Flexible Plan Investments Ltd.

Item 1 – Cover Page Flexible Plan Investments, Ltd. 3883 Telegraph Rd. Suite 100, Bloomfield Hills, MI 48302 800-347-3539 Primary websites: flexibleplan.com | ontargetinvesting.com Supplemental websites: forabetterworld-investing.com | annuityprices.com | activeinvestmentadvisor.com quantifiedfunds.com | faithfocusedinvesting.com | goldbullionstrategyfund.com March 31, 2026 This Brochure provides information about the qualifications and business practices of Flexible Plan Investments, Ltd. If you have any questions about the contents of this Brochure, please contact our Compliance Department at 800-347-3539 or by e-mailing gsmith@flexibleplan.com. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission or by any state securities authority. Flexible Plan Investments, Ltd. is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Flexible Plan Investments, Ltd. is available on the SEC's website at www.adviserinfo.sec.gov. SEC File # 801-21073 i #119-0326 Part 2A of Form ADV Firm Brochure  Item 2 – Material Changes In the past, we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business' fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Material changes since the last brochure (June 10, 2025): • Fee Disclosure — FPI vs. Solicitor/Co-Adviser Compensation (Item 5, Revised): The fee tables and narrative in Item 5 have been revised to separately disclose (a) the portion of the total advisory fee retained by Adviser (FPI) for investment management services, and (b) the portion paid to the client's financial adviser through a soliciting agent or co-advisory arrangement. The total maximum fees charged to clients have not changed. The Separate Written Disclosure document attached to each client's Investment Management Agreement continues to set forth the specific fee rates applicable to that client's account. See Item 5 for full details. • Fee Schedule Restructuring (Item 5.E, Revised): The program fee schedules have been reorganized to lead with the FFS (Flexible Fee Schedule), which applies to most SMA accounts, and to separately identify Non-FFS legacy accounts, ETF/Direct Investment, FundLink, Group Retirement, Orphaned House Accounts, Donor Advised Fund, and Platform Asset Management. See Item 5.E for full details. • Orphaned House Accounts and Platform Asset Management Fees (Item 5.E, New): Fee schedules for Orphaned House Accounts and Platform Asset Management services (QFC and ETF SMA) are disclosed as separately identified fee categories. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, you may also request our Brochure by contacting our Compliance Department at 800-347-3539 or by emailing gsmith@flexibleplan.com. Our Brochure is also available on our website at www.flexibleplan.com free of charge. Additional information about Flexible Plan Investments, Ltd. is available via the SEC's website www.adviserinfo.sec.gov. The SEC's website also provides information about any persons affiliated with Flexible Plan Investments, Ltd. who are registered, or are required to be registered, as investment adviser representatives of Flexible Plan Investments, Ltd. SEC File # 801-21073. ii #119-0326 Part 2A of Form ADV Firm Brochure  Item 3 -Table of Contents Item 1 – Cover Page .................................................................................................................................................... i Item 2 – Material Changes ......................................................................................................................................... ii Item 3 -Table of Contents .......................................................................................................................................... iii Section 4.A – Firm Overview ..................................................................................................................................1 Section 4.B – Key Questions Answered .................................................................................................................1 Section 4.C – Definitions .........................................................................................................................................2 Section 4.D – Services Not Provided ......................................................................................................................3 Section 4.E – Advisory Services – Channel Descriptions.......................................................................................3 Section 4.F – General Advisory Provisions ............................................................................................................4 Section 4.G – Conflicts of Interest – At a Glance ...................................................................................................5 Item 5 – Fees and Compensation ..............................................................................................................................6 Section 5.A – Fee Snapshot ...................................................................................................................................6 Section 5.B – Fee Examples ...................................................................................................................................7 Section 5.C – Billing Mechanics and Rescission Rights .........................................................................................8 Section 5.D – Affiliated Fund Fee Credit (QFC Strategies) ....................................................................................9 Section 5.E – Program-Specific Fee Details ...........................................................................................................9 Section 5.F – Additional Fee Considerations ....................................................................................................... 13 Section 5.G – Annuity-Specific Fee Considerations ............................................................................................ 14 Section 5.H – Fee Comparison Disclosure .......................................................................................................... 14 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................................... 14 Item 7 – Types of Clients ......................................................................................................................................... 15 Section 7.A – Who Is FPI's Client? ...................................................................................................................... 15 Section 7.B – Client Types ................................................................................................................................... 15 Section 7.C – Account Minimums ........................................................................................................................ 15 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 16 Section 8.A –Overview and Navigation Guide ..................................................................................................... 16 Section 8.B – Top Risks ....................................................................................................................................... 17 Section 8.C – Investment Security Analysis ........................................................................................................ 17 Section 8.D – Investment Methodologies ............................................................................................................ 18 Section 8.E – Operational Provisions .................................................................................................................. 22 Section 8.F – Turnkey (Core) Strategies ............................................................................................................. 23 Section 8.G – Other Core Strategies ................................................................................................................... 24 Section 8.H – Single Strategy Explore Strategies ............................................................................................... 26 Section 8.I – Special Programs ............................................................................................................................ 31 Section 8.J – Proprietary Funds Table................................................................................................................. 35 Section 8.K – Platform Availability Table ............................................................................................................. 36 Section 8.L – Consolidated Risk Factors ............................................................................................................. 36 iii #119-0326 Part 2A of Form ADV Firm Brochure  Item 9 – Disciplinary Information ............................................................................................................................. 40 Item 10 – Other Financial Industry Activities and Affiliations................................................................................... 40 Section 10.A – Other Compensation ................................................................................................................... 40 Section 10.B1 – Compensation-Bearing Affiliations and Conflicts ...................................................................... 40 Section 10.B2 – Platform and Operational Relationships .................................................................................... 42 Section 10.C – Indirect Retirement Account Services ......................................................................................... 43 Item 11 – Code of Ethics ......................................................................................................................................... 44 Item 12 – Brokerage Practices ................................................................................................................................ 45 Item 13 – Review of Accounts ................................................................................................................................. 46 Item 14 – Client Referrals and Other Compensation .............................................................................................. 47 Item 15 – Custody .................................................................................................................................................... 48 Item 16 – Investment Discretion .............................................................................................................................. 48 Item 17 – Voting Client Securities ........................................................................................................................... 49 Item 18 – Financial Information ............................................................................................................................... 49 Privacy Notice .......................................................................................................................................................... 49 Cybersecurity Disclosure ......................................................................................................................................... 50 Appendix A – Grandfathered Fee Schedules .......................................................................................................... 52 Brochure Supplements Part 2B 1. Supplemental Information for Jerry C. Wagner ……….………………………………………………………….1 2. Supplemental Information for Daniel Poppe………………………………………………………………...…….3 3. Supplemental Information for Noah Campbell………………..………………………………..…………….……5 iv #119-0326 Part 2A of Form ADV Firm Brochure  Item 4 – Advisory Business Section 4.A – Firm Overview Flexible Plan Investments, Ltd. ("Flexible" or "FPI" or "Adviser") was founded in Bloomfield Hills, Michigan in 1981 by Jerry C. Wagner, President and controlling owner. Combining expertise in investment analysis, system design, and software development, Mr. Wagner anticipated technological innovations that allow average investors to enjoy professional management advantages at one time available only to institutions and high net worth individuals. Mr. Wagner founded Adviser with the goal of applying systematic, quantitative investment analysis to provide professionally managed investment programs to individuals through their financial representatives. As of December 31, 2025, Adviser had $1,484,076,880 of discretionary assets under management. Flexible is a TAMP — Turnkey Asset Management Program — that primarily provides managed accounts through direct strategy management of investments in mutual funds, ETFs, and/or other securities, or by supplying signals to various strategies to effectuate trading of such strategies by others. Adviser is registered with the U.S. Securities and Exchange Commission as an investment adviser. SEC File # 801-21073. Adviser's Business Model — Fees. Adviser's business model is to act as an asset manager and service provider to client accounts solicited or co-advised by agents or employees of third-party broker/dealers and registered investment advisers. The Investment Management Agreement ("IMA") entered into with each client provides that Adviser collects an advisory fee that is a combination of an Adviser (FPI) portion and a solicitor or co-adviser portion. Adviser's retained portion of the advisory fee is tiered by account size; the solicitor or co-adviser portion is a flat rate selected by the financial adviser within the ranges set by Adviser's fee schedules. Financial advisers are never paid directly by Adviser — they receive compensation from the third party that employs or contracts with them. The specific fee rates applicable to each client's account are set forth in a Separate Written Disclosure document attached to the client's IMA. See Item 5 for complete fee disclosure. Additional firm websites: forabetterworld-investing.com | annuityprices.com | activeinvestmentadvisor.com | quantifiedfunds.com | faithfocusedinvesting.com | goldbullionstrategyfund.com Section 4.B – Key Questions Answered The following answers key questions you may have about our services. Each answer includes a cross-reference to the Item in this brochure where full detail is provided. Question Answer What services does Adviser provide? Adviser provides discretionary investment management through quantitative, model-driven strategies. Adviser does not provide financial planning, tax advice, or legal advice. (See Section 4.D and Item 8) Who selects my investment strategy? You and your financial representative select strategies — Adviser does not select strategies for clients. (See Section 4.E) How are fees charged? Advisory fees are collected by Adviser quarterly in arrears as a percentage of your account balance. The total advisory fee has two components: (1) Adviser's (FPI's) retained fee for investment management services, which is tiered by account size and decreases as your balance grows; and (2) your financial adviser's compensation, which is a flat annual rate chosen by your financial adviser within the ranges set by Adviser's fee schedules. Your specific fee rates are disclosed in the Separate Written Disclosure document attached to your IMA. A fee snapshot table is provided in Section 5.A; detailed schedules are in Section 5.E. (See Item 5) What are the key conflicts of interest? Adviser receives sub-advisory fees from the Quantified Funds it manages, and forwards marketing fees to broker-dealers. A summary of all material conflicts is provided in Section 4.G. (See Items 5, 10, and 14) 1 #119-0326 Part 2A of Form ADV Firm Brochure  Question Answer A risk summary is in Item 8, Section B. A comprehensive risk library is in Item 8, Section L. Where do I find the investment risks? Please contact our Compliance Department: 800-347-3539 or gsmith@flexibleplan.com. Who do I contact with questions or complaints? Fees are described in Item 5; brokerage practices in Item 12; referral and solicitor compensation in Item 14. Section 4.C – Definitions "Adviser," "FPI," "Flexible" — Flexible Plan Investments, Ltd., the SEC-registered investment adviser. "Billable Balance" — The value of the investment account as of the last day of the relevant billing period, adjusted daily to prorate additions and withdrawals. "Co-Adviser" — A firm that accepts co-fiduciary responsibility alongside Adviser and monitors Adviser's activities on behalf of the client. Co-advisers receive a flat-rate annual compensation component collected by Adviser from the client's account and passed through to the co-adviser's firm — this component does not change with account size. See Items 5.E and 14. "FFS" — Flexible Fee Schedule. The primary fee schedule used for most of Adviser's SMA account business, pursuant to which the total advisory fee is composed of a tiered FPI portion and a flat solicitor/co-adviser portion selected by the financial adviser within ranges set by Adviser. See Item 5.E. "Investment" — Unless otherwise specified, includes mutual funds, exchange traded funds ("ETF"), exchange traded notes ("ETN"), exchange traded products ("ETP"), stocks, Commodity Trading Advisories (CTAs), Variable Annuity (VA) and Variable Universal Life (VUL) product sub-accounts, and other investment products having unit values determined on a daily basis at a minimum, or individual securities. These may include funds, sub-accounts or collective trusts of which Adviser is the adviser or sub-adviser. "Investment Family" — A mutual fund complex, insurance company, brokerage firm, or trust company custodian that maintains a universe of Investments suitable for Adviser's management. "IMA" — Investment Management Agreement. The written agreement governing the relationship between Adviser and each direct advisory client. "Platform" — A custodian, broker-dealer, insurance company, or trust company through which Adviser's strategies are implemented. Trading frequency, available investments, and fees vary by platform. "QFC" / "QFC Strategy" / "Affiliated Funds" / "Quantified Funds" — QFC (Quantified Fee Credit) Strategies are strategies that invest primarily in the Quantified Funds — a family of mutual funds for which Adviser serves as sub-adviser and receives a sub-advisory fee. Clients using QFC Strategies receive a Fee Credit against their advisory fee. See Section 4.G and Item 5.D. "SDBA" — Self-Directed Brokerage Account. A retirement plan participant's brokerage account through which Adviser provides management services. "Separate Written Disclosure" — The disclosure document attached to the client's IMA setting forth the specific solicitor/co-adviser fee rate applicable to that client's account. Clients should review this document carefully, as the specific rates shown may differ from the maximum rates disclosed in this brochure. "SMA" — Separately Managed Account. The type of asset management service generally carried out by Adviser. "Solicitor" — A firm or person that refers clients to Adviser pursuant to a Third Party Fee Agreement whose agent receives a flat-rate annual compensation component collected by Adviser from the client's account and passed through to the solicitor's employing or contracting firm. The solicitor fee component does not change with account size and is not retained by Adviser. See Items 5.E and 14. 