CREATIVE INVESTMENT GROUP

CREATIVE INVESTMENT GROUP LLC FORM ADV PART 2A BROCHURE Item 1 – Cover Page 30 Burton Hills Blvd., Suite 250 Nashville, Tennessee 37215 615-949-9629 www.creativeinvests.com This brochure provides information about the qualifications and business practices of Creative Investment Group LLC. If you have any questions regarding the contents of this brochure, please do not hesitate to contact our Chief Compliance Officer, Kevin Kim by telephone at 513-977-8615 or by email at kevin.kim@dinsmorecomplianceservices.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 Investment Group LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Additional information about Creative Investment Group LLC is available on the SEC’s website at www.adviserinfo.sec.gov. December 23, 2025  Item 2 – Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the last annual filing of this Form ADV Part 2A, dated April 1, 2025, the following material changes have occurred: • • • Items 5, 10 & 12: We removed the dual registration with LPL Financial. Items 1: Chief Compliance Officer has been changed to Kevin Kim Item 5: Further description of Creative’s Fee Billing Procedures have been added: o We bill monthly in advance as of the previous month’s ending value o We bill on cash flows o Disclosure of a $150 annual account administration fee, which may be waived at our discretion. • Item 8: A disclosure on the risks of using a Securities Backed Line of Credit has been added.  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 A. Description of the Advisory Firm .................................................................................................... 5 B. Types of Advisory Services ............................................................................................................. 5 C. Client-Tailored Advisory Services .................................................................................................. 6 D. Information Received From Clients ................................................................................................. 6 E. Assets Under Management .............................................................................................................. 7 Item 5 - Fees and Compensation ................................................................................................................... 7 A. Financial Planning and Investment Management Services .............................................................. 7 B. Payment of Fees ............................................................................................................................... 8 C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers ... 9 D. Prepayment of Fees .......................................................................................................................... 9 E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients ............ 9 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................... 9 Item 7 - Types of Clients ............................................................................................................................ 10 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .................................................... 10 A. Methods of Analysis and Risk of Loss .......................................................................................... 10 B. Material Risks Involved ................................................................................................................. 11 Item 9 – Disciplinary Information .............................................................................................................. 15 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 15 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 16 A. Description of Code of Ethics ........................................................................................................ 16 Item 12 – Brokerage Practices .................................................................................................................... 17 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................ 17 B. Trade Aggregation ......................................................................................................................... 19 Item 13 – Review of Accounts .................................................................................................................... 19 A. Periodic Reviews ........................................................................................................................... 19 B. Other Reviews and Triggering Factors .......................................................................................... 19 C. Regular Reports ............................................................................................................................. 20 Item 14 – Client Referrals and Other Compensation .................................................................................. 20  Creative Investment Group Disclosure Brochure A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ............................ 20 B. Compensation to Non-Supervised Persons for Client Referrals .................................................... 20 Item 15 – Custody ....................................................................................................................................... 20 Item 16 – Investment Discretion ................................................................................................................. 21 Item 17 – Voting Client Securities .............................................................................................................. 21 Item 18 – Financial Information ................................................................................................................. 