model will fully exclude any companies that could be excluded based on the criteria above. Instead, this strategy should substantially reflect Biblical Values and will otherwise attempt to follow the models established by Creative Financial Designs. BIBLICAL FAITH VALUES – HARVEST GROWING DIVIDEND – DESCRIPTION: The Biblical Faith Values Harvest Growing Dividend strategy is part of the Biblical Faith Values series of investment strategies for the firm. The Biblical Faith Values series of available strategies is a BRI strategy. Under this strategy, Creative utilizes certain software and independent third-party asset screening programs and communicates with fund companies in order to limit investments in the stock of companies that engage in certain industries or support certain activities or lifestyles or otherwise contribute to or endorse such industries or activities. The firm generally endeavors to exclude investment companies that engage in or participate in or support industries or lifestyles relating to gambling, tobacco, alcohol, pornography, abortion, non-family lifestyles and other factors traditionally considered averse to Biblical standards. The Harvest Growing Dividend Strategy (the “Strategy”) primary objective is to provide current income through dividend paying investments along with capital appreciation as a secondary objective. The Strategy will invest primarily in value style US equities (typically 20-30 stocks) that have a track record of 25+ years of paying dividends, and which have grown each year on a per share basis. Each stock must also pass Creative’s proprietary Biblically Responsible Investing (BRI) screening, which screens for business practices that are not aligned with Biblical faith values. The Strategy will also invest in fixed income ETFs (typically 3-5), which are either managed by a pre-approved BRI firm or have at least 50% of each respective ETFs holdings that pass Creative’s BRI screener test. The asset allocation mix for the Strategy will differ - based on the individual investor’s selected portfolio objective of Conservative, Moderately Conservative, Moderate, Moderately Aggressive, or Aggressive and asset allocation rebalancing decisions will be performed quarterly. While the Strategy seeks to provide long-term returns while limiting volatility through creating a diversified portfolio, the exclusion of securities that do not pass Creative’s proprietary BRI screening could lead to higher comparative concentration and portfolio risk. The total investable domain of US stocks is narrowed by creating a list of companies that have paid a dividend for 25+ years, and which have increased each year. This list is then narrowed further by eliminating companies that do not pass Creative’s proprietary BRI screening. A rigorous research approach is then applied to each individual stock selection. Based on the stocks that pass the BRI screening, an in-depth analysis of industry and macroeconomic trends is performed in conjunction with a bottom-up deep dive analysis of company fundamentals, including, but not limited to, dividend yield, 3-5 year historical and expected future dividend growth rates, payout ratio, and Free Cash Flow generation. Perceived undervalued stocks that provide strong dividend income and exhibit positive fundamentals are then identified. Creative’s goal for the strategy is to generate higher than average total returns from current income and possibly capital appreciation versus its benchmark. The fixed income BRI ETF selection process is performed using a proprietary and meticulous scoring 9  approach that analyzes several factors, including, but not limited to, expense ratios, historical returns (absolute & vs. peers), weighted average coupons/yields, weighted average durations, and ratings. EXCHANGE TRADED FUNDS (ETF) – DESCRIPTION: The ETF investment strategy is focused on using Exchange Traded Funds to allocate a well-diversified portfolio within the given investment portfolios. The Creative Investment Team may add mutual funds to complete the allocation and if asset classes are not available or do not meet the Team’s research requirements. The screening process generally consists of in-depth analysis to identify a fund’s risk characteristics, performance metrics, and management quality. The focus of the ETF strategy is low cost with primarily passive ETF’s and well-diversified portfolios. This group of data is gathered utilizing industry standard software tools as well as needed communication with the fund’s managers. The investments selected typically are those that perform at the top of their category in terms of our analytical metrics. The actual number of ETFs employed in a given portfolio is approximately 10 to 15 investments. This varies on the level of asset class exposure primarily depending on portfolio objective. ETFs are normally a passive investment holding with potentially lower than average internal expenses compared to actively traded mutual funds. Passive investments have a tendency to track the indices they are modeled after. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. FIVE TOOL – DESCRIPTION: The Five Tool brokerage investment strategy is designed to give clients a rules-based, well- diversified management option while looking to maximize returns given the selected portfolio objective. This strategy likely uses all nine asset-class boxes for portfolio objectives Moderate, Moderate Plus, Moderately Aggressive, Aggressive, and Aggressive Plus. The strategy will likely use fewer asset classes in the Conservative and Moderately Conservative portfolio objectives; however, the goal is to remain well diversified. The strategy often opportunistically over-weighs investments in tech, health care, or other selected more aggressive sectors in order to bolster potential returns. This increased concentration does increase risk in the portfolio. This strategy uses actively managed mutual funds and potentially ETFs to fill in the allocations of each portfolio objective with defined rules to help filter for each style box, finding the best mutual fund investments available through the applicable custodian. The screening process for the Five Tool investment strategy is a rules-based standard that focuses on historical performance, lower internal investment cost, and superior historical returns compared to its industry peers. This information, and more, is filtered through Morningstar, Inc., an independent investment research company. Morningstar updates the investment information monthly, and the strategy compares investments on a monthly basis and makes changes as necessary, sometimes just providing a portfolio rebalance. The strategy looks to have 15-20+ active mutual funds and/or ETFs inside each portfolio objective with the typical holding, targeting 5%. The actual number of mutual funds and/or ETF holdings varies by portfolio objective and asset class exposure. The strategy attempts to use such mutual funds and/or ETFs that meet a 10-year track record, initially ranked as a five-star according to Morningstar at the time of purchase. Morningstar analyst rated as a gold, silver, or bronze, is highly ranked compared to its appropriate asset class peers and is lower trending in its internal investment expense compared to other active mutual funds in the same asset-class. Seven portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderate Plus, Moderately Aggressive, Aggressive and Aggressive Plus) and allocations are determined by data analysis. TAX-WISE STRATEGY – DESCRIPTION: The Tax-Wise Investment Strategy is available for non-qualified brokerage accounts and primarily uses ETFs and municipal mutual funds available through custodians, though the firm may also choose to use other investments to build the diversified portfolios. Muni mutual funds and ETFs are usually used for fixed income areas and ETFs for the equity for the available portfolios. The screening process generally consists of analyzing the tax implications of a fund in addition to an in-depth analysis to identify its risk characteristics, performance metrics, and management quality. These groups of data are gathered utilizing industry-standard software tools as well as through needed communication with the fund’s managers. The funds selected are typically those that perform at the top of their category in terms of the analytical metrics Creative examines. In a given portfolio, approximately 10 - 15 ETFs and mutual funds are employed to achieve the strategy’s objective. The goal for the strategy is to reduce the amount of taxable income, dividends, and capital gains for the account. Using ETFs helps Creative use investments that historically allow clients to keep more and reduce the potential amount of capital gains passed through to accounts. Given the more limited holdings, there may be less diversification in this portfolio than 10  in some more standard diversified portfolios, and that could add risk to the portfolio. Investors are encouraged to consider this potentially higher level of risk when selecting the strategy. Five portfolio objectives are available for the client to choose from (Conservative, Moderately Conservative, Moderate, Moderately Aggressive, and Aggressive) and are modeled after Creative Financial Designs’ overall diversified asset class models. Holdings will likely vary from account to account due to client’s capital gains concerns. ALLOCATE OVER TIME OPTION – DESCRIPTION: With respect to all of the strategies described herein, Creative makes the Allocate Over Time option available for accounts greater than $50,000. If selected by the client, Creative will not likely invest all of the client funds into the selected model portfolio immediately. Instead, Creative will allocate the account more slowly, usually over a 4 to 8-month timeframe, with the intention of investing funds during pullbacks and in different months. Of course, pullbacks do not always occur, and it is not always possible or feasible to limit purchases to periods of pullbacks. Under such market conditions, Creative tries to invest based on the 4-to-8-month timeframe. During this transition period, the account may not be invested according to the model portfolio, or selected portfolio objective, and may have fewer and less-diversified holdings than would be normally the case in the same portfolio. This does not guarantee a profit and could be detrimental to the portfolio growth especially over the short term. The Allocate Over Time option is available for accounts valued at $50,000 or more. CONDITIONS FOR MANAGING ACCOUNTS: Creative may make exceptions to the minimum account size requirements in some instances. Those exceptions may be made for a variety client-specific reasons, which may include, but are not limited to such situations as a client having multiple managed accounts with the firm, an anticipation of the client adding additional assets at a future point in time, or such other circumstances as the firm may deem applicable. The fees charged by Creative for the account is in addition to the fees charged by the underlying investments, product fees, account fees, any custodial fees, etc. To the extent that a client intends to restrict Creative from selling particular investments for an extended period of time, regardless of whether the asset is deposited into the account or purchased into the account, it may be more economical for the client to hold the investment in a non-managed account. Clients are advised that holding such restricted assets in the account will result in an obligation to pay management fees, transaction fees and custodial fees, as