2 #119-0326 Part 2A of Form ADV Firm Brochure  "TAMP" — Turnkey Asset Management Program. Adviser's primary operating model, providing investment management infrastructure to financial representatives and their clients. "Third-Party Fee Agreement" — The agreement between Adviser and a third-party broker/dealer or RIA (solicitor firm or co-advisory firm) governing fee ranges and service arrangements applicable to referred accounts. The specific fee rates applicable to each client are set forth in the Separate Written Disclosure attached to the client's IMA. Section 4.D – Services Not Provided No Financial Planning or Consulting Services. Adviser does not hold itself out as providing, nor does it provide, any financial planning, tax, or related consulting services. Neither Adviser nor any of its representatives serves as an attorney, accountant, or insurance agent on behalf of clients, and no portion of Adviser's services should be construed as such. Adviser does not recommend individual securities outside its program investment strategies. Adviser does not monitor assets held outside accounts managed by the Adviser unless expressly agreed in writing. Section 4.E – Advisory Services – Channel Descriptions Strategic Solutions Strategic Solutions is Adviser's trade name for its risk-managed account business available at Axos Advisor Services ("Axos") on a taxable basis, and on a tax-deferred basis utilizing a Monument Advisor Variable Annuity policy issued by Nationwide Advisory Solutions ("Nationwide") (collectively, the "Program"). Item Description How client engages. An individual becomes a client upon completion and Adviser's acceptance of an IMA with Adviser and a custodial agreement with the independent custodian. Discretion and trading. Adviser acts as discretionary investment manager pursuant to limited power of attorney granted in the IMA. Adviser implements client-selected strategies on a fully discretionary basis. Platform limitations. Platform-specific trading frequency restrictions, available investment choices, and fee structures apply. See Section 4.F for the Operational Differences table. Fees. See Item 5. Key Conflicts. See Sections 4.G, Item 5.D (Affiliated Fund Fee Credit), and Item 14 (Solicitor/Co-adviser compensation). Custodians. The current custodians for Strategic Solutions are Axos Advisor Services, 7103 South Revere Parkway, Centennial, CO 80112 (taxable) and Nationwide Advisory Solutions, 10350 Ormsby Park Place, Louisville, KY 40233 (tax-deferred). Custodian Responsibilities. Receipt and safekeeping of client cash and investment account assets; Execution of all investment directions from Adviser; Maintenance of separate accounting records for each client account; Payment of Program fees and Establishment Fees (if applicable) from client accounts as directed; Preparation and delivery of quarterly statements; Mailing of quarterly statements to each Program client. A copy of Adviser's agreement with each custodian is available upon written request. Adviser Custody. Adviser does not maintain physical custody of client assets. However, because Adviser has authority to deduct advisory fees directly from client accounts, Adviser is deemed to have constructive custody for purposes of applicable regulations. See Item 15. Rescission rights. All clients have the right to rescind their IMA without cost within five (5) days of the date of the IMA. IRA accounts have a seven-day rescission period. See Item 5.C for full details. 3 #119-0326 Part 2A of Form ADV Firm Brochure  Adviser retains the right, from time to time, to appoint, terminate, and replace Axos as custodian for the taxable segment of the Program. In such event, Adviser will select a replacement custodian providing at least the same level of services at commensurate cost. This right does not extend to Nationwide Advisory Solutions as custodian for the tax-deferred annuity segment. Variable Annuity / Variable Universal Life Platforms Adviser provides risk-managed account advisory services for variable annuities and variable universal life insurance policies on several insurance platforms. Please see Item 8 for strategy descriptions and Item 5 for applicable fees. Self-Directed Participant (Brokerage) Accounts Adviser provides management of certain workplace retirement plan accounts through self-directed brokerage account (SDBA) arrangements at various brokerage platforms. In these arrangements, the applicable retirement plan permits participants to direct a portion of their plan assets to a brokerage account for investment in Adviser's strategies. See Items 5.D and 8.I. Group Retirement Plans Adviser provides plan core fiduciary services, model portfolios, and management of participant retirement plan accounts custodied on various platforms, including The Flex Plan and Strategic Advantage 401k platforms. Sub-Advisory / Signal / Model Portfolio Services Adviser provides signals, model portfolios, and trade instructions to third-party platforms, TAMPs, broker-dealers, and other advisers. In these arrangements, the third party (not the end client) is Adviser's counterparty. Adviser acts as sub-adviser to the Quantified Gold Futures Tracking Fund, the Quantified Gold Futures Tracking Portfolio, and the Quantified family of funds. See Item 10 for affiliated fund detail. Section 4.F – General Advisory Provisions Suitability. Adviser requires clients to complete a suitability questionnaire as part of the IMA. This questionnaire establishes client's relative risk profile (conservative, moderate, or aggressive) and investment time horizon. Adviser uses this information to confirm that the strategies selected are suitable for the client. Client-Imposed Restrictions. Client may impose reasonable restrictions on the management of client's account. In the event that a requested restriction is clearly inconsistent with Adviser's investment approach or creates an administrative burden, Adviser reserves the right to decline the account or terminate the IMA. Platform and Custodian Differences. Adviser's management process and style does not differ between custodians other than with respect to the variety of strategies available, underlying products traded, and specific operational parameters of each platform. Operational Differences by Program (Summary Table) Program Trading Frequency Eligible Instruments Key Constraints Strategy Selection Client / adviser Strategic Solutions (Axos) NTF rules; redemption fees Mutual funds, ETFs, ETNs, Individual Securities Frequency of signals varies from daily to annual based on strategy employed; end-of-day mutual fund execution Platform-dependent VA/VUL sub-accounts Client / adviser Strategic Solutions (VA/VUL) Insurance platform limits SDBA QFC strategies only Quantified Funds Plan / custodian rules Client / adviser Platform-dependent ERISA / plan limits Adviser or participant Group Retirement Plans Platform-available funds Sub-Advisory / Signal Per platform Per platform Counterparty-defined Platform / adviser agreement 4 #119-0326 Part 2A of Form ADV Firm Brochure  Section 4.G – Conflicts of Interest – At a Glance The following is a summary of Adviser's material conflicts of interest. Each conflict is fully disclosed in the cross-referenced Item. Adviser seeks to manage these conflicts through disclosure, quantitative methodology controls, and compliance policies designed to address each conflict. Description Potential Conflict of Interest Affiliated Fund / Sub- Advisory Compensation. Adviser receives sub-advisory fees from the Quantified Funds when they are held in client accounts. Clients receive a Fee Credit to reduce — but not necessarily eliminate — this conflict. See Items 5.D and 10. Payment Agent / Share- Class Incentives. Adviser forwards marketing fees from the Affiliated Funds' distributor to broker-dealers offering Adviser Class SDBA shares. While the strategies available to the two share classes are different and have different attributes, financial representatives earn more on Adviser Class than Investor Class, creating an incentive to recommend Adviser Class. See Items 5.F and 14. Solicitor Fee Structure — Flat Rate on Large Accounts. Adviser's retained advisory fee is tiered and decreases with account size (maximum 1.00% on the first tier). The solicitor or co-adviser compensation is a flat rate regardless of account size (0–1.25% depending on program). On larger accounts where Adviser's tiered portion has decreased substantially, the solicitor or co-adviser may receive a higher percentage of the combined fee than Adviser retains. This creates a potential incentive for financial advisers to favor fee programs that maximize their flat-rate component. Adviser manages this conflict by capping total advisory fees at the maximums disclosed in Item 5.E and by requiring disclosure of all fee components in the Separate Written Disclosure attached to each client's IMA. See Items 5.E and 14. Marketing Consulting Arrangement. Adviser receives a marketing consulting fee from Advisors Preferred LLC for advice and training related to Affiliated Fund marketing. See Item 10. Employee Solicitation Compensation. Adviser's Regional Business Consultants (RBCs), Internal Business Consultants (IBCs), and Internal Associates (IAs) receive compensation to solicit clients. Clients pay no additional fee as a result of these arrangements. See Item 14. Sub-Adviser Signal Fee Arrangements. Adviser pays signal fees (generally 20% of Net Advisory Fee) to third-party sub-advisers including Disciplined Wealth Management (DWM), Hg Capital Advisors, ProfitScore Capital Management (PCM), Global View Capital Management (GVCM), Active Investment Management (AIM), Avant Capital Management, and STF Management. See Item 10. See Items 5, 10, 12, and 14 for full disclosure of each conflict. 5 #119-0326 Part 2A of Form ADV Firm Brochure  Item 5 – Fees and Compensation Section 5.A – Fee Snapshot Adviser's business model is to collect a combined advisory fee from client accounts — composed of (1) Adviser's own tiered advisory fee for investment management services, which decreases as account size increases, and (2) a flat-rate compensation component for the client's financial adviser (solicitor or co-adviser), which is chosen by the financial adviser within ranges established by Adviser. The specific solicitor/co-adviser rates applicable to each client are set forth in the Separate Written Disclosure document attached to the client's IMA. Client Advisory Note. Clients should consider total costs — including the FPI advisory fee, financial adviser compensation, underlying product expenses, and platform/custodian charges — not only any single component, when evaluating the overall cost of the program. The table below summarizes fee components by program. It does not include underlying product expenses (fund expense ratios) or platform/custodian charges payable to third parties. Donor Advised Fund (DAF) accounts follow the same advisory fee schedule as FFS or Non-FFS SMA accounts, as applicable — see Section 5.E. All fee rates are annual maximums; actual rates may be lower. See Section 5.E for full tier-by-tier breakdowns. Program FPI Advisory Fee (Annual, Tiered) Optional Establishment Fee Platform / Custodian (Third Party) Underlying Fund Expenses Financial Adviser Compensation (Annual, Flat) Maximum Total Advisory Fee Paid to FPI Combined maximum Paid to Third Party Paid to Fund Paid to Financial Adviser FPI 0.20% / Solicitor up to 1.00% 2.25% → 1.60% FFS Accounts (Most SMA accounts) 1.00% → 0.35% (tiered by AUM) 0% – 1.25% (flat; set by adviser) Fund / ETF expense ratios Up to 1.20% total (FPI 0.20%; solicitor up to 1.00%) Axos / Nationwide / platform charges Platform- dependent Non-FFS Accounts (Legacy agreements) Same as FFS (where applicable) Fund / ETF expense ratios 2.00% → 0.70% (see 5.E) Half of total tiered fee: 1.00% → 0.35% (tiered by AUM) Half of total tiered fee: Fixed at FPI rate per tier (1.00% → 0.35%) None ETF / Direct Investment Trading costs; bid/ask spread 1.75% → 1.35% 0.75% → 0.35% (tiered by AUM) 0% – 1.00% (flat; set by adviser) ETF expense ratios FundLink None Platform charges 1.85% → 1.60% 0.60% → 0.35% (tiered by AUM) 0% – 1.25% (flat; set by adviser) Fund expense ratios None 0.75% (all sizes) Record keeper / TPA fees 1.75% (all sizes) Group Retirement (Flex Plan / SA 401k) Fixed at 1.00% (per plan agreement) Fund expense ratios None Orphaned House Accounts None (no solicitor) Custodian charges 1.50% → 0.85% Fund expense ratios 1.00% → 0.35% (advisory) + 0.50% (servicing) 6 #119-0326 Part 2A of Form ADV Firm Brochure  Program FPI Advisory Fee (Annual, Tiered) Optional Establishment Fee Platform / Custodian (Third Party) Underlying Fund Expenses Financial Adviser Compensation (Annual, Flat) Maximum Total Advisory Fee Paid to FPI Combined maximum Paid to Third Party Paid to Fund Paid to Financial Adviser FPI 0.20% / Solicitor up to 1.00% 1.00% (flat; all sizes) Custodian charges 1.00%– 2.00% Small Accounts (<$25,000 initial balance) 0% – 1.00% (flat; set by adviser) Fund expense ratios None (Establishment Fee NOT permitted) N/A None Billed by Platform only Platform Asset Management (QFC Strategies) Fund expense ratios = Affiliated Fund Credit earned on strategy (no addl. fee billed) No separate advisory fee billed to client N/A None Billed by Platform to client Fund expense ratios Per Platform contract Platform Asset Management (ETF SMA Strategies) Management fee contracted with Platform; billed by Platform None SDBA (Investor Class) Sub-advisory offset only Plan / custodian fees Fund expense ratios No separate advisory fee billed 0% – 0.30% (flat; set by adviser) paid from Sub- advisory offset None SDBA (Adviser Class) Sub-advisory offset only Plan / custodian fees; higher BD compensation Higher fund expense ratios No separate advisory fee; fund- level costs 0.15% (flat) paid from Sub- advisory offset 0.60% marketing fee (via Payment Agent; not deducted from acct) Important: Financial adviser compensation is paid to the financial adviser's employing or contracting firm — it is not retained by Adviser (FPI). The total advisory fee represents the maximum combined amount Adviser may collect on behalf of all parties. Your specific rates are in your Separate Written Disclosure. Section 5.B – Fee Examples The following examples are illustrative only and do not represent a projection of future fees, performance, or returns. Actual fees depend on billing period, account value, platform, strategy selected, applicable fee waivers, and the specific solicitor/co-adviser rate selected by the financial adviser. Underlying fund expenses and platform/custodian charges are additional and vary. Example 1: $250,000 FFS Account (Maximum Rates) FPI advisory fee (first $250,000 × 1.00%): $2,500 - $625 per quarter in arrears* Financial adviser compensation (flat 1.25% × $250,000): $3,125 - $780 per quarter in arrears Maximum total advisory fee (2.25% × $250,000): $5,625 - $1,405 per quarter in arrears No Optional Establishment Fee Note: If the financial adviser selects a lower flat rate (e.g., 0.50%), the FPI fee remains $625 per quarter in arrears while the adviser's component drops to $313 per quarter in arrears. At this tier FPI's fee does not change based on the solicitor's rate selection. 