21 4  Creative Investment Group Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm Creative Investment Group LLC (“Creative” or the “Firm”) is a limited liability company organized in the State of Tennessee. Creative is an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”). Creative is owned by Bradley Bars and Skye Mejia. B. Types of Advisory Services Creative provides personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, endowments, and qualified retirement plans. Investment Management Services Creative offers investment management services on a discretionary basis and non-discretionary basis. All investment advice provided is customized to each client’s investment objectives and financial needs. The information provided by the client, together with any other information relating to the client’s overall financial circumstances, will be used by Creative to determine the appropriate portfolio asset allocation and investment strategy for the client. Financial planning services also are provided, depending on the needs of the client. The securities utilized by Creative for investment in client accounts mainly consist of equity securities, but we will also invest in registered mutual funds, exchange traded funds (ETFs), corporate bonds, REITS, variable annuities, private funds/alternative investments, tax exempt state and local municipality fixed income instruments (“municipal securities”), and US government and agency securities if we determine such investments fit within a client’s objectives and are in the best interest of our clients. Creative may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. Creative generally renders services to the client relative to the discretionary selection of External Managers. Creative also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by Creative. Financial Planning and Consulting Services Creative offers personal financial planning services to set forth goals, objectives and implementation strategies for the client over the long-term. Depending upon individual client requirements, the financial plan will include recommendations for retirement planning, educational planning, estate planning, cash flow planning, tax planning and insurance needs and analysis. Creative prepares and provides the financial planning client with a written financial plan and performs periodic reviews of the plan with the client, as 5  Creative Investment Group Disclosure Brochure agreed upon with the client. In addition, Creative provides financial planning services that are completed upon the delivery of the financial plan to the client. Clients should notify us promptly anytime there is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the financial information initially provided to us. Clients are under no obligation to implement any of the recommendations provided in their written financial plan. However, should a client decide to proceed with the implementation of the investment recommendations then the client can either have Creative implement those recommendations or utilize the services of any investment adviser or broker-dealer of their choice. Creative cannot provide any guarantees or promises that a client’s financial goals and objectives will be met. Investment Management Services to Retirement Plans Creative offers discretionary and non-discretionary advisory services to qualified plans, including 401k plans. These services include, depending upon the needs of the plan client, recommending, or for discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written investment policy statements, working with plan service providers, and providing general investment education to plan participants. Note for IRA and Retirement Plan Clients: When Creative provides investment advice to you regarding your retirement plan account or individual retirement account, Creative is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way Creative makes money creates some conflicts with your interests, so Creative operates under a special rule that requires Creative to act in your best interest and not put Creative’s interest ahead of yours. Note Regarding Tax or Legal Advice: In providing services, Creative does not offer or otherwise provide tax or legal advice. Creative will, at a client’s direction and approval, work with a client’s existing tax or legal professionals to assist in the provision of the services. Fees charged by any tax, legal or other third- party professionals are the responsibility of the client. Creative may refer professionals; however, there is no compensation to Creative for these referrals, and clients are under no obligation to use the referred service providers. C. Client-Tailored Advisory Services Clients may impose reasonable restrictions on the management of their accounts if Creative determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Creative’s management efforts. D. Information Received From Clients Creative will not assume any responsibility for the accuracy or the information provided by clients. Creative is not obligated to verify any information received from a client or other professionals (e.g., attorney, accountant) designated by a client, and Creative is expressly authorized by the client to rely on 6  Creative Investment Group Disclosure Brochure such information provided. Under all circumstances, clients are responsible for promptly notifying Creative in writing of any material changes to the client’s financial situation, investment objectives, time horizon, or risk tolerance. E. Assets Under Management As of March 31, 2025, Creative Investment Group managed on a discretionary basis $205,861,022 and $0 on a non-discretionary basis. Client assets are managed on an individualized basis. Clients may impose restrictions on their accounts. Item 5 - Fees and Compensation Creative charges fees based on a percentage of assets under management as well as fixed fees, depending on the particular types of services to be provided. The specific fees charged by Creative for services provided will be set forth in each client’s agreement. A. Financial Planning and Investment Management Services Fees for Investment Management Services Creative charges an annual investment management services fee that is agreed upon with each client and set forth in an agreement executed by Creative and the client. The annual investment management fee is based on a percentage of the value of assets under management and is paid monthly in advance. For accounts opened after the beginning of a new calendar quarter the Management Fee for the initial quarter will be paid starting at the end of the first month based on the asset value of the client’s accounts as of the last business day of that month. For subsequent quarters, the investment management services fees will be paid in advance based on the asset value of the client’s accounts as of the last business day of that quarter. For purposes of fee calculation, the asset value of client accounts include cash and cash