applicable. In addition, no fee adjustments are made during any calendar quarter for appreciation or depreciation in the value of the account. Additional fees may, however, be assessed if cumulative deposits during a quarter equals or exceeds 10% of account value, and a refund of fees will occur if a withdrawal equals or exceeds 10% of account value. Clients are advised that they may be able to purchase similar services separately from other service providers and the cost of such services may be more or less than the program fee charged by Creative. ITEM 5: FEES AND COMPENSATION Advisory fees are as set forth below with respect to the various programs and services. Fees may be negotiable depending on such factors as, without limitation, special needs or requirements of the client and/or the complexity or simplicity of the work required. Creative charges its fees directly to accounts managed by CPM. Creative does not charge performance-based fees under any advisory program, nor does it share or participate in the gains or losses of client accounts. The firm shall be paid such compensation for its services, and in such manner, as described below. Until paid, the fees and expenses charged by the firm shall constitute a lien upon the assets of the client’s managed account. In the event that additional assets are deposited into a client’s managed account during a fee period, the firm may but is not obligated to charge the client an additional fee in respect of the value of the additional assets, prorated for the number of days remaining in such fee period. In connection with any withdrawal of assets from a client’s managed account or upon termination of the client’s Investment Management Agreement, the firm retains the right to complete any transactions initiated or open as of the time thereof and to retain amounts in the client’s managed account sufficient to effect such completion and to satisfy any amounts owing by such client to the firm under the client’s Investment Management Agreement, however and whenever arising. Client pays certain fees and charges that are in addition to the asset management fee. These fees are dependent on the broker/dealer. 11  Further, the advisory fee charged by the firm for the client’s account is in addition to the fees charged by product issuers for certain products, including open-end funds, closed-end funds, ETFs, UITs, etc. To the extent that a client directs Creative to purchase particular investments or restricts Creative from selling particular investments for an extended period of time, it may be more economical for the client to hold the investment in a non-managed account. Additionally, such restrictions may increase the risk profile of the account. Clients are advised that holding such restricted assets in the Account will result in an obligation to pay management fees, transaction fees and custodial fees, as applicable. To the extent that the customer is charged 12b-1 fees by a mutual fund issuer based on funds maintained in the account, Creative shall not receive any compensation with respect to such fees. Any such refunds would be subject to the policies and procedures of that broker/dealer. BROKERAGE MANAGEMENT – CUSTODIAL FEE: A broker/dealer may charge a custodial fee on certain assets, in accordance with their policies and procedures. The custodial fee is charged as set forth in account-establishing documents. Neither Creative nor any of its affiliates share any compensation based on this fee collected by the custodian. Fees on these client accounts may be up to a maximum of 2.00% annually. Please understand that the 2.00% maximum figure described herein is charged by CPM, but will compensate both CPM and the Co-Adviser for services provided. CPM fees will be between 0.25% and 0.33%, depending on account size. All fee charged in excess on that amount is paid to Co-Adviser. Additionally, custodial fees, transaction fees, and other fees (whether transaction or asset based), whether charged by affiliated or non-affiliated parties, are not considered as part of the maximum fee described herein. The Co-Advisor portion of the advisory fee is negotiable. The fees collected by CPM are used to compensate CPM and the Co-Adviser for the services that are provided. TERMINATION PROVISIONS: Termination of advisory services can be accomplished by written notice from one party to another. CPM will return to client any unearned pre-paid advisory fees upon termination. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The firm and your representative do not accept performance-based fees for investment management services. The firm does not provide side-by-side management of mutual funds and other assets. ITEM 7: TYPES OF CLIENTS CPM provides advisory services to retail and institutional investors, individuals, including high net worth individuals and business entities, such as charitable organizations, as well as to employer retirement and pension plans. For account minimums, see Descriptions and Account Minimums and review the particular service. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Categorizations of assets are made using Morningstar or similar software, when possible. Appropriate adjustments to the overall model portfolios are determined by Creative’s Executive Investment Committee and the firm’s investment management team and are based upon assessments and views of then-current or future forecasted market and industry circumstances, in addition to other variables such as economic, demographic and geo-political events. With all investments and investment strategies there is a risk of loss of investment principal, and no guarantees are or can be made that any particular investment, investment plan or strategy will fulfill its objective or prove to be profitable. EDUCATION, BUSINESS STANDARDS OF PERSONS GIVING OR DETERMINING ADVICE: The risks associated with a particular strategy are provided to each client in advance of investing client accounts. Creative, through its solicitors, work with each client to determine their tolerance for risk as part of the portfolio and strategy selection process. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each client should understand and be willing to bear. Clients are reminded to discuss these risks with their investment advisor representative. 12  Creative utilizes an Executive Investment Committee in determining the general strategies employed in the delivery of investment advice provided to clients. Biographies of the Executive Investment Committee members are set forth below: Brent A. Owens, born in 1969, graduated from Indiana Wesleyan University with a B.S. in Business Administration in 1992. He is a General Securities Principal and a Financial Operations Principal. He has passed the following FINRA/state- regulatory qualifying examinations: Series 7, Series 24, Series 27, Series 63 and Series 65. He is an active member of the Financial Services Institute and the National Association of Insurance and Financial Advisers. Mr. Owens has been President of the firm and cfd Investments, Inc. (a registered broker/dealer) since 1997. From 1992 to 1997, Owens served both the firm and cfd Investments, Inc. in various capacities, including plan writing and investment management of the firm’s managed accounts. Kregg J. Rooze, born in 1974, graduated from Purdue University with a B.S. in Financial Counseling and Planning and Consumer Affairs in 1998. He is a General Securities Principal and Vice President of the firm. He has passed the following FINRA/state-regulatory qualifying examinations: Series 7, Series 24, and Series 63. He began working for firm in 1997. His experience includes plan writing, since 1999, Rooze served as the Managed Account Director of the firm. Mick Owens, born in 1946, graduated from Indiana State University in 1968 with a B.S. in Mathematics. Owens is the founder of the firm and of cfd Investments, Inc. Owens is also the founder of several companies that do not have material interrelationships with the firm: cfd Insurance Planners, cfd Accounting Services, and cfd Realty. Owens has obtained the CLU, ChFC, and CFP designations and is a general securities principal. He has passed the following FINRA/state-regulatory qualifying examinations: Series 7, Series 24, Series 63 and Series 65. Chris Rockey, born in 1979, graduated from Butler University in 2001 with a B.S in Physician Assistant Studies. Chris has worked in the financial services industry since 2008 after working as an emergency department Physician Assistant for more than 10 years. He works with individuals and small businesses to help them formulate their financial goals and develop strategies to implement them. Rockey has obtained the ChFC designation and has passed the following FINRA/state- regulatory qualifying examinations: Series 7 and Series 66. OTHER BUSINESS ACTIVITIES: Solicitor Activities Acting as Solicitor: The firm may in some instances act as a solicitor for third party asset managers and receive a fee for its solicitation activities. The fee received may include any of the following: a portion of the asset management fee charged to the client, a platform fee paid directly by third party asset manager, which may or may not be based on the assets under management maintained by the asset manager. With respect to certain third-party asset managers, the fee described herein may be in addition to fees associated with corporate sponsorship, revenue share or other arrangements discussed elsewhere in this form ADV or other firm disclosures. Acting as a Co-Advisor: The firm may in some instances act as a Co-Advisor, whereby Creative may provide advisory services alongside a third-party investment adviser. In such arrangements, typically, the third-party investment adviser will be providing management services, and the firm will engage in other advisory services in connection with the client/account. Both the third-party asset manager and the firm may charge a fee for the advisory services that each provides. That fee may be combined or billed separately, depending on the policies and procedures of the third-party investment adviser. With respect to certain third-party asset managers, the fee described herein may be in addition to fees associated with corporate sponsorship, revenue share or other arrangements discussed elsewhere in this form ADV or other firm disclosures. There are different methods used for the billing of fees, and these differences are dependent upon the third-party manager. Certain managers/custodians will collect the advisory fees in accordance with their policies and procedures. If that is the case, see the third-party manager’s policies and procedures for the details of the billing methodology. To the extent that CPM is billing its fees, and to the extent that the third-party investment advisor would so permit, the annualized fee that is billed quarterly, in advance and is based on the value of the assets on the final day of the quarter. When an account is opened during the quarter, the fee will be prorated for the portion of the calendar quarter for which management services were provided. The annual rate is fixed when a client opens or modifies an account. The rate is identified in the customer’s agreement. 