7 #119-0326 Part 2A of Form ADV Firm Brochure  Example 2: $1,500,000 FFS Account (Large Account Dynamic) FPI advisory fee (blended): $500,000 × 1.00% + $499,999 × 0.75% + $500,001 × 0.35% ≈ $10,500 - $2,625 per quarter in arrears* Financial adviser compensation (flat 1.00% × $1,500,000): $15,000 - $3,750 per quarter in arrears Maximum total advisory fee: ≈ $25,500 - $6,375 per quarter in arrears Note — large account dynamic: At maximum rates on this account the financial adviser receives approximately $15,000 divided over four quarters in arrears while FPI retains approximately $10,500 divided over four quarters in arrears. As balances grow, FPI's tiered rate continues to decrease while the solicitor's flat rate remains unchanged. This is a material conflict of interest disclosed in Section 4.G. Example 3: $20,000 Small Account One-time Set-Up Fee: lesser of 3% × $20,000 ($600) or $350 = $350 (retained entirely by FPI) FPI advisory fee (flat 1.00% × $20,000): $200/year - $50 per quarter in arrears* Financial adviser compensation (e.g., flat 0.50% × $20,000): $100/year- $25 per quarter in arrears Combined advisory + solicitor (1.50%): $300/year - $75 per quarter in arrears Example 4: $100,000 SDBA Adviser Class Account FPI advisory fee in excess of Affiliated Fund Fee Credit: $0 (sub-advisory fee at fund level entirely offsets advisory fee for QFC-only SDBA accounts meeting waiver threshold) Financial adviser fee for Solicitors and Co-Advisors dealers is 0.75%, consisting of 0.15% from combined advisory and sub-advisory fees and 0.60% in marketing fees paid on behalf of the Distributor; not deducted separately from account) Total annual compensation to broker/dealers is 0.75%, consisting of 0.15% from combined advisory and sub-advisory fees and 0.60% in marketing fees paid on behalf of the Distributor. QFC Fee Credit — Illustrative Calculation Assume: $200,000 FFS account; FPI fee at 1.00% = $2,000/year*. QFC sub-advisory fee credit at 55 bps = $1,100/year. Adviser first applies the $1,100 credit to offset its own $2,000 fee — net FPI fee ≈ $900/year. If the credit had exceeded FPI's fee, Adviser would apply the excess to pay a portion of the solicitor fee on the client's behalf (see Section 5.D). This credit is not guaranteed and may vary based on fund allocation and AUM levels. *As Advisory Fees are calculated on Billable Balance each quarter or month, as the case may be, actual dollar amounts will vary based on gains of losses in the investment in the funds as well as Additions and Withdrawals made with respect to Client accounts. Section 5.C – Billing Mechanics and Rescission Rights Clients compensate Adviser for advisory services through advisory fees charged pursuant to the IMA. Adviser collects the combined advisory fee (FPI portion plus solicitor/co-adviser portion) from the client's account and pays the solicitor or co-adviser portion to the financial adviser's employing or contracting third-party firm in accordance with the applicable Third Party Fee Agreement. Agents are never paid directly by Adviser — they receive compensation through the third party that employs or contracts with them. Unless otherwise provided in an agreement between the parties, all fees are computed quarterly in arrears at a rate equal to one- quarter (1/4) of the annual percentage multiplied by the Billable Balance, less any applicable Affiliated Fund Fee Credits (see Section 5.D). The Billable Balance means the value of the investment account as of the last day of the relevant quarter, adjusted daily to prorate additions and withdrawals during the quarter. Effective August 1, 2012, monthly billing in arrears became available to select broker-dealers. Monthly fees are computed at a rate equal to one-twelfth (1/12) of the annual percentage multiplied by the Billable Balance on the last day of the preceding calendar month. Separate Written Disclosure. The specific solicitor/co-adviser fee rate applicable to each client's account are set forth in a Separate Written Disclosure document attached to the client's IMA. The rates shown in this brochure are maximum rates; actual rates may be lower pursuant to the governing Third Party Fee Agreement. 8 #119-0326 Part 2A of Form ADV Firm Brochure  Termination. Either Adviser or client can terminate an IMA by written notice. Upon termination, client is required to pay all unpaid amounts due Adviser, including a pro-rata fee to the date of termination. For Strategic Solutions accounts, the custodian will deduct fees due from client accounts on the date directed by Adviser. Overdue Fees. Fees not paid when due may accrue interest to the extent permitted by applicable law. Fee Negotiation. Adviser reserves the right to negotiate fees to amounts less than its published fee rate schedule, including the right to offer special rates during promotional periods or to waive all or a part of the fees based on account size or other factors. Rescission Rights. All clients have the right to rescind their IMA without cost within five (5) days of the date of the IMA. IRA accounts have a seven-day rescission period. Any advisory fees paid will be refunded in full upon rescission. The rescission right applies to the total advisory fee (both FPI and solicitor/co-adviser components). Section 5.D – Affiliated Fund Fee Credit (QFC Strategies) What is a QFC Strategy? QFC (Quantified Fee Credit) Strategies invest primarily in the Quantified Funds — a family of mutual funds for which Adviser serves as sub-adviser and receives a sub-advisory fee. Because Adviser earns compensation at the fund level when these funds are used in client accounts, clients using QFC Strategies receive a Fee Credit that reduces fees payable from the client's account. See Item 8.D. Affiliated Fund Fee Credit — How It Works. When Adviser invests in Affiliated Fund Investments within a client's portfolio, Adviser receives a sub-advisory or advisory fee from the Affiliated Funds ranging from 55 to 105 basis points per annum, pro-rated and calculated daily. Adviser applies the resulting Fee Credit as follows: • First, the Fee Credit offsets Adviser's own (FPI) retained advisory fee. To the extent the Credit equals or exceeds FPI's fee for the period, no FPI advisory fee is billed to the client. • Second, to the extent the Fee Credit exceeds FPI's advisory fee for the period, Adviser uses the remaining excess to pay a portion of the solicitor or co-adviser fee on the client's behalf — funding that payment from its own sub-advisory income. In this way, the client receives the full benefit of the Credit regardless of which fee component it offsets. • The solicitor or co-adviser earns its agreed flat rate in full — it is not reduced by this mechanism. The Fee Credit is intended to reduce, but may not eliminate, the conflict of interest created by Adviser's receipt of compensation at the fund level. The amount of the Credit may vary based on assets under management in the Affiliated Funds. In certain QFC-only programs (select third-party and retirement platforms), Adviser may structure its advisory compensation so that no separate advisory fee is charged in excess of the affiliated fund compensation received. In such cases, clients indirectly bear fund-level expenses as an internal cost of the funds held in their account. QFC Fee Waiver. Adviser will waive its portion of the Advisory Fee on QFC Strategy investments in excess of the Affiliated Fund Fee Credit if, within a single account, any portion is: (1) invested solely in QFC Strategies in an amount ≥ $150,000; or (2) invested solely in QFC Turnkey Strategies (Multi-Strategy Core and Multi-Strategy Explore) in an amount ≥ $100,000. Starting April 1, 2021, the $100k/$150k waiver extends to household accounts. For FundLink, Adviser will waive its fee if any portion is invested solely in the Alpha Beta Combo QFC strategy in an amount ≥ $500,000. Even where FPI's advisory fee is waived to zero, the client remains subject to the solicitor/co-adviser fee and any platform administration fees — except to the extent Adviser applies excess Credit to those fees as described above. Section 5.E – Program-Specific Fee Details Fee Structure Overview. For most programs, the total advisory fee consists of two components: • FPI Advisory Fee: Adviser's retained fee, tiered by account size — decreases as balance grows. • Financial Adviser Compensation (Solicitor or Co-Adviser Fee): A flat annual rate selected by the financial adviser within ranges set by the applicable Third Party Fee Agreement. Does not change with account size. Collected by Adviser and passed through to the financial adviser's firm. Financial advisers are never paid directly by Adviser. All fees are annual maximums before any Affiliated Fund Fee Credit. The total advisory fee is a blended percentage based on the client's total assets within each tier unless otherwise noted. 9 #119-0326 Part 2A of Form ADV Firm Brochure  FFS Advisory Fee Schedule Applies to most SMA accounts under a Third-Party Fee Agreement that includes the Flexible Fee Schedule. All amounts before any Affiliated Fund Credit. Size of Account Maximum Total Annual Fee FPI Advisory Fee (Annual, Tiered) Financial Adviser Compensation (Annual, Flat — set by adviser) Up to $500,000 1.00% 0% – 1.25% 2.25% Next $500,001–$999,999 0.75% 0% – 1.25% 2.00% $1,000,000 and up 0.35% 0% – 1.25% 1.60% The solicitor fee is a flat rate selected by the financial adviser — the same rate applies regardless of account tier. The specific rate for each client is in the Separate Written Disclosure. Non-FFS Advisory Fee Schedule (Legacy Accounts) Applies to SMA accounts under Third-Party Fee Agreements predating the FFS that have not been converted. The solicitor fee is fixed by the original Third-Party Fee Agreement at a rate equal to the FPI fee for each tier. All amounts before any Affiliated Fund Credit. Size of Account Maximum Total Annual Fee FPI Advisory Fee (Annual, Tiered) Financial Adviser Compensation (Annual, Flat — set by adviser) Up to $500,000 1.00% 2.00% Fixed at 1.00% (per agreement) Next $500,001–$999,999 0.75% 1.50% Fixed at 0.75% (per agreement) $1,000,000 and up 0.35% 0.70% Fixed at 0.35% (per agreement) ETF / Direct Investment Strategy Fee Schedule Applies to SMA accounts investing primarily in ETFs and/or direct securities. Maximum solicitor fee is 1.00% (lower than the 1.25% FFS maximum). Establishment Fees do not apply. Size of Account Maximum Total Annual Fee FPI Advisory Fee (Annual, Tiered) Financial Adviser Compensation (Annual, Flat — set by adviser) Up to $999,999 0.75% 0% – 1.00% 1.75% $1,000,000 and up 0.35% 0% – 1.00% 1.35% FundLink Program Fee Schedule Applies to SMA accounts in the FundLink program (multi-family mutual fund portfolios). Establishment Fees and Small Account Set- Up Fees do not apply. All amounts before any Affiliated Fund Credit. Size of Account Maximum Total Annual Fee FPI Advisory Fee (Annual, Tiered) Financial Adviser Compensation (Annual, Flat — set by adviser) Up to $50,000 0.60% 0% – 1.25% 1.85% Next $50,001–$500,000 0.45% 0% – 1.25% 1.70% 1.65% Next $500,001–$999,000 0.40% 0% – 1.25% 1.60% $1,000,000 and up 0.35% 0% – 1.25% 10 #119-0326 Part 2A of Form ADV Firm Brochure  Group Retirement Plan Fee Schedule ("The Flex Plan" and "Strategic Advantage 401k") Applies to employer-sponsored group retirement plan accounts. A single flat rate applies to all sizes; solicitor fee is fixed at 1.00% per plan agreement. Establishment Fees and Small Account Set-Up Fees do not apply. All amounts before any Affiliated Fund Credit. Size of Account Maximum Total Annual Fee FPI Advisory Fee (Annual, Tiered) Financial Adviser Compensation (Annual, Flat — set by adviser) All sizes 0.75% 1.75% Fixed at 1.00% (per plan agreement) Fees are determined by negotiation with the employer sponsor. The same rates apply to all participants in a given plan. Orphaned House Accounts Occasionally the third-party firm abandons a client account. After notice to the third party and communication to the client of any fee changes, the following structure applies. There is no solicitor fee because that relationship has ended. All amounts are before any Affiliated Fund Credit. Size of Account FPI Advisory Fee FPI Servicing Fee Solicitor Fee Maximum Total Annual Fee Up to $500,000 1.00% 0.50% None 1.50% Next $500,001–$999,999 0.75% 0.50% None 1.25% $1,000,000 and up 0.35% 0.50% None 0.85% The FPI Servicing Fee reflects Adviser's assumption of some client relationship responsibilities previously performed by the solicitor. Clients will receive advance notice and updated disclosure. Small Account Set-Up Fee and Advisory Fee Applies to accounts established with an initial balance of less than $25,000. Account Type FPI Advisory Fee (Flat — all sizes) Combined Cap (any 12- month period) FPI Small Account Set-up fee Financial Adviser Compensation (Flat) 2.00% Small Accounts (Initial balance < $25,000) Lesser of $350 or 3% 0.25% per quarter in arrears 0% – 0.25% per quarter in arrears Set-Up Fee. For all accounts established with an initial balance of less than $25,000, a non-refundable administrative Set-Up Fee to offset advisory and administrative costs is charged, upon the establishment of the account, in an amount equal to the lesser of 3% of the initial balance of the account (the "Approx $" amount indicated in client's Investment Management Agreement) or $350. No portion of the Set-Up Fee is paid to the Solicitor or Co-Adviser. At Adviser’s discretion the Set-Up Fee may be paid by client in the form of a check or by deduction from client’s Account by the Custodian after establishment of client’s Account. The fee will be remitted to Adviser. For purposes of determining the applicability of this Fee to client’s account and the total Account Set-Up Fee due, Adviser, in its sole discretion, and regardless of the initial balance at the time of establishment, may at any time determine and/or re-determine the “initial balance” of any client’s account in the event that post-establishment additions to or withdrawals from the account by client are made during the period from account establishment to the last day of the fourth full calendar quarter following establishment. The provision of Adviser's management to Small Accounts may be subject to certain procedural rules that Adviser may periodically publish, which may result in costs to client and termination of the account at Adviser's discretion. Advisory Fees on Small Accounts. Advisory fees for Small Accounts follow the same FFS or Non-FFS fee schedule applicable to other SMA accounts, subject to a maximum solicitor or co-advisory fee of 1.00% per annum. Additionally, the Advisory Services fee rate shall not exceed 2.0% for any tier of Billable Balance of any account with respect to which a Small Account Set-up Fee is payable. The Establishment Fee does not apply to Small Accounts and may not be charged in lieu of or in addition to the Set-Up Fee. 11 #119-0326 Part 2A of Form ADV Firm Brochure  Donor Advised Fund (DAF) Program Advisory fees for DAF accounts follow the same FFS or Non-FFS fee schedule applicable to other SMA accounts, subject to a maximum solicitor or co-advisory fee of 1.00% per annum. In addition, DAF accounts are subject to NCE Administrative Fees as set forth. NCE Administrative Fee. DAF program clients are also subject to Administrative Fees payable to the DAF Sponsor (National Charitable Endowment / NCE) as set forth below. These fees are paid to NCE — not to Adviser — and are in addition to the advisory fee described above. Aggregate Amount Contributed Annual Administrative Fee (NCE) First $500,000 0.65%* Next $500,000 0.35% Next $1,500,000 0.25% Next $2,500,000 0.18% Next $5,000,000 0.15% Next $10,000,000 0.12% Above $20,000,000 0.10% * Clients' Annual Administrative Fee rate is determined based on aggregate assets contributed across all program accounts. Each client is subject to a minimum Annual Administrative Fee of $295. Given aggregate program contributions currently in excess of $1,000,000, it is expected that the rate would start at 25 bps for new accounts. Optional Establishment Fee Applicable only to quarterly billing FFS and Non-FFS accounts; not applicable to FundLink, DAF, ETF/Direct Investment, Small Accounts or accounts where the client has incurred a sales commission at account initiation. Not available to Co-Advisers. All accounts established with an initial balance of $25,000 or more and for which the client has not incurred a sales commission may be charged a single, non-refundable Establishment Fee of up to 1.20% of the initial investment. Of this fee, 0.20% is paid to Adviser (FPI) and up to 1.00% is paid to the Solicitor. The total of the Establishment Fee and the Advisory Fee payable during the first 12 months may not exceed 3% of the applicable balance. Paper Delivery Fee For accounts other than Group Retirement Plan and SDBA accounts, all communications from Adviser will be transmitted electronically. If a client fails to consent to electronic delivery, a paper delivery fee of $10/month or $30/quarter applies. This fee may be waived for accounts with a net investment value of at least $100,000. Platform Asset Management Advisory Fee Adviser provides asset management services on many third-party platforms without direct client contact. Fees may differ between platforms for similarly named services. QFC Strategies on Platforms. Offered at an advisory fee equal to the Affiliated Fund Credit earned on the strategy — no additional advisory fee billed to the client. Clients indirectly bear fund-level expenses. ETF SMA Strategies on Platforms. Subject to a management fee contracted by Adviser with the platform. All fees are billed to the client by the platform. Clients and their agents are urged to consult with the platform for strategy descriptions, fees, and available services. SDBA Accounts (Investor Class and Adviser Class) SDBA clients are not subject to a separate Advisory fee in excess of the Affiliated Fund Fee Credit. Adviser's compensation is received through sub-advisory fees on Affiliated Fund investments. See Section 5.D and Item 8.I. For Adviser Class SDBA accounts, see the Payment Agent arrangement in Section 5.F. 12 #119-0326 Part 2A of Form ADV Firm Brochure  Section 5.F – Additional Fee Considerations It should be noted that all Investments, whether managed by the Adviser or not, incur expenses, which are paid from fund assets. Such expenses include, without limitation, investment advisory fees, charges by certain Investments of 12b-1, revenue sharing, administrative or shareholder servicing fees, or certain other fees, all of which reduce the Net Asset Value (NAV) of the Investments on a continuing basis. In addition, variable annuities and variable life insurance charge other expenses in the same manner, including mortality charges. All such fees and expenses are reflected in the value of the fund's shares and are therefore indirectly incurred by clients in addition to the fees detailed above. From time to time such 12b-1, revenue sharing, administrative or servicing fees may be available to the product provider or the Custodian. Adviser does not retain 12b-1, revenue sharing or administrative fees; however, Adviser may receive shareholder servicing fees, and does receive its sub-advisory fee, payable by the Quantified Funds when such funds are utilized. In such event, any and all such fees to which Custodian or product provider may be entitled are either, on a dollar- for-dollar basis, applied to and offset custodial, other third-party expenses and obligations, or advisory fees, or are