equivalents. Creative adjusts on cash flows for clients assets; if assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value as related to the deposit/withdrawal and billed or charged not later than at the time of the next billing. Creative does not reduce investment management services fees for margin borrowing, regardless of whether the assets are in cash or other securities. Creative has a financial incentive to recommend that clients borrow money for the purchase of additional securities for the client’s account managed by Creative or otherwise not liquidate some or all the assets Creative manages. Creative addresses this conflict of interest by this disclosure and working to ensure that any recommendation to a client regarding the use of margin is suitable for the client. The annual advisory fee ranges up to 1.50% (per annum). A $150 annual account administration fee will apply to all accounts opened with Creative, unless waived by Creative at our discretion. Fees for Financial Planning and Consulting Services Clients that are receiving financial planning services only are charged a fixed fee ranging from up to $100,000, depending upon the complexity of a client’s plan and services provided. For clients receiving ongoing financial planning services the annual fee is charged quarterly. For financial planning services that are completed upon the delivery of the financial plan to the client, the fixed fee can be charged in quarterly installments, or otherwise in full upon delivery of the completed financial plan. Actual fees charged are 7  Creative Investment Group Disclosure Brochure clearly outlined in the financial planning agreement and clients receive invoices reflecting the amount of the fee due and payable. Fees for Investment Management Services to Retirement Plans Retirement plan advisory clients will be charged an asset based fee. The annual advisory fee for retirement plan clients ranges up to 0.75% (per annum). Notwithstanding the foregoing, Creative and the client may choose to negotiate advisory fees that vary from the ranges set forth above. Factors upon which a different advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. The investment management services fee charged by the Firm will apply to all of the client’s assets under management, unless specifically excluded in the client agreement. The investment management services fee may include the financial planning services described above. Although Creative believes that its fees are competitive, clients should understand that lower fees for comparable services may be available from other sources and firms. In addition, there are clients of the Firm who were clients of personnel of the Firm while such personnel were investment adviser representatives of an unaffiliated investment adviser. Those clients, in becoming clients of the Firm, have retained their previous fee schedules which vary from the ranges set forth above. The investment advisory agreement between Creative and the client may be terminated at will by either Creative or the client upon written notice. Creative does not impose termination fees when the client terminates the investment advisory relationship, except when agreed upon in advance. B. Payment of Fees Creative generally deducts its advisory fee from a client’s investment account(s) held at his/her custodian. Upon engaging Creative to manage such account(s), a client grants Creative this limited authority through a written instruction to the custodian of his/her account(s). The client is responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. A client may utilize the same procedure for financial planning or consulting fees if the client has investment accounts held at a custodian. Although clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, Creative will directly bill a client for investment advisory fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the client's account(s), including any fees paid directly to Creative. Clients may make additions to and withdrawals from their account at any time, subject to Creative’s right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate transferred securities or decline to accept particular securities into a client’s account. Clients may withdraw account assets at any time on notice to Creative, subject to the usual and customary securities 8  Creative Investment Group Disclosure Brochure settlement procedures. However, the Firm generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Creative may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers In connection with Creative’s management of an account, a client will incur fees and/or expenses separate from and in addition to Creative’s advisory fee. These additional fees may include transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate account manager (and the manager’s platform manager, if any), limited partnership, or other advisor, transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by a brokerage account. For External Managers, clients should review each manager’s Form ADV 2A disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship). The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding brokerage practices. D. Prepayment of Fees As noted in Item 5(B) above, Creative’s advisory fees are paid in advance. Therefore, upon the termination of a client’s advisory relationship Creative will review to determine whether a refund is due for advance billed fees. The client may specify how he/she would like such refund issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her account). E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients Creative does not buy or sell securities and does not receive any compensation for securities transactions in any client account, other than the investment advisory fees noted above. However, as further described in Item 10, certain personnel of Creative, in their individual capacities, are registered representatives of LPL Financial LLC, a FINRA and SIPC member, and registered broker/dealer. In addition, representatives of Creative, in their individual capacities, are also are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Item 6 - Performance-Based Fees and Side-by-Side Management Creative does not charge performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Creative’s fees are calculated as described in Item 5 above. 