13  In certain instances, fees may be charged to the account, to the client directly, through another managed account if allowed, via a bank or credit card all at the client’s option. Engaging Solicitors: To the extent permitted under applicable law(s), the firm may pay a fee under its referral program. The amounts paid and the persons eligible under the referral program are provided for by written agreement. The amount is based on a percentage of the fees it collects for investment advisory or financial planning services. Engaging Co-Advisors In situations relevant to the usage of this form ADV, CPM will act as a Co-Advisor, whereby another investment adviser may provide advisory services alongside CPM. In such arrangements, typically, CPM will be providing management services, and the third-party investment adviser will engage in other advisory services in connection with the client/account. Both the third-party investment adviser and CPM may charge a fee for the advisory services that each provides. That fee will be combined for efficiency of billing. CPM is billing its fees quarterly, in advance and is based on the value of the assets on the final day of the quarter. When an account is opened during the quarter, the fee will be prorated for the portion of the calendar quarter for which management services were provided. The annual rate is fixed when a client opens or modifies an account. The rate is identified in the customer’s agreement. In certain instances, fees may be charged to the account, to the client directly, through another managed account if allowed, via a bank or credit card all at the client’s option. ITEM 9: DISCIPLINARY INFORMATION In 2020, The Securities and Exchange Commission “SEC” issued an Administrative and Cease and Desist Order pursuant to Section 15(B) of the Securities Exchange Act, and Sections 203(E) and 203(K) of the Investment Advisers Act of 1940. The Order found that Creative Financial Designs, Inc. breached its fiduciary duty in connection with its mutual fund share class selection practices and revenue sharing payments by cfd Investments, Inc., its affiliated broker/dealer. The Order identified that the payments of 12B-1 fees and revenue share arrangements to cfd Investments, Inc., that were in effect from 2014 through 2019. These arrangements constituted a conflict of interest that was not fully disclosed in the form ADV. Additionally, the compensation received by cfd Investments, Inc. was not fully disclosed in the form ADV. The Order issued a monetary fine of $212,300 and ordered disgorgement of $569,516 and prejudgment interest of $208,424. Other details related to this matter, or matters relating to affiliates of CPM, can be found on the Investment Adviser Public Disclosure site (www.adviserinfo.sec.gov) or FINRA’s brokercheck (www.brokercheck.com). ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS CPM has some common shareholders, officers and directors with cfd Investments, Inc., cfd Insurance Planners, Inc. and other companies related only by common ownership. No CFD company has a controlling ownership interest in any other CFD company. cfd Investments, Inc. is an SEC-registered Broker/Dealer and member of FINRA and is also an insurance agency. Cfd Insurance Planners is a licensed life and health insurance agency. As disclosed elsewhere, there is also cfd Realty [a real estate broker]. The objective is to make the products and services of those companies available to clients, if desired, in order to provide superior services and products toward achievement of clients’ overall financial goals. However, unless otherwise noted herein, clients are not obligated to use either cfd Investments or any other affiliated entity in the course of implementing advice given by CPM. For some management platforms, clients are required to use the services of cfd Investments, Inc. as the broker/dealer. While the firm believes that the fees, commissions and charges of cfd Investments, Inc. are competitive with the industry norms and the negotiation of commission rates is possible, clients may be able to obtain substantially similar services from other industry broker/dealers at lesser cost. Given the close relationship between cfd Investments and CPM, cfd Investments and CPM have jointly created the firm Customer Relationship Summary (Form CRS). CPM believes that this is the best way of describing the relationships available with CPM. 14  ITEM 11: CODE OF ETHICS -- PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CPM, its employees and solicitors, are subject to the firm’s Code of Ethics. The Code generally provides that in all of CPM’s business the best interest of the client is primary. Conflicts of interest are to be avoided and, where they cannot be avoided, acted upon in the client's best interests. The Code further requires employees and solicitors to, among other things, adhere to all applicable regulatory requirements and to protect the confidential information of clients. This Code of Ethics also relates to solicitors relative to their personal investment transactions, all of which are monitored by the firm to ensure that personal trading does not interfere with the obligations and responsibilities of the solicitor to the client. Clients may obtain a copy of the firm’s Code of Ethics upon request. Specifically, solicitors are precluded from conducting trading in their personal accounts or in the accounts prior to placing client transactions with the same securities, except to the extent that it relates to block trades which are fully executed. ITEM 12: BROKERAGE PRACTICES CHOICE OF BROKER/DEALERS: Clients may establish a brokerage account through an approved broker/dealer. CPM may also make other broker/dealer arrangements available from time to time. For the costs and expenses related to Schwab, please check with the information made available by those Schwab, as its fees and charges can change from time to time. If CPM approves other custodians, the details of fees and expenses associated with such an account will be fully disclosed to the client upon any recommendation to open up such an account. EXECUTION OF TRANSACTIONS: When effecting securities transactions, the firm’s personnel