simply retained by the Custodian. Although these fees are internal expenses of the funds, they are ultimately a cost to the investor. No such fees are collected directly by Adviser with the exception of Security Benefit Life Insurance Company's AdvisorDesigns, AdvanceDesigns, EliteDesigns, and EliteDesigns II variable annuity products, which pay Adviser a 25 basis point annual fee. Adviser and Affiliated Advisor Share Class Fund Distributor (“Fund Distributor”) entered into a Payment Agent agreement in which, in part, Adviser will forward payments from the Fund Distributor, on behalf of the respective fund, to broker/dealers who offer, sell or promote shares of the Funds, under the terms of which Adviser will pay to client’s financial representative a marketing fee of 60 basis points, on behalf of the Fund Distributor, for the use of Advisor Class shares in Adviser’s FlexPlan Strategic investment strategy. See discussion of SDBA Program in the Investment Strategies section, below. Some Investments pay a portion of their administrative, management or certain other fees to the custodian of client’s account in recognition of the fact that the custodian is incurring certain service costs for the benefit of the fund. In such instances, the custodian handles transfer functions, shareholder servicing, sub-accounting and tax reporting functions that the fund would otherwise have to provide. Any such amounts payable on fund positions held in client accounts at the custodian that are directed to the custodian are retained by the custodian. Mutual fund investors on many platforms and custodians may be limited to being able to invest only in the funds available on the platform utilized. In most cases, these funds pay the platforms or custodians 12b-1 and sub-TA fees that concomitantly increase the expenses of the fund and reduce investor returns. clients should check with their financial advisor to determine the charges applicable to their Investments. Additional Fees-Axos. Axos charges $20.00 per requested next-day mail service, $25.00 per returned/cancelled check, $50.00 full transfer out fee, and $5.00 per account, per statement for paper statements. There are additional fees levied by Axos dependent on the type of account, investment, and transaction. Solo 401(k) accounts have separate and distinct fees as follows: Annual Maintenance Fee, $200 charged at a rate of $50 per quarter; Loans, $100 loan origination fee per loan; additional contractual fees. All of the additional fees described in this paragraph are payable by client and are not included in Adviser’s fees. Adviser utilizes the services of many unaffiliated investment custodians, including trust companies, brokerage platforms, and insurance companies. Accordingly, Adviser’s strategies are constrained to the investment choices available on the custodians’ platform as well as the custodians’ fee structure, including custodial fees. Therefore, each custodian is unique in regard to the class and type of funds on their platform, as well as their fee structure. Generally, there are two custodial platform models: 1) platforms that charge a custody fee and do not limit investment choices to funds that have 12b-1 expenses but still have some funds available that are only available with 12b-1 expense (the Quantified Funds). Trust companies generally fall into this model. 2) Platforms that charge the funds to be on their platform and offer few, if any, non-12b-1 funds to choose from but do not charge a custody fee. Adviser does not directly, or indirectly, benefit as a result of the client’s selection of a custodial model or a specific custodian. Adviser does not retain 12b-1, revenue sharing or administrative fees; however, Adviser may receive shareholder servicing fees, and does receive its sub-advisory fee, payable by the Quantified Funds when such funds are utilized. In such event, any and all such fees to which Custodian or product provider may be entitled are either, on a dollar-for-dollar basis, applied to and offset custodial, other third-party expenses and obligations, or advisory fees, or are simply retained by the Custodian. Although these fees are internal expenses of the funds, they are ultimately a cost to the investor. Although the choice of the custodian platform is made by the client, the availability of strategies that can be implemented by Adviser on the various custodial platforms is influenced by each platform’s trading and service capabilities, total costs and limitations on trading and other incidental costs. Consequently, investment performance may vary between investment platforms. Adviser offers ETF trading strategies on some platforms. While the choice of ETF and/or mutual fund trading is one made by the client, (and often is controlled by the availability of a desired strategy that may or may not be available in both formats), it should be noted that ETF trading: 1) does not carry with it either 12(b)1 costs and issues discussed above; does not include the availability of sub-advisory fee fund credits; may be restricted to larger accounts where fractional shares are not available; and may be charged 13 #119-0326 Part 2A of Form ADV Firm Brochure  custodial fees. Clients are urged to discuss their choice of mutual fund versus ETF trading and the fee structure of the various platforms with their financial adviser before opening an account with Adviser. Total costs of the program, the availability of particular strategies or Investments, and the allowable frequency of trading, among other factors, are all affected by the choice made. Custody at EAS. Pursuant to the 2020 Agreement under the prior custodian, E*TRADE Advisor Services (“EAS”), Strategic Solutions strategies will have no restrictions on mutual fund or ETF selection. This agreement continues in place with Axos, subsequent to its purchase of EAS from Morgan Stanley. Client accounts in different strategies and with different platforms and custodians are necessarily impacted differently with respect to internal fund expenses. This is because all strategies rely on the selection of funds or ETFs available on the platform or custodian which may be from different providers with different internal fund expenses; therefore, the internal fund cost between strategies and risk profiles thereof will differ depending on the funds being held by each particular strategy or risk profile at a particular custodian or platform at any given point in time. However, the internal fund expenses of any client within a given strategy or risk profile trading with the same platform or Custodian will be the same as any other client trading with the same platform or Custodian within such strategy or risk profile at the same time. Custody on other platforms. Schwab, Fidelity, and other custodians do not charge separately for custody but the NTF funds and ETFs used may have higher internal expenses in order to pay the custodian to be available on their platform. These expenses may be equal to 40 basis points or more per year. Non-NTF funds or ETFs may be available on these platforms with lower expense ratios, however trading them may incur transaction expenses deemed cost prohibitive for the active strategies offered by Adviser. While Adviser seeks to use the NTF funds for its trading, unless noted otherwise herein, clients may request the use of non-NTF funds and assume any added trading costs that may be incurred on these platforms. Custody fees are charged separately and are paid by the client. Section 5.G – Annuity-Specific Fee Considerations Taxable Distributions from Annuities (Advisory Fees). Clients should be aware that the IRS has taken a position in at least one private letter ruling that payments of advisory fees directly from an individual annuity (as opposed to an annuity that is part of a tax- qualified plan) constitute taxable distributions. While it may be contended that the payments are an expense rather than a distribution (a position conceded by the IRS in a subsequent private letter ruling), in the event the IRS is successful in establishing that a fee payment is a distribution, the contract owner would be liable for federal income tax on the amount and might also incur interest, a 10% early distribution penalty if under age 59½, and additional costs. Adviser does not give legal or tax advice and clients are urged to consult their own tax advisers. The IRS has also taken the position in subsequent private letter rulings to a select group of variable, fixed indexed, or hybrid non- qualified individual annuity providers that the payment of such fees may not produce a taxable distribution up to 1.5% of the contract value. Payments to Adviser may exceed such amounts and clients should consult their tax advisers. Section 5.H – Fee Comparison Disclosure Clients should understand that fees and expenses associated with Adviser’s programs may be higher or lower than those available through other advisers or through direct investment in mutual funds without advisory services. For example, a client might purchase mutual fund shares directly from the mutual fund with no front-end cost, placing reliance solely on the investment advisers to the specific mutual fund and the fund's custodian. In such case, the fees of the Solicitor, Co-Adviser, Sponsor, and Custodian would be avoided. Grandfathered Fee Schedules. Fee schedules applicable to accounts established under prior rate structures are set forth in Appendix A. Appendix A applies only to clients currently billed under those historical arrangements; these rates are not offered to new accounts. If you are unsure which fee schedule applies to your account, please refer to your most recent invoice or contact the Compliance Department at 800-347-3539. Item 6 – Performance-Based Fees and Side-By-Side Management Adviser does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). As Adviser manages client accounts utilizing the same or substantially similar investment strategies, trades executed in the same strategy on the same day are allocated on a pro-rata basis. Adviser does not manage any proprietary accounts alongside client accounts. 14 #119-0326 Part 2A of Form ADV Firm Brochure  Item 7 – Types of Clients Section 7.A – Who Is FPI's Client? Depending on the program through which you invest, you may be Adviser's direct advisory client, or you may be an investor in a program where Adviser's counterparty is a platform, plan sponsor, or other institutional entity. The following clarifies what Adviser's client relationship means practically: Question Answer Who receives this brochure and updates? Investors who are direct IMA clients of Adviser receive this brochure and material change notifications directly. Platform and model clients receive disclosure through their platform or plan sponsor. Who the contracting party is? If you have signed an IMA directly with Flexible Plan Investments, Ltd., you are a direct advisory client. If your account is on a third-party platform or retirement plan, the platform or plan is Adviser's counterparty. Who has authority to give investment instructions? Direct IMA clients give instructions through their IMA and suitability questionnaire. Platform- resident investors give instructions through the platform's participant account management agreement. Where to direct complaints or questions? All investors — whether direct or platform clients — may contact FPI's Compliance Department at 800-347-3539 or gsmith@flexibleplan.com. Which agreement governs? For direct IMA clients, the IMA governs Adviser's obligations. For platform and model relationships, the agreement between Adviser and the platform governs. Section 7.B – Client Types Adviser provides investment advisory services to individuals, high net worth individuals, investment companies including mutual funds, corporate pension and profit-sharing plans, other investment advisers, other business entities, charitable organizations, state or municipal government entities, and other institutional investors. Adviser also operates in the capacity of a TAMP providing services to other registered investment advisers and broker-dealers and their clients, and as a platform or model provider to various retirement plan platforms and broker-dealer platforms. Section 7.C – Account Minimums Program Minimum to Open and Maintain All programs (standard) $25,000 Group Retirement Plans (participant accounts) No minimum Small Accounts Program ($5,000–$24,999) $5,000 $15,000 Strategic Solutions / Nationwide Advisory Solutions Monument VA $100,000 Investor Class Self-Directed Brokerage Accounts at Fidelity BrokerageLink Donor Advised Fund Program $50,000 Common Ground Direct Investment $500,000 Targeted Yield Income Distribution Service (TYDS) $250,000 Targeted Income Distribution Service (TIDS) $250,000 15 #119-0326 Part 2A of Form ADV Firm Brochure  Adviser reserves the right to waive account minimums in its discretion. Minimums may be waived based on factors such as related household accounts, anticipated growth, or other circumstances at Adviser's discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Section 8.A –Overview and Navigation Guide This item describes how Adviser analyzes investments, the strategies it offers, and the risks of loss associated with those strategies. Item 8 is organized into the following sections: Section Contents 8.A Overview — this navigation guide and the Strategy Key 8.B Top Risks at a Glance —summary of the most significant risks before you read the strategy descriptions 8.C Investment Analysis — how Adviser analyzes securities and constructs portfolios 8.D Methodologies — Adviser's proprietary methodologies (Evolution, TVA, Regime Overlays, QFC) 8.E Operational Provisions — how strategies are offered, platform limitations, combination rules 8.F Turnkey (Core) Strategies — multi-strategy turnkey portfolios (QFC MSC, MSE, MSP, Symphony, FlexPlan Strategic) 8.G Other Core Strategies — suitability-based core strategies including All Terrain suite 8.H Single Strategy Explore Strategies — 30+ individual explore strategies with Key Risks bullets 8.I Special Programs — SDBA (Investor & Adviser Class), DAF Program, TYDS, TIDS, Rebalancing, Group Retirement Plans 8.J Proprietary Funds Table — sub-advised Affiliated Funds with contact information 8.K Platform Availability Table — strategy availability by platform and custodian 8.L Consolidated Risk Factors — unified risk disclosures from three Draft 3.4 locations, plus new Cybersecurity/Technology Risk Strategy Key The following terms are used throughout this Item to classify strategies. Understanding these distinctions will help you interpret the strategy descriptions below: Term Definition Core Strategy A strategy designed to serve as the primary or substantial holding in a client's portfolio, typically representing 65% or more of invested assets. Core strategies are designed to provide diversified, risk-managed exposure across market conditions. Explore Strategy A strategy intended to supplement a diversified portfolio rather than serve as a standalone investment. Explore strategies are not intended to be primary holdings and generally concentrate in specific markets or techniques. Tactical Allocation A strategy that adjusts portfolio allocations based on market conditions, typically moving between equity and defensive positions (such as money market funds or short-term bonds). Dynamic Allocation A strategy that continuously adjusts portfolio allocations across multiple asset classes based on quantitative signals such as momentum, volatility, and correlation. QFC Strategy A strategy that invests primarily or exclusively in the Quantified Funds — mutual funds sub- advised by Adviser — to implement a given strategy methodology. QFC Strategies generate an Affiliated Fund Fee Credit. See Item 5.D. Turnkey Strategy A multi-strategy portfolio that blends multiple individual strategies or funds into a single suitability-profiled offering, providing multiple layers of diversification. 