9  Creative Investment Group Disclosure Brochure Item 7 - Types of Clients Creative offers investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, endowments, and qualified retirement plans. Creative does not impose a minimum portfolio size or a minimum initial investment to open an account. However, Creative does reserve the right to accept or decline a potential client for any reason in its sole discretion. Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss The first step in Creative’s investment strategy is to understand the client’s financial picture by determining their risk tolerance, financial goals, tax situation, and liquidity needs. Creative then compiles this information and develops a financial plan that is offered to the client. Once Creative understands the client’s financial picture, investment recommendations are developed to align specifically with the client’s goals and risk tolerance. Creative primarily employs fundamental and technical analysis methods in developing investment strategies for its clients. Research and analysis from Creative are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criterion consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria which we believe indicates that they are a strong investment with a value discounted by the market. While this type of analysis helps Creative in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. Creative monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Creative will be able to accurately predict such a reoccurrence. As noted above, Creative generally employs a long-term investment strategy for its clients, as consistent with their financial goals. Creative will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of clients. At times, Creative may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector or asset class. 10  Creative Investment Group Disclosure Brochure Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence Creative’s investment recommendations. Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved Investing in securities involves a significant risk of loss which clients should be prepared to bear. Creative’s investment recommendations are subject to various market, currency, economic, political and business risks, and such investment decisions will not always be profitable. Clients should be aware that there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the client’s investment objectives will be obtained and no inference to the contrary should be made. Generally, the market value of equity stocks will fluctuate with market conditions, and small-stock prices generally will fluctuate more than large-stock prices. The market value of fixed income securities will generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and asset-backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration fixed income securities will generally fluctuate more than shorter duration fixed income securities. Investments in overseas markets also pose special risks, including currency fluctuation and political risks, and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve its investment objective. We may discuss or assist clients in establishing a Securities-Backed Line of Credit (“SBLOC”) with a qualified lender. An SBLOC is a revolving, non-purpose loan secured by eligible securities in a taxable brokerage account. While SBLOCs can provide liquidity without liquidating investments, they involve significant risks, including: market risk, leverage risk, interest rate risk, liquidity and concenration risk, and other considerations. Clients should carefully consider these risks, review lender terms, and maintain sufficient liquidity to meet potential collateral calls. We do not guarantee SBLOC availability or terms and do not receive compensation from lenders unless disclosed. SBLOCs may not be suitable for all clients. Past performance of investments is no guarantee of future results. Additional risks involved in the securities recommended by Creative include, among others: • Stock market risk, which is the chance that stock prices overall will decline. The market value of equity securities will generally fluctuate with market conditions. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend to fluctuate over the short term as a result of factors affecting the individual companies, industries or the securities market as a whole. Equity securities generally have greater price volatility than fixed income securities. 11  Creative Investment Group Disclosure Brochure • • Sector risk, which is the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall stock market. Daily fluctuations in specific market sectors are often more extreme than fluctuations in the overall market. Issuer risk, which is the risk that the value of a security will decline for reasons directly related to the issuer, such as management performance, financial leverage, and reduced demand for the issuer's goods or services. • Non-diversification risk, which is the risk of focusing investments in a small number of issuers, industries or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. • Value investing risk, which is the risk that value stocks not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to recognize the stock’s intrinsic value, or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though in theory they are already undervalued. Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an up market. • Smaller company risk, which is the risk that the value of securities issued by a smaller company will go up or down, sometimes rapidly and unpredictably as compared to more widely held securities. Investments in smaller companies are subject to greater levels of credit, market and issuer risk. • • Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests exclusively in securities of U.S. companies. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. Interest rate risk, which is the chance that prices of fixed income securities decline because of rising interest rates. Similarly, the income from fixed income securities may decline because of falling interest rates. • Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that fixed income security to decline. • Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the possible loss of principal. ETFs typically trade on a securities exchange and the prices of their shares fluctuate throughout the day based on supply and demand, which may not correlate to their net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that an active trading market will develop or continue. Owning an ETF generally reflects the risks of owning the underlying securities it is designed to track. ETFs are also subject to secondary market trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks to track for a number of reasons, including transaction costs incurred by the ETF, the temporary unavailability of certain securities in the secondary market, or discrepancies between the ETF and the index with respect to weighting of securities or number of securities held. • Management risk, which is the risk that the investment techniques and risk analyses applied by Creative may not produce the desired results and that legislative, regulatory, or tax 12  Creative Investment Group Disclosure Brochure developments, affect the investment techniques available to Creative. There is no guarantee that a client’s investment objectives will be achieved. • • Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts (“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to those associated with direct ownership of real estate, including losses from casualty or condemnation, and changes in local and general economic conditions, supply and demand, interest rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An investment in REITs or real estate-linked derivative instruments subject the investor to management and tax risks. Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the investor will bear additional expenses based on his/her pro rata share of the mutual fund’s operating expenses, including the management fees. The risk of owning a mutual fund generally reflects the risks of owning the underlying investments the mutual fund holds. • Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of Creative and its service providers. The computer systems, networks and devices used by Creative and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow or otherwise disrupt operations, business processes or website access or functionality. Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or other compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issues of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future. • Alternative Investments / Private Funds risk, investing in alternative investments is speculative, not suitable for all clients, and intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment, which can include: • • • • • • • • • loss of all or a substantial portion of the investment due to leveraging, short-selling or other speculative investment practices; lack of liquidity in that there may be no secondary market for the investment and none expected to develop; volatility of returns; restrictions on transferring interests in the investment; potential lack of diversification and resulting higher risk due to concentration of trading authority when a single adviser is utilized; absence of information regarding valuations and pricing; delays in tax reporting; less regulation and higher fees than mutual funds; risks associated with the operations, personnel, and processes of the manager of the funds 13  Creative Investment Group Disclosure Brochure investing in alternative investments. • Municipal securities risk, which is the risk related to securities issued by or on behalf of states, territories, possessions and local governments and their agency and other instrumentalities. Municipal securities and may be secured by the issuer’s general obligations or by the revenue associated with a specific capital project. Both “general obligation” municipal bonds and “revenue” bonds are subject to interest rate, credit and market risk, and uncertainties related to the tax status of a municipal bond or the rights of investors invested in these securities. The ability of an issuer to make payments could be affected by litigation, legislation or other political events or the bankruptcy of the issuer. In the event of bankruptcy of such an issuer, a client account investing in the issuer’s securities could experience delays in collecting principal and interest, and the client account may not, in all circumstances, be able to collect all principal and interest to which it is entitled. In addition, imbalances in supply and demand in the municipal market may result in a deterioration of liquidity and lack of price transparency in the market. At certain times, this may affect pricing, execution, and transaction costs associated with a particular trade. The value of certain municipal securities, in particular obligation debt, may also be adversely affected by rising health care costs, increasing unfunded pension liabilities, changes in accounting standards, and by the phasing out of federal programs providing financial support. Municipal securities may be less liquid than taxable bonds and there may be less publicly available information on the financial condition of municipal securities issuers than for issuers of other securities, and the investment performance of a client account investing in municipal securities may therefore be more dependent on the analytical abilities of Creative than if the client account held other types of investments such as stocks or taxable bonds. The secondary market for municipal securities also tends to be less well-developed or liquid than many other securities markets, a by-product of lower capital commitments to the asset class by the dealer community, which may adversely affect a client account’s ability to sell municipal securities it holds at attractive prices or value municipal securities. Lower rated municipal bonds are subject to greater credit and market risk than higher quality municipal bonds. • Government securities risk, is the risk relating to securities backed by the credit of the government as a whole or only by the issuing agency. US Treasury bonds, notes and bills and some agency securities, such as those issued by the Federal Housing Administration and Ginnie Mae, are backed by the full faith and credit of the US government as to payment of principal and interest and are the highest quality government securities. Other securities issued by US government agencies or instrumentalities, such as securities issued by the Federal Home Loan Banks and Freddie Mac, are supported only by the credit of the agency that issued them, and not by the US government. Securities issued by the Federal Farm Credit System, the Federal Land Banks and Fannie