will generally effect transactions for all clients utilizing block trading, (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts). This will not advantage one client over that of another. When the type or nature of the transaction is not conducive to the use of block trading, CPM will conduct all of the transactions as close in time as practicable under the prevailing circumstances. This practice will result in some clients obtaining execution of their portfolio transactions earlier than other clients do and in periods of market volatility could result in differing execution prices for some clients for transactions involving the same securities. The CPM investment strategies are mirrors of strategies that are otherwise offered to customers of Creative. When effecting transactions through different custodians, transactions will be conducted first at National Financial Services, then Schwab, and then at any remaining custodians. National Financial Services is a clearing firm for cfd Investments, Inc., an affiliate of Creative. relating is discussed on the SOFT DOLLARS/REFERRALS/DIRECTED BROKERAGE: Except as otherwise identified herein, CPM does not accept products or services that do not qualify for Safe Harbor outlined in Section 28(e) of the Securities Exchange Act of 1934, such as those services that do not aid in investment decision-making or trade execution. That said, certain third-party asset managers provide payments to CPM or cfd Investments, Inc. in the form of marketing support. Such payments are made to CPM for the purposes of supporting training of its solicitors, and such third-party asset managers are identified as corporate sponsors. firm’s website at to corporate sponsors Information www.creativefinancialdesigns.com. Certain third-party asset managers provide incentives to solicitors, and these incentives can include the payment of additional funds to solicitors, beyond the fee collected, as an offset of costs paid by the solicitors in the performance of their practices. These incentives may also include forms of non-cash compensation which would generally be used to offset expenses related to marketing or training activities. Discussions of these programs can be made available directly by our solicitors, as applicable to the services that they recommend. More information about these programs and arrangements are discussed in the firm’s conflicts of interest disclosure, and in the financial professional specific conflicts of interest disclosure. Please discuss this matter with your solicitor, if applicable. ITEM 13: REVIEW OF ACCOUNTS AND FINANCIAL PLANS 15  REVIEW OF ACCOUNTS: Managed accounts are reviewed by the Managed Accounts Department. Investments and portfolio strategies are managed for investment and portfolio ratings, drift, along with internal valuations on gains, losses, allocation, and diversification, etc. CPM conducts its monitoring via independent software as well as personal observations. In order to ensure that all portfolio transactions, holdings and values are correct and current, CPM urges its clients to carefully review all statements received directly from the independent financial institutions and qualified custodians. Furthermore, CPM conducts reviews of trades and managed accounts. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION CLIENT SOLICITATION: CPM, from time to time, enters into solicitation agreements pursuant to which it compensates third-party intermediaries for client referrals that result in the provision of investment advisory services by CPM. CPM will disclose these solicitation arrangements to affected investors, and any cash solicitation agreements will comply with Rule 206(4)-3 under the Advisers Act. Solicitors introducing clients to CPM may receive compensation from CPM, such as a retainer, a flat fee per referral and/or a percentage of introduced capital. Such compensation will be paid pursuant to a written agreement with the solicitor and generally may be terminated by either party from time to time. The cost of any such fees will be borne entirely by CPM and its solicitors and not by any affected client. THIRD PARTY ASSET MANAGERS OR CO-ADVISORY RELATIONSHIPS: CPM enters into marketing arrangements with certain third-party asset managers whereby CPM receives compensation and/or allowances in amounts based either upon a percentage of the value of new or existing account assets of clients referred to the third-party asset manager by CPM, or a flat dollar amount. CPM uses these funds to offset marketing expenses of CPM or its solicitors. ITEM 15: CUSTODY All client assets are held at qualified custodians who provide account statements directly to clients per their stated way of receiving (through online access, email, or mail). Clients have the choice of the custodian that they wish to have, and are responsible to pay for all custodial, transaction fees, or other such fees as charged by the custodian of their choice. ITEM 16: INVESTMENT DISCRETION CPM exercises discretion. Discretion gives CPM the authority to determine the securities to be bought and sold without obtaining specific client consent, unless a client of CPM specifically restricts certain transactions in their accounts. For certain managed accounts it is required that the clients maintain the account at a broker/dealer. ITEM 17: VOTING CLIENT SECURITIES CPM does not vote proxies for its clients with regard to their securities holdings. All client securities are held at their respective custodians in the name of the client and therefore client custodians’ direct proxies to the clients themselves for voting. ITEM 18: FINANCIAL INFORMATION CPM does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, CPM is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. CPM has no disclosures pursuant to this topic. 16