16 #119-0326 Part 2A of Form ADV Firm Brochure  Section 8.B – Top Risks Before reviewing the strategy descriptions below, please understand these key risks. Full descriptions appear in Section 8.L (Consolidated Risk Factors). Risk Description You can lose money. All strategies described in this brochure involve the risk of loss of principal. Past performance does not guarantee future results. Active management may underperform. Adviser's quantitative strategies may underperform their benchmarks or a buy-and-hold approach during any given period. Leverage amplifies gains and losses. Many strategies use leveraged and inverse funds. Leveraged positions can double or more your exposure to market movements — including losses. Affiliated Fund conflict of interest. QFC Strategies invest in mutual funds sub-advised by Adviser. Adviser receives a sub- advisory fee from these funds, creating a conflict of interest. See Items 5.D and 10. Sub-adviser risk. Several strategies rely on buy/sell signals from third-party sub-advisers (DWM, Hg Capital, PCM, GVCM, AIM, STF Management). Adviser is responsible for executing those signals but does not independently validate them in real time. Platform differences. The same strategy name may produce different results on different platforms due to available investments, trading restrictions, and execution timing. Mutual funds and variable annuity sub-accounts may impose redemption restrictions. Strategy changes may take several days to implement. See Section 8.L. Trading restrictions and delays. Client-initiated strategy changes are processed on a once-per-week schedule and may not be implemented immediately. Strategy changes implemented weekly for non-systematic changes. Adviser relies on third-party data, software, and platforms. Systems may fail or be disrupted. See Section 8.L and the Cybersecurity Disclosure in End Matter. Cybersecurity and technology risk. Section 8.C – Investment Security Analysis Adviser may utilize both fundamental and technical factors in its security analysis. Adviser utilizes a number of indicators, factors, and statistics in creating investment selections for its strategy. These include but are not limited to trend analysis, price momentum indicators, volatility indicators, relative strength indices, moving averages, and other technical and fundamental analysis. The technical indicators utilized by Adviser generate, for the most part, short-term gains or losses for tax purposes. However, market conditions may result in long-term gains or losses being generated from time to time. Adviser employs mathematical, technical, and fundamental models and indicators, most of which are proprietary, in the management of clients' investments. The goal of Adviser's strategies generally is to seek returns that exceed inflation (as measured by the Consumer Price Index) and certain conservative fixed income alternatives over a full market cycle; (ii) seek to manage portfolio volatility relative to applicable referenced indexes, as measured by Beta, Standard Deviation or Ulcer Index; and (iii) attempt to improve risk-adjusted returns relative to a passive buy-and-hold approach in the Investments. These are long-term objectives requiring a full market cycle, including a 20%-plus bull and bear market and usually lasting 4 to 7 years, to evaluate. There can be no assurance that any of these objectives will be achieved. Client should consider these objectives in light of the total fees and expenses described in Item 5, as higher overall costs may reduce net returns. Investing in securities involves risk of loss, including the possible loss of principal. Past performance is not indicative of future results. Clients should be prepared to bear the risk of loss consistent with their selected strategy 17 #119-0326 Part 2A of Form ADV Firm Brochure  Section 8.D – Investment Methodologies Generally. Adviser is a quantitative asset management firm employing methodologies known as tactical asset allocation and dynamic asset allocation. Adviser uses the term 'market timing' to describe short-term trading practices designed to exploit stale prices in mutual funds and similar instruments, which Adviser does not engage in. Adviser's strategies are signal-driven and rules-based. Enhancements have been made in the methodologies from time to time, which are believed to have a positive effect on returns or are intended to improve risk management or implementation efficiency. The number of these enhancements is not precisely quantifiable, but as the strategy actual buy and sell signals are used, the effect of these enhancements is reflected in the strategy performance. Efforts to develop indicators are ongoing and may result in further changes. There is no assurance that such enhancements will result in improved performance. QFC Strategies. Several strategies are offered in QFC and non-QFC versions (see Table below). The differences between the versions may include trading universe, trading frequency and costs. QFC Strategies primarily utilize the sub-advised Quantified Funds to implement the designated QFC Strategy methodology. Since these funds are sub-advised by Adviser, they are referred to as Affiliated or Proprietary Funds. Adviser receives compensation in its capacity as sub-adviser to these Funds. Although clients receive an Affiliated Fund Fee Credit as described in Item 5, the use of proprietary funds creates a conflict of interest because Adviser has an incentive to allocate assets to funds from which it receives compensation. Please see Item 5 for additional information regarding this conflict and the related fee credit. QFC Strategies offer investors two levels of dynamic risk management: (1) the management within the Quantified Funds and (2) the allocation/rebalancing we do among the Quantified Funds within the QFC Strategies. Because these strategies utilize proprietary funds, clients indirectly bear the operating expenses of the Funds in addition to advisory fees described in Item 5. Although Affiliated Fund Fee Credits may offset a portion of advisory fees, total expenses may be higher than if non-affiliated investments were used. The presence of multiple management layers may increase complexity and does not assure improved performance or reduced risk. Evolution Asset Allocation Methodology. Many of Adviser's strategies employ the Evolution Asset Allocation Methodology. This proprietary methodology creates portfolios by evaluating each selected security's price momentum, volatility, correlation, and other factors to create optimally weighted allocations. The methodology is applied across multiple timeframes and is updated on a systematic basis. Evolution may be used to invest in a broad range of investments, including, without limitation, domestic and international bonds and equities, style box investments, leveraged index funds, sector funds, precious metals equities and futures, inverse funds, money market instruments, and income investments (any of which may be within funds for which we serve as sub-adviser). Its investment selections depend on our determination of which market segment or segments have, at any given time, the highest appreciation potential consistent with a level of risk we deem acceptable. Due to the active management and multi-strategy diversification occurring within strategies, we may characterize certain of our strategies as having low to moderate risk relative to traditional long-only equity benchmarks over a full market cycle, even though they may utilize investments that normally carry higher risk profiles, such as, without limitation, leveraged or inverse investment vehicles. The use of such instruments may increase volatility, tracking error, and potential losses, particularly over shorted time periods. Targeted Volatility Analysis (TVA). TVA is a proprietary methodology that attempts to target a volatility level for a portfolio based on its historic standard deviation of daily returns as determined by Adviser by combining a risky asset and a defensive asset in proportions calculated to achieve the target volatility. If the current historical volatility of the risky asset is above the pre-determined targeted volatility, then it will increase the exposure to the less risky asset to lower the volatility of the overall portfolio. Regime Overlays. Adviser may at times use regime overlays and regime investing to guide our allocation systems. Regime Investing is the use of market information (financial and econometric) to determine the current investment environment that may affect the return profiles of major asset classes. Adviser then uses this information to better inform our investment allocations via adapting our algorithms to the current regime stage or by disabling certain components of our strategies. This approach is a result of an evolution of Adviser’s active management philosophy. In the event the regime overlay is applied, the results from trading the strategy will likely be different from the original strategy without the overlay. These results could be better or worse. While internal research may support the use of regime overlays, there is no guarantee that such overlays will improve future results. Allocation decisions resulting from regime 18 #119-0326 Part 2A of Form ADV Firm Brochure  overlays are based solely on quantitative criteria and are not influenced by differential compensation Adviser may receive from affiliated funds. See Section 8.L. Defensive Investments. Most strategies offered by FPI utilize defensive investments from time to time. Descriptions of strategy methodologies may reference allocations to cash or bonds when discussing defensive actions which may be taken. Regardless of such terminology, FPI may use gold, commodity, alternative strategies, bond and money market Investments or a blend of these Investments when taking defensive positions in any of its strategies. Such investments may be more volatile than a money market investment. INVESTMENT STRATEGIES Adviser generally offers separately managed mutual fund, variable annuity, variable universal life, or ETF accounts that utilize its Strategic Solutions strategies. Similarly, Adviser may provide timing and allocation signals to various platforms maintained by other advisors, TAMPS, broker/dealers, retirement accounts and custodians. The strategies offered may vary by the platform chosen by the client and their financial advisor for the application of the Adviser’s strategies to the client’s account. The ultimate choice of the strategy or combination of strategies used by a client is a matter of choice of the financial advisor and/or client. FPI follows the directions of same in managing a client account. 19 #119-0326 Part 2A of Form ADV Firm Brochure  The following table is an overview of strategy characteristics and platform availability: May Use Precious Metal Investments May Use International Investments May Use Leveraged Investments Available at Monument Advisor Available at Other Custodian(s) May Use Inverse Investments Not Available to New Clients May Use Proprietary Funds May Use Bitcoin Futures # of Suitability Profiles Sub-adviser Utilized Strategy Minimum Available at Axos March 31, 2026 ● ● ● ○ ○ ● ● ● ● ● ● ● ● ● ● ● ● ● ◊ ◊ ○ ○ ○ ● ● ● ● ● ● ● ● ● ● ○ ● ● ● ◊ ◊ ◊ ◊ ◊ ○ ● ○ ○ ○ ○ ○ ○ ● ○ ◊ ◊ ● * ● ● ● ● ● ● ● ● ○ ○ ● ● ● ● ● ● ● ● ● ● ○ ○ ● ○ ○ ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ○ ○ ● ● ● ● ● ● ● ● ● ○ ● ● ● ● ● ○ ○ ● ◊ ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ○ ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ○ ● ● ○ ◊ ● ● ● ● ● ◊ ◊ ○ ● ● ● ● ● ● ● ● ● ● ● ● ● All-Terrain Aggressive - Trivantage Leveraged All-Terrain Balanced - Trivantage All-Terrain Conservative - Dynamic All-Terrrain Growth - Dynamic Leveraged All-Terrain Moderate - Static ASI Aggressive Sector ETF Rotation ASI Aggressive Sector Fund Rotation ASI Factor ETF Rotation ASI Global Income ETF Rotation ASI Income ETF Rotation ASI International ETF Rotation ASI Lone Star ETF Rotation ASI Sector ETF Rotation ASI Sector Fund Rotation ASI Style ETF Rotation Classic Classic Better World Classic Faith Focused Common Ground BRI/SRI - Direct Investing Contrarian S&P Trading Evolution Evolution Emerging Markets Evolution II Evolution Plus Evolution Tactical FlexDirex Single-Stock ETF Strategy: Focused Core FlexDirex Single-Stock ETF Strategy: Tech Plus FlexPlan Strategic For A Better World FundLink Alpha Beta Combo FundLink Classic FundLink Evolution Global Macro Equity - Tactical Global Macro Income - Tactical Global Maturities Global Select Global View Portfolio Strategies (Only Avail at GVCM) Government Income Tactical High Yield Tactical Lifetime Evolution Low Volatility Rising Dividends Managed Income Managed Money Market Market Leaders Sector Growth Market Leaders Sector Growth Ultra Market Leaders Strategic Market Leaders Tactical Municipal Rotation QFC All Terrain QFC Classic QFC Classic Better World QFC Classic Faith Focused QFC Common Ground BRI/SRI QFC Diversified Tactical Equity QFC Dynamic Trends 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 5 5 1 1 5 3 4 1 4 1 1 1 1 7 1 1 5 1 1 1 1 1 5 5 1 5 1 1 1 5 1 1 ◊ ● ● ● ● ● ● ● ○ ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $500k $5k $5k $5k $5k $5k $5k $25k $25k $25k $5k $25k $25k $25k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k ● - Available in No-Load Mutual Funds ○ - Available in ETFs ◊ - Available in No-Load Mutual Funds and/or ETFs * - Available with individual securities 20 #119-0326 Part 2A of Form ADV Firm Brochure  May Use Precious Metal Investments May Use International Investments May Use Leveraged Investments Available at Monument Advisor Available at Other Custodian(s) May Use Inverse Investments Not Available to New Clients May Use Proprietary Funds May Use Bitcoin Futures # of Suitability Profiles Sub-adviser Utilized Strategy Minimum Available at Axos March 31, 2026 ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ○ ○ ◊ ● ● ● ● ● ● ◊ ● ● ● ● ● ● ● ● ● ● ● ● ● ○ ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● ● QFC Evolution Plus QFC Faith Focused Investing QFC For A Better World QFC Global Managed Equity QFC Government Income Tactical QFC High Yield Tactical QFC Lifetime Evolution QFC Liquid Alternatives QFC Low Volatility Rising Dividends QFC Managed Futures QFC Managed Income QFC Market Leaders QFC Market Leaders Sector Growth Ultra QFC Multi-Strategy Core QFC Multi-Strategy Explore Blend QFC Multi-Strategy Explore: Equity Trends QFC Multi-Strategy Explore: Low Correlation QFC Multi-Strategy Explore: Low Volatility QFC Multi-Strategy Explore: Special Equity QFC Multi-Strategy Portfolios QFC Political Seasonality Index QFC S&P Pattern Recognition QFC Select Alternatives QFC Self-Adjusting Trend Following QFC Strategic Tactical QFC Symphony QFC Systematic Advantage QFC Tactical Bond QFC TVA Gold Select Alternatives Self-adjusting Trend Following Strategic High Yield Bond Systematic Advantage Tactical Bond Tactical Emerging Markets Tactical Unconstrained Growth (TUG) Targeted Income Distribution Service Targeted-Yield Distribution Service Balanced TVA Gold Volatility Adjusted NASDAQ Wolfpack WP Income Builder 5 5 3 1 1 1 5 1 1 1 1 5 1 5 1 1 1 1 1 5 1 1 1 1 5 5 1 1 1 1 1 1 1 1 1 1 1 1 1 1 3 1 ● ○ ● ● ○ ● ● ● ● ● ● ● ● ● ● $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $25k $5k $5k $5k $5k $5k $25k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $5k $250k $250k $5k $5k $5k $5k ● ● ● - Available in No-Load Mutual Funds ○ - Available in ETFs ◊ - Available in No-Load Mutual Funds and/or ETFs * - Available with individual securities FURTHER EXPLANATION OF TABLE HIGHLIGHTED RISKS Index and Leveraged Funds (including inverse funds). Investment vehicles utilized include one or more index Investments that are internally designed to have a targeted positive or negative correlation to the underlying index. A positively correlated index Investment is designed to appreciate or depreciate in correlation with the underlying index. A negatively correlated index Investment or "inverse fund" is designed to appreciate in value as the underlying index declines and depreciate when the index increases. In addition, certain index Investments use leverage to achieve a targeted multiple of the performance of the underlying index (leveraged index Investments). These Investments introduce risks, which are in addition to the traditional market risks of equity or income investing. All leveraged index Investments make use of short sales, swaps, options and/or futures contracts (so called derivative investments) to achieve the target leverage (which may result in an increase of volatility and percent movement based on the beta to the referenced index). Certain leveraged funds or products may be held within strategies for long periods of time, thereby compounding the risk of a portfolio. There is no guarantee that these Investments will be able to achieve their stated objectives. Any strategy employing equity 21 #119-0326 Part 2A of Form ADV Firm Brochure  or income Investments may use inverse Investments in implementing the strategy described. Most of these funds seek only to represent index returns on a daily basis. Prolonged use of them may not represent such returns. International Investments. When investing in international securities, the program’s return will be affected by the fluctuating value of the US dollar in relation to foreign currencies and political events in foreign countries. If available and applicable to the strategy chosen by client, Adviser may make substantial allocations of the Investments to international bond and equity Investments, which invest their assets predominately in the shares or obligations of companies organized outside the United States. In addition to traditional measures of performance of individual companies, such Investments may also be substantially impacted by unstable political environments in their country of organization and by foreign currency fluctuations. Implementation of Euro-Currency conversion by members of the European Economic Community has introduced additional risks to Investments with portfolio investments organized or priced in those countries. Foreign taxes and differences in financial and accounting standards from those applicable to U.S. companies introduce additional risks to international Investments. References to global investing or strategies means that these international investments may be combined with U.S. domestic funds. Precious Metals Investments. If available and applicable to the strategy chosen by client, Adviser may also make substantial allocations to precious metals equity Investments which invest their assets predominately in the shares of companies engaged in exploration, recovery, refinement and sale of natural resource commodities such as energy, gold, silver, platinum, and palladium. In addition to traditional measures of performance of individual portfolio companies, such Investments also tend to reflect the changing values of the commodities. Proprietary Funds. Adviser serves as sub-adviser to Advisors Preferred, LLC to provide investment advisory services for selective equity and income mutual funds commonly known as the Quantified Gold Futures Tracking Fund, the Quantified Gold Futures Tracking Portfolio and Quantified Funds. These funds may be utilized to comprise a portion of or a client’s entire portfolio. Each of these funds is aggressively managed and may be “non-diversified,” meaning that a relatively high percentage of each fund’s assets may be invested in a limited number of issuers of securities. Because these funds have disparate objectives and draw from differing underlying security universes, diversification by simultaneous investment among multiple sub-advised funds may have the effect of diminishing the risk of investment in non-diversified funds. Readers should also review “Risk Considerations” below. INVESTMENT STRATEGIES Certain strategies described in this brochure may not be available on all platforms (see Table above). FPI does not recommend strategies or combinations of strategies for specific clients. Instead, FPI can provide illustrations of past strategies or combinations of