Mae are supported by the agency’s right to borrow money from the US Treasury under certain circumstances but are not backed by the full faith and credit of the US government. No assurance can be given that the US government would provide financial support to its agencies and instrumentalities if not required to do so by law. • Prepayment and call risk, is the risk that an issuer may repay principal in advance, especially when yields fall. Changes in the rate at which prepayments occur can affect the return on investment of these securities. When debt obligations are prepaid or when securities are called, the proceeds may be reinvested in securities with a lower yield. The account also may fail to recover additional amounts (i.e., premiums) paid for securities with higher coupons, resulting in an unexpected capital loss. 14  Creative Investment Group Disclosure Brochure There also are risks surrounding various insurance products that are recommended to Creative clients from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. Creative does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of External Managers Creative may select certain External Managers to manage a portion of its clients’ assets. In these situations, the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. In addition, Creative generally may not have the ability to supervise the External Managers on a day-to-day basis. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s management. Creative has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agent Activities As mentioned above in Item 5, advisory persons of Creative are licensed as insurance professionals. Such persons earn commission-based compensation for selling insurance products to clients. Insurance commissions earned by advisory persons who are insurance professionals are separate from and in addition to Creative’s advisory fee. This practice presents a conflict of interest as an advisory person who is an insurance professional has an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on client needs. Creative addresses this conflict through disclosure and strives to make recommendations which are in the best interests of its clients. Clients are under no obligation to purchase insurance products through any person affiliated with Creative. Creative clients should understand that lower fees and/or commissions for comparable services may be available from other insurance providers. Registered Representative Activities As mentioned above in Item 5, certain representatives of Creative are also registered representatives with LPL Financial LLC, a FINRA and SIPC member and registered broker-dealer. In this capacity, such representatives of Creative offer securities or alternative investments and receive normal and customary fees or commissions as a result of these transactions. In addition, these individuals receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the period that the client maintains the mutual fund investment. As a result of this relationship, LPL Financial LLC has access to certain confidential information (e.g., financial information, investment objectives, 15  Creative Investment Group Disclosure Brochure transactions and holdings) about clients, even if a client does not establish an account through LPL Financial LLC. If you would like a copy of the LPL Financial LLC privacy policy, please contact Creative as described on the cover page of this brochure. Clients should be aware that the receipt of additional compensation itself creates an inherent conflict of interest, and may affect the judgment of these individuals when making recommendations. Creative and LPL Financial LLC are separate, nonaffiliated entities. Nevertheless, to the extent that a Creative representative recommends the purchase of securities or other investment products where the representative receives commissions for doing so, a conflict of interest exists because the representative is incentivized to make recommendations based on the compensation received rather than on a client’s needs. Creative has adopted certain procedures designed to mitigate the effects of this conflict. As part of Creative’s fiduciary duty to clients, Creative and its representatives endeavor at all times to put the interests of clients first, and recommendations will only be made to the extent that they are reasonably believed to be in the best interests of clients. Additionally, the conflicts presented by this relationship are disclosed to clients through this brochure, client agreement and/or verbally prior to or at the time of entering into an Agreement. Clients are not obligated to implement recommended transactions through any Creative representative or any particular broker-dealer. Clients have the option to purchase any recommended investment through broker-dealers other than LPL Financial LLC. Creative clients should understand that lower fees and/or commissions for comparable services may be available from other broker-dealers. Recommendation of External Managers Creative may recommend that clients use External Managers based on clients’ needs and suitability. Creative does not receive separate compensation, directly or indirectly, from such External Managers for recommending that clients use their services. Creative does not have any other business relationships with the recommended External Managers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions A. Description of Code of Ethics Creative has a Code of Ethics (the “Code”) which requires Creative’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to Creative for review by the Firm’s Chief Compliance Officer. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. 