strategies for review by financial advisors. The ultimate choice of the strategy or combination of strategies used by a client is a matter of choice of the financial advisor and/or client. FPI implements the selected strategy on a discretionary basis but does not provide individualized financial planning or strategy selection advice unless otherwise agreed in writing. However, when strategies are terminated, eliminated from platforms or custodial platforms are changed at the discretion of Adviser, Adviser will notify client and their financial advisor of an automated change and provide a time period to allow client or their financial advisor to elect different action. Section 8.E – Operational Provisions Adviser does not recommend strategies or combinations of strategies for specific clients. Instead, Adviser can provide illustrations of past strategies or combinations of strategies for review by financial advisors. The ultimate choice of the strategy or combination of strategies used by a client is a matter of choice of the financial advisor and/or client. Adviser follows the directions of same in managing a client Account. However, when strategies are terminated, eliminated from platforms, or custodial platforms are changed at the discretion of Adviser, Adviser will notify client and their financial advisor of an automated change and provide a time period to allow client or their financial advisor to elect different action. Combinations of Strategies. Adviser may specifically allow clients from time to time to allocate the values of any one annuity or custodial account in a combination of up to eight (8) of the available investment strategies, dependent on the custodian utilized, with 22 #119-0326 Part 2A of Form ADV Firm Brochure  the exception of the Turnkey Strategies (described above), which are subject to an investment minimum of $5,000 in each strategy within the combination and also to the availability of multiple strategies in client’s variable annuity contract as determined by Adviser. clients are urged to utilize such combinations whenever there are sufficient asset values to meet the $5,000 per strategy minimum. These portfolios are initiated with equal dollars invested in each strategy. As fund values change, the portion invested in each strategy will vary and no longer be equal. No attempt may be made in the course of management of the portfolio to rebalance the strategies. Strategy changes among strategies may require several weeks to complete. Diversification of Strategies. With the exception of the Turnkey and Core strategies, strategies offered are not intended to be exclusive strategies for management of a client's Investments. They are intended in most cases to constitute a part of a diversified investment approach in combination with other low correlated strategies. Multiple strategies may be utilized as a part of a diversified investment approach combining other strategies with differing risk profiles. Consideration should be given to combining lower risk strategies with higher risk strategies in order to seek to reduce the overall risk of these higher risk strategies in client's portfolio. Notwithstanding the selection of multiple portfolios to achieve diversification, the fact that several portfolios may, in part, draw upon substantially similar investment vehicles will, under certain circumstances, result in different portfolios holding the same or similar asset classes. This potential investment concentration in a particular asset class increases risk for the period during which such concentration exists. For example, QFC Lifetime Evolution and QFC Select Alternatives both include precious metals as a potential asset class for investment. As a result of an initial period of market strength in that asset class, these portfolios might both hold precious metals investments. Generally, all of the strategies described are managed by Adviser with the objective of attaining the highest appreciation potential, while seeking to manage risk at a level that Adviser deems acceptable. From time to time Adviser may employ strategies other than the Strategic Solutions strategies in accounts of clients with substantial assets. Generally, these are clients with investment accounts aggregating more than $500,000. These customized strategies are employed after individual consultation among client, client’s Agent and Adviser respecting the individual’s objectives and risk tolerance, and may be employed alone or in combination with one or more of the Strategic Solutions or other custom strategies. Adviser manages each of the Strategic Solutions strategies other than a custom strategy or those specified as including individual securities, by selecting appropriate Investments from a universe of Investments available on a no-transaction fee basis through the Custodian. Adviser manages those strategies by purchasing and redeeming shares of the selected Investments as indicated by its proprietary models and indicators. From time to time Adviser may determine that one or more of the strategies are closed to new investment. In any case, clients who have selected any such strategy will be so advised and provided the opportunity to make alternate selections. In the event that the financial representative of record is no longer associated with a client’s account, for any reason whatsoever, Adviser shall notify said client and may expand its level of service to the client. Adviser shall assume select representations and undertakings, previously the responsibility of the financial representative, as provided in the client’s executed Investment Management Agreement and confirmed and/or expanded upon in the Adviser’s notification communication, as well as, a portion of any compensation provided for therein. In addition, Adviser will: (i) contact client at least annually; (ii) use their best efforts quarterly by notification to determine if client’s investment objectives have changed; and (iii) be available during business hours for consultation with client regarding client’s financial condition and the continued suitability of the strategies for client. Section 8.F – Turnkey (Core) Strategies QFC Turnkey Strategies — General. Turnkey Strategies blend Adviser's dynamic, risk-managed strategies or sub-advised funds to produce suitability-based, multi-strategy portfolios. The Turnkey Strategies offer investors multiple layers of risk management and diversification in a single allocation. 23 #119-0326 Part 2A of Form ADV Firm Brochure  QFC Multi-Strategy Core (MSC). QFC Multi-Strategy Core is a turnkey strategy that allocates among Adviser's Quantified Funds to produce five suitability-based portfolios (Conservative, Moderate, Balanced, Growth, Aggressive) designed to provide a broad base of risk-managed, systematic exposure. QFC Multi-Strategy Explore (MSE). This group of turnkey strategies uses a combination of explore strategies to create multi-strategy portfolios. MSE variants: Low Volatility; Low Correlation; Special Equity; Equity Trends; Blend — each combining QFC Explore strategies for portfolio diversification. QFC Multi-Strategy Portfolios (MSP). QFC MSP combines 65% of the account to the chosen suitability profile of QFC Multi-Strategy Core and 35% to a QFC Multi-Strategy Explore variant, consistent with a level of historical volatility defined by Adviser, creating a blended core/explore portfolio. Our Symphony Model / Symphony Model. Our Symphony Model (also referenced as Symphony Model) is a true strategy of strategies that solely uses FPI's sub-advised Quantified Funds, without the use of additional strategy methodologies. The model is designed to provide exposure to multiple Quantified Funds in suitability-based allocations. FlexPlan Strategic. FlexPlan Strategic harnesses the power of four Quantified Funds in their Adviser share class: Quantified Common Ground Fund; Quantified STF Fund; Quantified Managed Income Fund; and Quantified Eckhardt Managed Futures Strategy Fund. Available exclusively in the Adviser Class SDBA program. Section 8.G – Other Core Strategies All Terrain Suite and QFC All Terrain. This suite of actively managed, suitability-based strategies seeks growth, diversification, and risk management in all market conditions. The five strategies are mapped to suitability profiles as follows: Suitability Profile All Terrain Strategy Conservative All Terrain Conservative - Dynamic Moderate All Terrain Moderate - Static Balanced All Terrain Balanced - Trivantage Growth All Terrain Growth — Dynamic Leveraged Aggressive All Terrain Aggressive - Trivantage Leveraged All Terrain Conservative - Dynamic. All-Weather Dynamic — Unleveraged (renamed All Terrain Conservative - Dynamic) is designed to create a robust portfolio for all market regimes, including periods of high or low GDP growth and high or low inflation. It uses Adviser's regime overlay to allocate dynamically among equity, gold, and income assets. All Terrain Moderate - Static. All-Weather Static (renamed All Terrain Moderate - Static) attempts to create a robust portfolio for all market regimes. Static portfolio allocations are weighted based upon securities' performance in past regime environments. All Terrain Balanced - Trivantage. Trivantage — Unleveraged (renamed All Terrain Balanced - Trivantage) takes advantage of the low historical correlation between equities and gold, while also providing the ability to move between these two asset classes dynamically. 24 #119-0326 Part 2A of Form ADV Firm Brochure  All Terrain Growth — Dynamic Leveraged. All-Weather Dynamic — Leveraged (renamed All Terrain Growth — Dynamic Leveraged) attempts to create a robust portfolio for all market regimes. It is a more aggressive version of the unleveraged All Terrain Conservative - Dynamic, using leveraged funds to amplify potential returns. All Terrain Aggressive - Trivantage Leveraged. Trivantage — Leveraged (renamed All Terrain Aggressive - Trivantage Leveraged) takes full advantage of the low historical correlation between equities and gold, while also providing the ability to move between these two asset classes with leverage. Evolution Plus and QFC Evolution Plus. Evolution Plus is a proprietary, quantitative, asset allocation technology that considers four factors to generate position size and relative asset exposure: asset momentum, asset volatility, cross-asset correlation, and regime overlay. Evolution Plus uses leverage exclusively. QFC Faith Focused Investing. QFC Faith Focused Investing is a dynamic, risk-managed investment strategy applying Adviser's proprietary allocation methodology to a universe of highly rated Judeo-Christian stocks (based on ratings from eVALUEator). The strategy offers clients a 10% charitable donation option on advisory fees. Note: The 10% charitable donation option is a benefit to the client and does not reduce fees paid to Adviser. Adviser's portion of the fee subject to charitable contribution is clarified here for avoidance of doubt. QFC For A Better World and QFC Common Ground BRI/SRI. QFC For A Better World is a dynamic, risk-managed strategy applying Adviser's proprietary allocation methodology to a universe of highly rated SRI stocks (CSRHub ratings). QFC Common Ground BRI/SRI applies the same methodology to S&P 1500 stocks pre- filtered to include only stocks meeting both Judeo-Christian (eVALUEator) and SRI (CSRHub) screens. Common Ground BRI/SRI Direct Investing. QFC Common Ground BRI/SRI Direct Investing applies Adviser's proprietary allocation methodology across a universe pre-filtered to include only stocks meeting both Judeo-Christian (eVALUEator) and SRI (CSRHub) screens, but invests directly in individual stocks rather than through a sub-advised fund. Lifetime Evolution and QFC Lifetime Evolution. Lifetime Evolution utilizes the Evolution Asset Allocation methodology to create five investment profiles based on client suitability. QFC Lifetime Evolution is a dynamically risk-managed version allocated solely among Adviser's sub-advised Quantified Funds. Some funds may use leverage and inverse strategies. Market Leaders Strategic and QFC Market Leaders. Market Leaders Strategic begins with an all-equity portfolio, reallocating monthly into the leading funds of the strongest asset classes and out of lagging funds. Multiple risk profiles available via combination with QFC managed income strategies. QFC Market Leaders is a dynamically risk-managed strategy allocated solely among Adviser's Quantified Funds. QFC Strategic Tactical. QFC Strategic Tactical adjusts exposure between equity and defensive investments based on intermediate-term market trends. When favorable conditions are identified, it allocates up to the maximum allowable equity exposure for the selected risk profile, and shifts toward more defensive positioning during unfavorable market environments. 25 #119-0326 Part 2A of Form ADV Firm Brochure  Section 8.H – Single Strategy Explore Strategies Important: Explore strategies are not designed as standalone primary holdings. They are intended to be used within a diversified portfolio of other strategies and/or asset classes. See Section 8.A (Strategy Taxonomy Key) for the definition of Explore strategies. QFC versions of the following strategies may be available (see Section 8.K). QFC versions seek to approximately implement the described methodology using the Quantified Funds only. Where third-party sub-advisers are involved, the QFC version uses the corresponding Quantified Fund sub-advised to implement that methodology. FundLink Program Strategies. Alpha Beta Combo - FundLink. Alpha Beta Combo - FundLink applies Adviser's proprietary dynamic, risk-managed allocation methodology to both a universe of popular third-party funds and Adviser's QFC Multi-Strategy Portfolios (QFC MSP). It creates a blended alpha/beta strategy. Classic - FundLink. Classic - FundLink applies Adviser's tactical asset-allocation strategy to a universe of popular third-party funds. It is a dynamic model: when the signal is long, the strategy allocates 100% to equity funds; when short, 100% to defensive. Evolution - FundLink. Evolution - FundLink applies Adviser's proprietary dynamic, risk-managed allocation methodology to a universe of third-party funds. The strategy aims to invest in top-performing funds within the equity, bond, and alternative asset classes. All-Terrain Strategies (Single Strategy Explore versions — see Section 8.G for full descriptions and Key Risks). Classic Strategy Group. Classic. Classic is a tactical allocation strategy that Adviser has offered for decades to invest in domestic equity Investments or, in the alternative, in money market and/or other income Investments based upon Adviser's MEI signal. Signal-testing history extends back to 1928. QFC Classic. QFC Classic is a dynamically risk-managed '100% in–100% out' tactical asset-allocation strategy. It invests in sub-advised Quantified Funds to access equity and bond markets, seeking an additional layer of risk management via the QFC methodology. Classic Better World, QFC Classic Better World, Classic Faith Focused, QFC Classic Faith Focused. These Principled Investing strategies each use the same methodology as Classic but apply it to a restricted universe of socially responsible (SRI) funds (Better World variants) or faith-based funds (Faith Focused variants). FlexDirex Single-Stock ETF Strategies. FlexDirex Single-Stock ETF Strategy: Focused Core. FlexDirex Single-Stock ETF Strategy: Focused Core is a diversified, actively managed core strategy that targets a growth portfolio of single-stock ETFs across multiple sectors. It seeks to capture returns from both rising and falling single-stock performance through tactical rotation. 26 #119-0326 Part 2A of Form ADV Firm Brochure  FlexDirex Single-Stock ETF Strategy: Tech Plus. FlexDirex Single-Stock ETF Strategy: Tech Plus is a high-conviction strategy that invests in fast-evolving single-stock ETFs within the technology sector. Designed to capture returns from both rising and falling individual tech stock performance. Sector and Market-Specific Strategies. Contrarian S&P Trading. Active Investment Management (AIM) is a sub-adviser under contract with Adviser and provides all buy and sell directions for this strategy. The strategy is designed to provide market returns while attempting to minimize the risk of long-term drawdowns. It can operate with very low market exposure (historically averaging approximately 24%) and uses leveraged and inverse funds. QFC Diversified Tactical Equity. QFC Diversified Tactical Equity aims to create a robust equity-allocation portfolio of Adviser's equity-based sub-advised Quantified Funds. Tactical equity strategies seek to be in a particular stock sector when it has positive momentum and out when momentum turns negative. Market Leaders Sector Growth Ultra-ETF. This strategy attempts to hold the top-performing sectors of the S&P 500 (excluding Utilities and Consumer Staples) and avoid underperformers through a three-step process: (1) momentum ranking; (2) MEI signal overlay; (3) inverse fund hedge when bearish. QFC Market Leaders Sector Growth Ultra. QFC Market Leaders Sector Growth Ultra is a dynamic, risk-managed sector-allocation strategy that overweights the best-performing equity sectors while reducing exposure to underperforming sectors, implemented through sub-advised Quantified Funds. Market Leaders Sector Growth. Market Leaders Sector Growth actively manages a portfolio of sector investments by identifying neutral, bull, and bear market conditions using the MEI signal. The strategy can move from 100% invested to 100% inverse and employ leverage. Market Leaders Low Volatility/Rising Dividends and QFC Market Leaders Low Volatility/Rising Dividends. This strategy seeks tax efficiency while maintaining risk management through a tactical overlay. It holds a diversified portfolio of domestic and global, large-cap and mid-cap dividend stocks and can employ a 2X inverse equity position when bearish. Municipal Rotation. Municipal Rotation trades funds invested in the municipal bond market. The strategy can invest in funds from any state or U.S. territory and may move into high-yield muni funds and single-state funds. QFC Political Seasonality Index. Adviser's Political Seasonality Index (PSI) strategy analyzes thirteen different political and seasonality factors with daily index data back to 1885. The strategy allocates to equity or defensive positions based on the combined signal. QFC S&P Pattern Recognition. QFC S&P Pattern Recognition seeks a variety of daily mean-reversion patterns in the price direction of the S&P 500 Index. Using incremental trades, the strategy can range from 200% leverage to 200% inverse exposure. Select Alternatives and QFC Select Alternatives. Select Alternatives combines the diversification and liquidity of Investments with alternative investments traditionally available only to hedge funds. It utilizes Investments representative of most hedge fund categories. 27 #119-0326 Part 2A of Form ADV Firm Brochure  Self-Adjusting Trend Following (STF) and QFC Self-Adjusting Trend Following. STF tracks the price action of the NASDAQ 100 Index. STF is an aggressive strategy seeking high rates of return in rising and falling markets. In falling markets it can use inverse funds; in rising markets it can use leveraged funds. Strategic High Yield Bond. ProfitScore Capital Management, Inc. (PCM) is sub-adviser and provides all buy and sell directions. The strategy invests in an actively managed portfolio of high-yield bond mutual funds using PCM's proprietary High Yield Rotation System. • High-yield (junk) bonds carry significant credit risk and are more correlated to equity markets than investment-grade bonds • Defensive movement to money market may lag market turning points Systematic Advantage and QFC Systematic Advantage. Systematic Advantage monitors the status of approximately 80 recognized third-party tactical asset allocation systems and selects the top-performing systems daily using the Evolution methodology. A portion of the account may use a leveraged index Investment. Tactical Emerging Markets. Tactical Emerging Markets actively manages a portfolio of global frontier and emerging markets mutual funds using trend-following, relative-strength, and momentum approaches. Global View Capital Management (GVCM) is sub-adviser. TVA Gold and QFC TVA Gold. TVA Gold trades the Quantified Gold Futures Tracking Portfolio variable annuity sub-account using Adviser's proprietary TVA. TVA uses the precious metal's past volatility to determine the current allocation between gold and a defensive position. Tactical Unconstrained Growth (TUG). TUG is an actively managed strategy designed to pursue long-term growth while managing risk. It seeks to reduce equity exposure when market conditions are unfavorable. STF Management provides all signals. Volatility Adjusted NASDAQ. Applying Adviser's proprietary TVA quantitative methodology to the NASDAQ 100 Index, the strategy evaluates current short-term volatility risk relative to its long-term historical average on a daily basis and adjusts between leveraged and inverse funds. Wolfpack (WP) Strategies. Wolfpack strategies were developed to trade individual market indices using a consortium of active money managers with existing track records (Hg Capital Advisors). The diverse strategies and techniques of the consortium may not always be in agreement, providing a form of diversification. WP Income Builder. PCM is sub-adviser providing all buy and sell directions. Income Builder allocates assets to multiple absolute return investment strategies, all attempting to make profits in all market environments. Global Maturities. Investments are allocated among global and emerging market bond Investments selected from a universe of such funds using the Evolution Asset Allocation methodology. Adviser may utilize leveraged and inverse bond funds. Global Select. Using Adviser's Evolution Asset Allocation methodology, allocations will be made to equity or income Investments classified as global, international, and emerging markets only. Appropriate for growth suitability investors seeking international diversification. 28 #119-0326 Part 2A of Form ADV Firm Brochure  Global Macro Equity-Tactical and Global Macro Income-Tactical. Global Macro Equity-Tactical applies a global macro manager approach across equities (U.S., Developed International, Emerging Markets) and commodities (Precious Metals, Basic Materials, Agriculture) using GVCM signals. Global Macro Income-Tactical utilizes a multiple strategy approach across global income-oriented asset classes. Global View Portfolio Strategies (GPS) — Private Label. GPS is a private-label strategy currently available only to a single solicitor firm. GPS offers seven suitability-based model portfolios in Adviser's Strategic Solutions program and three in certain variable annuity platforms across approximately 70 strategies. Government Income Tactical and QFC Government Income Tactical. Government Income Tactical draws on at least five different strategies to trade government bonds. The strategies are chosen and rebalanced quarterly by Adviser's proprietary algorithm. QFC Global Managed Equity. QFC Global Managed Equity is a flexible investment solution that can allocate across the globe in both equities and tactically into bonds. The strategy is primarily composed of a global fund (QGBLX) that includes ADR exposure. QFC High Yield Tactical. QFC High Yield Tactical provides dynamic exposure to tactical high yield bond trading methodologies, primarily allocating to the Quantified Tactical Fixed Income Fund (QFITX) with potential tactical allocations to equity and other Quantified Funds. High Yield Tactical (Annuity Platform Version). High Yield Tactical is a strategy on annuity platforms applying tactical high-yield bond trading methodologies within variable annuity accounts. The strategy uses multiple sub-strategies to adjust exposure. QFC Liquid Alternatives. QFC Liquid Alternatives aims to achieve strong risk-adjusted returns from a universe of alternative-asset-class funds, allocated solely among Adviser's sub-advised Quantified Funds using the Evolution Asset Allocation methodology. QFC Managed Futures. QFC Managed Futures aims to be a flexible investment strategy allocating across financial and commodity markets. It primarily invests in the Quantified Eckhardt Managed Futures Strategy Fund (QETCX) but may allocate tactically to other Quantified Funds. Managed Income and QFC Managed Income. Managed Income applies Evolution Asset Allocation to a selected group of high-yield (junk) corporate, convertibles, leveraged, international, global, emerging market, and government bond Investments. QFC Dynamic Trends. QFC Dynamic Trends is a trend-following strategy that focuses on the NASDAQ 100 Index when volatility is signaled to be low (via the Quantified STF Fund, QSTFX) and on a broader managed futures portfolio (via QETCX) when volatility is high. QFC Tactical Bond. QFC Tactical Bond provides investors with dynamic exposure to the fixed-income market through tactical allocations among sub- advised Quantified fixed-income funds that actively manage different areas of the bond market. 29 #119-0326 Part 2A of Form ADV Firm Brochure  Tactical Bond (Annuity Platform Version). Tactical Bond is a strategy on annuity platforms providing dynamic exposure to the fixed-income market within variable annuity accounts. The strategy combines multiple sub-strategies to increase or decrease exposure to various bond sectors. Evolution Emerging Markets. Evolution Emerging Markets uses Adviser's proprietary Evolution allocation method to focus on leading emerging-markets equity and fixed-income funds. The strategy may utilize leveraged Investments. Appropriate for aggressive suitability investors. Managed Money Market. Important: Managed Money Market is intended as a temporary place to keep portfolio assets when taking risk off the table. It is not meant to be a long-term investment. This strategy is not insured by the FDIC and not guaranteed to maintain a stable net asset value. ASI Strategies — Available at Select Custodians. The following ASI Strategies are available only at select custodians. Each strategy takes a rotational approach to investing among a defined universe of ETFs or mutual funds, using intermediate-term price momentum for selection: • ASI Aggressive Sector Fund Rotation (sector-oriented Fidelity mutual funds; single fund at a time; very aggressive growth objective) • • ASI Aggressive Sector ETF Rotation (sector-oriented ETFs and ETNs; single ETF/ETN at a time; very aggressive growth objective) ASI Sector Fund Rotation (sector-oriented mutual funds; four funds simultaneously; aggressive growth objective) • ASI Sector ETF Rotation (sector-oriented ETFs and ETNs; four ETFs/ETNs simultaneously; aggressive growth objective) • ASI International ETF Rotation (international and global ETFs and ETNs; five funds simultaneously; developed and emerging market exposure; currency risk) • ASI Style ETF Rotation (15–20 market categories including Morningstar style boxes, mega-cap, micro-cap, international; two ETFs simultaneously) • ASI Lone Star ETF Rotation (alternative beta, strategy, and style ETFs and ETNs; single ETF/ETN at a time; aggressive growth) • ASI Income ETF Rotation (income-producing ETFs, ETNs, and mutual funds including high yield, zero coupon, treasuries, munis, convertibles; five funds simultaneously) • ASI Global Income ETF Rotation (global multi-asset income ETFs and ETNs; five funds simultaneously; international currency and credit risk) • ASI Factor ETF Rotation (smart-beta ETFs including factor, event-driven, theme-based, and strategy ETFs; three holdings; systematic rotation) Evolution Tactical. Evolution Tactical is a dynamically risk-managed investment strategy that aims to invest in the top-performing investments within the equity, bond, and alternative asset classes. On a regular basis, allocations are evaluated and adjusted based on a combination of Adviser's Evolution methodology, tactical overlay signals, and regime analysis. • Tactical overlay may incorrectly reduce equity exposure during brief volatility Additional Strategies — Not Open to New Clients. Evolution. Investments are allocated among a broad range of Investments including domestic, international bond and equity, sector, precious metals, leveraged, inverse, and money market Investments, based on Adviser's Evolution Asset Allocation methodology. Key Risks: (See Section 8.L for full risk factor descriptions) • • Not open to new clients — no new strategy performance data generated Broad universe including leveraged and inverse Investments — significant loss potential 30 #119-0326 Part 2A of Form ADV Firm Brochure  Evolution II. Evolution II utilizes a variety of asset classes. Adviser's proprietary Evolution methodology rotates into the best performing Investments within three to five Investment universes constructed with different holding periods. Key Risks: (See Section 8.L for full risk factor descriptions) Not open to new clients • • Multi-holding-period design — longer holding periods increase drawdown risk • Multi-universe complexity Market Leaders Tactical. Market Leaders Tactical begins with the same all-equity allocation approach used in Market Leaders Strategic, but applies it monthly and combines it with the MEI signal to identify bullish or bearish market environments. Key Risks: (See Section 8.L for full risk factor descriptions) Not open to new clients • • MEI signal may lag market turning points • Sub-adviser risk: DWM equity signals Section 8.I – Special Programs SELF-DIRECTED BROKERAGE ACCOUNT (SDBA) Program. The SDBA is an option available to participants in certain workplace retirement plans. The SDBA uses the QFC Strategies described above. Some strategies may not be available on all platforms and custodians. Investor Class SDBA. The Quantified Funds (Investor Class shares) are used by Adviser as the sole building blocks of the QFC Strategies utilized by the Investor Class share SDBA program. The strategies currently available for investment in the Investor Class SDBA program are QFC Common Ground, QFC Multi-Strategy Portfolios and QFC Strategic Tactical (only available at TIAA). These strategies are not available to the Adviser Class SDBA. Adviser is the sub-adviser to the Quantified Funds, for which it is paid a fee. Advisory Fees are levied in an amount equal to the amount of fees received by Adviser from the Quantified Funds. Adviser credits on a pro-rata basis the amount of sub-advisory fee it receives as sub-adviser to the Quantified Funds against its advisory fee levied for its strategy management within the SDBA. No further advisory fee will be levied by Adviser directly against either the Investments or client in respect of Adviser’s services rendered pursuant to client’s investment management agreement. Indirect compensation from Adviser will be paid to client’s financial representative, up to approximately 30 basis points (annually). Adviser serves as sub-adviser to the Quantified Funds, distributed by Ceros Financial Services, Inc. (Member FINRA/SIPC). Adviser and Ceros are not affiliated. Advisors Preferred, LLC (AP) serves as investment adviser to the Quantified Funds. Advisors Preferred, LLC is a wholly owned subsidiary of Ceros. Advisor Class SDBA. The Quantified Funds (Advisor Class shares) are used by Adviser as the sole building blocks of the QFC Strategy, FlexPlan Strategic, which is utilized solely by the Advisor Class share SDBA program. This strategy is not available to the Investor Class SDBA. Adviser is the sub-adviser to the Quantified Funds, for which it is paid a fee. Advisory Fees are levied in an amount equal to the amount of fees received by Adviser from the Quantified Funds. Adviser credits on a pro-rata basis the amount of sub-advisory fee it receives as sub-adviser to the Quantified Funds against its advisory fee levied for its strategy management within the SDBA. No further advisory fee will be levied by Adviser directly against either the Investments or client in respect of Adviser’s services rendered pursuant to client’s investment management agreement. Indirect compensation from Adviser will be paid to client’s financial representative in the amount of 75 basis points (annually). The fee consists of two portions; a referral fee in the amount of 15 basis points, paid directly by Adviser, and a marketing fee of 60 basis points, paid by Adviser on behalf of the Affiliated Advisor Share Class Fund’s Distributor, pursuant to a separate written agreement. Adviser serves as sub-adviser to the Quantified Funds, distributed by Ceros Financial Services, Inc. (Member FINRA/SIPC). Adviser and Ceros are not affiliated. Advisors Preferred, LLC serves as investment adviser to the Quantified Funds. Advisors Preferred, LLC is a wholly owned subsidiary of Ceros. 31 #119-0326 Part 2A of Form ADV Firm Brochure  SDBA Additional Considerations. Adviser's sub-advisory agreement for the Affiliated Funds provides that the AP advisory fee charged for all of the Affiliated Funds in the aggregate declines as the AUM of all of the funds increases. As a result, the sub-advisory fee paid to Adviser proportionately increases. Therefore, the Adviser has a conflict of interest in solely using the Affiliated Funds for this product in that the more assets placed in these Funds, the more sub-advisory fees the Adviser makes from these Funds. However, these fees are lower than the Adviser's regular fee schedule and are the only compensation Adviser receives for this product. In addition to negating the need to bill clients additional fees for smaller accounts, it also allows most of the transaction activity occasioned by Adviser's active management style to be confined within the Affiliated Funds rather than encumbering non-client shareholders of third-party Funds, and the custodians of its activity managed strategies, from bearing that burden. It also allows for the utilization of more cost-effective investments than would be easily utilizable within a third-party fund SMA. When evaluating investment program with multiple share classes, it's important to consider the differences between Investor Class and Advisor Class shares. Both share types have their advantages and disadvantages. Key factors to consider include the client's investment objectives, constraints, and considerations specific to the strategies offered by each Program, such as investment fit (correlation and return), custodian availability, minimum investment requirements, universe and track record of available Investments, and expected risk/return performance after costs. This list is not exhaustive, and the relative importance of each factor will vary depending on the unique needs of each client. Specific considerations in support of the Advisor Class offering are access to the FlexPlan Strategic methodology only available in Advisor Class shares and lower minimum investment of $25,000 for Fidelity BrokerageLink accounts relative to other SDBA products. FlexPlan Strategic allocates among four specially chosen, actively managed Quantified Funds: (1) the values-based equity growth Quantified Common Ground Fund (QCGAX), (2) the Quantified STF Fund (QSTAX), which utilizes momentum-driven market returns, (3) the Quantified Eckhardt Managed Futures Strategy Fund (QETAX), which provides alternative diversification with managed futures, and (4) the defensive, income allocation Quantified Managed Income Fund (QBDAX),to provide clients with risk control and diversified fund exposure. The Quantified Funds (Advisor Class shares) are used by Flexible Plan as the sole building blocks for the Flexible Plan Self Directed Brokerage Account (SDBA) FlexPlan Strategic strategy. Flexible Plan Investments is the subadvisor to the Quantified Funds, for which it receives a sub-advisory fee that varies by fund utilized. The total expense ratio for each fund consists of management fees, operating expenses, and distribution fees - see each fund's prospectus for complete expense details. Flexible Plan acts as the agent for the Fund Distributor in