16  Creative Investment Group Disclosure Brochure Creative will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Creative participates in the LPL Strategic Wealth Management Custodial Platform (“LPL”) program. Creative will recommend that investment management services clients establish brokerage accounts with LPL to maintain custody of clients’ assets and to effect trades for their accounts. Creative also will typically recommend the brokerage and custodial services of BNY Pershing LLC, “Pershing.” Pershing offers services to independent adviros, which include: custody of securities, trade execution, clearance and settlement of transactions and technology. Creative will continue to evaluate LPL and Pershing to confirm that they are providing quality execution services at competitive prices. In recommending LPL, Creative will consider a number of judgmental factors, including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and account statements; 3) the ability of LPL to settle the trade promptly and accurately; 4) the financial standing, reputation and integrity of LPL; 5) LPL’s access to markets, research capabilities, market knowledge, and any “value added” characteristics; 6) Creative’s past experience with LPL; and 7) Creative’s past experience with similar trades. While there is no direct link between the investment advice Creative provides and participation in the LPL program, Creative management receives certain economic benefits from the LPL program. These benefits may include software and other technology that provides access to client account data (such as trade confirmations and account statements), facilitates trade execution (and allocation of aggregated orders for multiple client accounts), provides research, pricing information and other market data, facilitates the payment of Creative’s fees from its clients’ accounts, and assists with back-office functions, recordkeeping and client reporting. Many of these services may be used to service all or a substantial number of Creative’s accounts, including accounts not held at LPL. LPL may also make available to Creative other services intended to help Creative manage and further develop its business. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance and marketing. In addition, LPL may make available, arrange and/or pay for these types of services to be rendered to Creative by independent third parties. LPL may discount or waive fees it would otherwise charge for some of these services, pay all or a part of the fees of a third-party providing these services to Creative, and/or LPL may pay for travel expenses relating to participation in such training. Finally, participation in the LPL program provides Creative with access to mutual funds which normally require significantly higher minimum initial investments or are normally available only to institutional investors. The benefits received through participation in the LPL program do not necessarily depend upon the proportion of transactions directed to LPL. The benefits are received by Creative, in part because of commission revenue generated for LPL by Creative’s clients. This means that the investment activity in client accounts is beneficial to Creative, because LPL does not assess a fee to Creative for these services. 17  Creative Investment Group Disclosure Brochure This creates an incentive for Creative to continue to recommend LPL to its clients. While it may be possible to obtain similar custodial, execution and other services elsewhere at a lower cost, Creative believes that LPL provides an excellent combination of these services. These services are not soft dollar arrangements, but are part of the institutional platform offered by LPL. Brokerage for Client Referrals Creative does not select or recommend BD/Custodians based solely on whether or not it may receive client referrals from a BD/Custodian or third party. Client Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage Creative to manage on a discretionary basis, Creative has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the client, to buy and sell securities for the client’s account and establish and affect securities transactions through the BD/Custodian of the client’s account or other broker-dealers selected by Creative. In selecting a broker- dealer to execute a client’s securities transactions, Creative seeks prompt execution of orders at favorable prices. A client, however, may instruct Creative to custody his/her account at a specific broker-dealer and/or direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage transactions, a client should consider whether the commission expenses, execution, clearance, settlement capabilities, and custodian fees, if any, are comparable to those that would result if Creative exercised its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a particular broker-dealer may involve the following disadvantages to a directed brokerage client: • Creative’s ability to negotiate commission rates and other terms on behalf of such clients • could be impaired; such clients could be denied the benefit of Creative’s experience in selecting broker-dealers that are able to efficiently execute difficult trades; • opportunities to obtain lower transaction costs and better prices by aggregating (batching) • the client’s orders with orders for other clients could be limited; and the client could receive less favorable prices on securities transactions because Creative may place transaction orders for directed brokerage clients after placing batched transaction orders for other clients. In addition to accounts managed by Creative on a discretionary basis where the client has directed the brokerage of his/her account(s), certain institutional accounts may be managed by Creative on a non- discretionary basis and are held at custodians selected by the institutional client. The decision to use a particular custodian and/or broker-dealer generally resides with the institutional client. Creative endeavors to understand the trading and execution capabilities of any such custodian and/or broker-dealer, as well as its costs and fees. Creative may assist the institutional client in facilitating trading and other instructions to the custodian and/or broker-dealer in carrying out Creative’s investment recommendations. Trade Errors 18  Creative Investment Group Disclosure Brochure In the event a trade error occurs, Creative endeavors to identify the error in a timely manner, correct the error so that the client’s account is in the position it would have been had the error not occurred, and, after evaluating the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at the designated custodian. In the event an error is made in a client account custodied elsewhere, Creative works directly with the custodian to take corrective action. In all cases, Creative will take the appropriate measures to return the client’s account to its intended position. B. Trade Aggregation To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Firm. Item 13 – Review of Accounts A. Periodic Reviews Investment Management Account Reviews Securities in client accounts are monitored on a regular and continuous basis by advisory persons of Creative and are subject to periodic sample testing reviews by the Chief Compliance Officer of Creative. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the client. In addition to the investment monitoring, each client account is reviewed at least annually. Reviews may be conducted more frequently at the client’s request. Investment management accounts are reviewed for consistency with the investment strategy and other parameters set forth for the account and to determine if any adjustments need to be made. Financial Planning and Consulting Services Account Reviews Creative offers ongoing financial planning services if established in the client agreement. Financial plans are updated and reviewed with the client at least annually. Reviews may be conducted more frequently at the client’s request and are not uncommon. The annual review includes an updated evaluation of the client’s financial objectives that were determined in the previous year. As a part of this evaluation, Creative will gather updated financial information from the client such as income, expenses, assets, liabilities, and insurance to develop their yearly financial planning reports. Financial planning reports are written and may consist of a net worth statement, cash flow statement, estimated tax projections, education analysis, retirement analysis, insurance needs analysis, estate tax calculation, and investment analysis. Reviews are conducted by an advisor of Creative who is appropriately licensed to provide financial planning services. In addition, Creative provides financial planning services that are completed upon delivery of the financial plan to the client. In such situations, Creative does not provide any ongoing reviews of the client’s financial plan. B. Other Reviews and Triggering Factors 19  Creative Investment Group Disclosure Brochure In addition to the periodic reviews described above, accounts may be reviewed as a result of major changes in economic conditions, material market, economic or political events, known changes in the client’s financial situation, and/or large deposits or withdrawals in the client’s account. Clients are encouraged to notify Creative if changes occur in a client’s personal financial situation that might adversely affect the client’s investment plan. C. Regular Reports Written brokerage statements are generated no less than quarterly and are sent directly from the qualified custodian. These reports list the account positions, activity in the account over the covered period, and other related information. Clients are also sent confirmations following each brokerage account transaction unless confirmations have been waived. Creative may also determine to provide account statements and other reporting to clients on a periodic basis. Clients are urged to carefully review all custodial account statements and compare them to any statements and reports provided by Creative. Creative statements and reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Creative does not receive benefits from third parties for providing investment advice to clients. B. Compensation to Non-Supervised Persons for Client Referrals Creative seeks to enter into agreements with individuals and organizations, some of whom may be affiliated or unaffiliated with Creative for the referral of clients to us. All such agreements will be in writing and comply with the applicable state and federal regulations. If a client is introduced to Creative by a solicitor, Creative will pay that solicitor a fee in accordance with the applicable federal and state securities law requirements. While the specific terms of each agreement may differ, generally, the compensation will be based upon Creative’s engagement of new clients and the retention of those clients and would be calculated using a varying percentage of the fees paid to Creative by such clients until the account is closed by written authorization from the client. Any such fee shall be paid solely from Creative’s fees, and shall not result in any additional charge to the client. Each prospective client who is referred to Creative under such an arrangement will receive a separate written disclosure document disclosing the nature of the relationship between the third party solicitor and Creative and the compensation that will be paid by us to the third party. In any case, applicable state laws may require these persons to become licensed either as representatives of Creative or as an independent investment adviser. Item 15 – Custody All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the custodian to retain their funds and securities and direct Creative to utilize the custodian for the client’s securities transactions. Creative’s agreement with clients and/or the clients’ separate agreements with the B/D Custodian may authorize Creative through such BD/Custodian to debit the clients’ accounts for the 20  Creative Investment Group Disclosure Brochure amount of Creative’s fee and to directly remit that fee to Creative in accordance with applicable custody rules. The BD/Custodian recommended by Creative has agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Creative. Creative encourages clients to review the official statements provided by the custodian, and to compare such statements with any reports or other statements received from Creative. For more information about custodians and brokerage practices, see “Item 12 - Brokerage Practices.” Item 16 – Investment Discretion Clients have the option of providing Creative with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in Creative’s client agreement. By granting Creative investment discretion, a client authorizes Creative to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of Creative if Creative determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Creative. See also Item 4(C), Client-Tailored Advisory Services. Item 17 – Voting Client Securities Creative does not accept the authority to and does not vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios. Item 18 – Financial Information Creative is not required to disclose any financial information pursuant to this item due to the following: a) Creative does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of rendering services; b) Creative is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts; and c) Creative has never been the subject of a bankruptcy petition. 21