remitting Marketing fees from the Advisor Class to the client's broker/dealer firm. Total annual compensation to broker/dealers is 0.75%, consisting of 0.15% from combined advisory and sub-advisory fees and 0.60% in marketing fees paid on behalf of the Distributor. These fees fully offset Flexible Plan's strategy management fees, with no additional advisory fees charged directly to clients or investments under the investment management agreement. A revenue sharing arrangement exists whereby Flexible Plan receives compensation for sub-advisory services and shares distribution fees. Note that broker/dealer will be paid a fee of 0.75% per annum, for the duration of your investment and it will continue regardless of strategy performance or market conditions. Other SDBA strategies using different share classes are available that may have lower overall costs (typically 0.25%-0.50% less annually) and lower broker/dealer compensation, creating a potential conflict between client costs and advisor compensation. Since FlexPlan Strategic is only available using Advisor Class shares, investors and their representatives should evaluate whether the strategy's asset class focus, methodology, features, and benefits better serve the investor's interests compared to lower-cost alternatives. The sub-advisory fees Flexible Plan receives vary by fund: - see each fund's prospectus for complete expense details. Since FlexPlan Strategic's allocation among funds changes quarterly based on the strategy's proprietary algorithm, Flexible Plan's total compensation will vary depending on which funds are selected. This creates a potential conflict as Flexible Plan could receive higher compensation when the strategy allocates more assets to funds paying higher sub-advisory fees. To mitigate this conflict, fund selection and allocation decisions are made solely according to the strategy's predetermined quantitative methodology without consideration of fee differentials. Selection of the Advisor Class SDBA program in lieu of the Investor Share Class may present a conflict of interest for client’s financial representative and Adviser with regard to fees received. As outlined above, client’s financial representative has the ability to earn up to 30 basis points annually on the Investor Class SDBA program and has the ability to earn 75 basis points annually on the Advisor 32 #119-0326 Part 2A of Form ADV Firm Brochure  Class SDBA program creating a financial incentive for client’s financial representative to recommend the Advisor Class program. Although the sub-advisory fee received by Adviser is consistent between the Investor and Advisor Class programs, dependent upon the mix of funds used, Adviser does retain a larger portion of its sub-advisory fee with respect to the use of the Advisor Class of Quantified funds on any platform than it does on comparable sales of its Investor Class products. This is because the payment to the client’s financial representative of fees for the Investor Class SDBA program comes solely from Adviser’s sub- advisory fees, while a majority (60 basis points) of the payment to the client’s financial representative of fees for the Advisor Class SDBA program are marketing fees, forwarded by Adviser, on behalf of the respective funds pursuant to the Payment Agent agreement, discussed herein, and do not come out of Adviser’s sub-advisory fees. Fund share classes that pay marketing or similar shareholder services fees generally carry a higher internal expense ratio than fund share classes which do not pay such fees. Although these fees are internal expenses of the funds, they are ultimately a cost to the client. Adviser does not receive marketing or shareholder servicing fees relating to either SDBA program. The Investor Class program is available to all SDBA clients. Adviser does not make recommendations or favor either of the SDBA programs or their underlying strategies. Selection of the SDBA program and underlying investment strategy is solely at the discretion of client with the assistance of its financial representative. DONOR ADVISED FUND (DAF) PROGRAM. Adviser has launched FPI Charitable, a donor-advised fund program sponsored by National Charitable Endowment (NCE), a 501(c)(3) charity. For a minimum account size of $50,000, FPI Charitable offers clients a risk-managed, tax-smart way to support their favorite charitable causes. clients make contributions into an account with the sponsoring organization, NCE. Once the account is funded, NCE owns and legally controls its assets, which allows the client to take a deduction for the full value in the initial year. The client recommends how the assets are invested utilizing any of Advisor’s available strategies. In addition, client determines the 501(c)(3) charities that funds held in FPI Charitable are ultimately donated to through NCE’s services. There is a separate Service fee for those services and Advisory fees are also charged on the account. See Fee discussion above. Adviser does not provide tax advice, and it is recommended that client consult a tax professional prior to utilizing the Donor Advised Fund program. FPI TARGETED-YIELD DISTRIBUTION SERVICE The FPI Targeted Yield Income Distribution Service (TYDS) offers account holders at Axos Advisor Services a way to receive variable monthly income distributions from their investment. Each month, the service calculates the distribution amount based on the ending balance of the investor’s TYDS account from the previous month. This amount is then multiplied by one-twelfth of the rate determined by the higher of two figures: 5% or the previous month's 10-year U.S. Treasury Bond yield plus 1%, with this rate not exceeding 8%. Distributions are made monthly through wire transfers to the investor’s bank account. The service utilizes the QFC Multi-Strategy Portfolios Balanced strategy for investing the account funds, which is designed to manage risk dynamically and aims for balanced growth. Unlike a Certificate of Deposit from a bank, the FDIC does not insure TYDS. Furthermore, TYDS accounts are subject to market and investment risks, including the possible loss of principal. Additionally, the performance of the QFC Multi-Strategy Balanced Portfolio and the underlying investment strategies can vary, and there is no guarantee that the investment objective of the service or strategy will be achieved. As a result, investors should be aware that the income distributions from TYDS are variable and can fluctuate with market conditions based on each month’s account value, and are not based on the original investment value of the account. While the yield rate is targeted, the amount of the income payout is not. REBALANCING SERVICE Adviser provides clients the ability to elect systematic rebalancing of their client accounts. Due to constraints beyond the advisor’s control, elective rebalancing may only occur at Axos. When rebalancing is elected, each account (without regard to other accounts held with Adviser) will be rebalanced to the most recent client allocation on file. Rebalancing will only be if at least one strategy is more than 5% away from the client’s current strategy allocation of record. All strategies within the account will be rebalanced back to the latest strategy allocation on file. Rebalancing elections need to be completed before the end of the quarter. Rebalancing will generally be completed during the first week of a calendar quarter, based on the immediate preceding quarter-end strategy balances. Any investment sells, associated with rebalancing, is on a first-in first-out (FIFO) basis for tax purposes. No consideration or priority is given to tax-favored strategies during rebalancing and therefore may undermine any allocation to these strategies for tax reasons. All trading is on a "best efforts" basis. 33 #119-0326 Part 2A of Form ADV Firm Brochure  GROUP RETIREMENT PLANS. Adviser works on several group retirement platforms (see Item 10.C for further detail). Each platform is unique with respect to services available and Adviser's fees are flexible and tailored to each platform. Managed Participant Accounts. Adviser provides investment management services to individual participants in certain employer-sponsored employee retirement plans that have been established with various custodians. The individual participants in such plans are permitted to direct investment of their respective accounts in the plan, including the authority to engage an investment adviser for their accounts. A participant desiring to engage Adviser enters into a Participant Account Management Agreement with Adviser. Management involves actively investing and reinvesting the account in various Investments that are available through the custodians. Adviser offers its Strategic Advantage 401(k) and Flex Plan services which feature: Turnkey—record keeper, custodian, investment manager and TPA, all in one; Plan design, ERISA reporting, and discrimination monitoring; open architecture platform; access to thousands of no-load mutual funds; transparent fee structure; managed accounts for participants; QDIA account managed solution; RIA-provided fiduciary services; reduced plan sponsor primary liability; professional investment management; OnTarget Investing reporting for participants and plan sponsor; daily, online account access at Axos Advisor Services via PCS Retirement, LLC and Nationwide/RIA Services, respectively. There may be an annual administration fee and an annual investment advisory fee. The maximum total of such fees is 1.75% annually, pro-rated and billed, in arrears monthly or quarterly for the Strategic Advantage plans. For non-Strategic Advantage plans electing QFC Strategies, Adviser is compensated for its portion of such fees solely by its sub-advisory fees from use of the Quantified Funds. An administrative fee may be paid from the Participant Account to record keepers, TPAs and program interface providers for assistance in enrollment, setup and trading. Adviser and a solicitor may share the Investment Advisory fee. Each such fee is determined by negotiation with the employer sponsor of the retirement plan. The same fees are applicable to all participants in a specific plan who engage Adviser’s services. The specific percentages are disclosed to the participant in other disclosure documents delivered to the participant at the time of execution of the Participant Account Management Agreement (PAMA). Both fees are a percentage of the average daily value of the participant’s account during each calendar quarter or month and are billed by and payable to Adviser in arrears. (Note: different custodians may pro-rate fees using different pro-rating methods or simply apply them to the month-end or quarter-end balance without proration or consideration of the date of additions or withdrawals. In such case, the resulting fee may be higher or lower than if the fee had been prorated. This is due to market price changes during the billing period and the timing of additions to, and withdrawals from the account ) Such fees are the sole expense payable from the participant’s account attributable to the provision of investment management on the account (although various fees and commissions may be applicable to the underlying investment vehicle, custodian or trading platform chosen by the Employer/Sponsor and Core Fiduciary Service fees may be paid with respect to participant-directed accounts). No minimum participant account size is required. This 1.75% maximum consists of FPI's retained advisory fee (0.75%) and the solicitor or co-adviser's flat-rate compensation (fixed at 1.00% per plan agreement), as disclosed in Section 5.E of this brochure. Actual rates depend on the governing Third Party Fee Agreement. Core Fiduciary Services. As an additional service to sponsors of qualified retirement plans, Adviser will serve as a co-fiduciary to the plan in the performance of certain contractually specified services. In such regard, Adviser will assist in the preparation or amendment of the plan’s Investment Policy Statement. Further, Adviser will periodically review and monitor the investment options available under the plan to its Self- Directing Plan Participants as they relate to the criteria in the Investment Policy Statement and recommend appropriate asset classes and investment options as well as specify the use or discontinuance of specific funds and collective trusts to be accessible by Self- Directing Plan Participant accounts. If the employer sponsor of the retirement plan contracts for the provision of Core Fiduciary Services, the fee may be fixed or determined by negotiation with the sponsor. The maximum fee charged is 10 basis points per annum, charged in arrears on the quarter-end balance or month-end balance (depending on the platform) of non-managed, participant-directed accounts. The same Core Fiduciary Services fee is applicable to all Self-Directing Plan Participants at that percentage specified in the Plan Sponsor Agreement between Adviser and the Plan Sponsor. Such fee is not applicable to plan assets managed by Adviser. Any solicitor fees are added to, and not included in, the Core Fiduciary Service Fee. These services are not available to new plans. 34 #119-0326 Part 2A of Form ADV Firm Brochure  Plan Sponsors may elect to provide model portfolios which may be elected into by plan participants or designated as the Qualified Default Investment Alternative (QDIA). Model Portfolios are then provided for various suitability profiles and managed by Adviser. A principal determinant of the suitability profile of such participants will be the participant’s age. This is due to the fact that there is often little communication from these participants with the plan administrator and the Adviser. In a given participant’s individual situation, age may not be the best measure of such participant’s suitability for a given investment or strategy. As such, it is incumbent on such participants to either self-manage their account or utilize the managed participant account services described above. Participants who do not avail themselves of such options assume the risk of the age based suitability profile in its application to their individual circumstances. Fees are charged in the same manner described in the Participant Account Management Agreement and there is no minimum participant account size. Section 8.J – Proprietary Funds Table Clients should review the Prospectus and Statement of Additional Information (SAI) for each sub-advised fund before investing. Contact information: Fund Fund Adviser Contact Quantified Gold Futures Tracking Fund (QGLDX) Advisors Preferred 1445 Research Blvd, Suite 530, Rockville MD 20850 Phone: 855-650-7453 quantifiedfunds.com Quantified Alternative Investment Fund Advisors Preferred (see above) Quantified Managed Income Fund (QBDSX) Advisors Preferred (see above) Quantified Market Leaders Fund (QMLFX) Advisors Preferred (see above) Quantified STF Fund (QSTFX/QSTAX) Advisors Preferred (see above) Quantified Tactical Fixed Income Fund (QFITX) Advisors Preferred (see above) Quantified Evolution Plus Fund (QEVOX) Advisors Preferred (see above) Advisors Preferred (see above) Quantified Common Ground Fund (QCGDX/QCGAX) Quantified Pattern Recognition Fund Advisors Preferred (see above) Quantified Tactical Sectors Fund Advisors Preferred (see above) Advisors Preferred (see above) Quantified Government Income Tactical Fund (QBDSX) Quantified Rising Dividend Tactical Fund Advisors Preferred (see above) Quantified Global Fund (QGBLX) Advisors Preferred (see above) Advisors Preferred (see above) Quantified Eckhardt Managed Futures Strategy Fund (QETCX/QETAX) Quantified Gold Futures Tracking Portfolio is also sub-advised by Adviser. Contact information above. 35 #119-0326 Part 2A of Form ADV Firm Brochure  Section 8.K – Platform Availability Table Section 8.L – Consolidated Risk Factors In addition to the risk considerations described below, also review the risk considerations designated in the table of strategy considerations provided in Item 8 above and the ensuing risk discussions immediately following the table. Investing in securities involves risk of loss that clients should be prepared to bear, including: Generally, Adviser attempts to accomplish the investment objectives of the strategies with short-term trading that will generate taxable short-term gains or losses if realized in a taxable account, other than after the first 12 months with All Terrain Moderate - Static. Although potential dividends are taken into account in selecting Investments for use in all strategies they are not an objective and any generated will be reinvested. As with any Investment, there can be no assurance that the investment objectives will be obtained or that material loss will not be incurred, and Adviser does not warrant investment success. Client should consider these objectives in light of the total fees and expenses described in Item 5, as higher overall costs may reduce net returns. Client acknowledges that client is fully cognizant of the risks described herein. 36 #119-0326 Part 2A of Form ADV Firm Brochure  Some of the risks these strategies can be exposed to are: Strategy and asset allocation decisions may not always be correct and may adversely affect account performance. The use of leverage may magnify this risk. Leverage and Investments employing derivatives carry other risks that may result in losses, including the effects of unexpected market shifts, default, and/or the potential illiquidity of certain derivatives. International investments carry additional risks, including volatile currencies, economies, and governments, and emerging-market securities can also be illiquid. Bonds are affected by changes in interest rates, credit conditions, and inflation. As interest rates rise, prices of bonds fall. Long-term bonds are more sensitive to interest-rate risk than short-term bonds, while lower- rated bonds may offer higher yields in return for more risk. Unlike bonds, bond Investments have ongoing fees and expenses. Stocks of small and/or midsize companies increase the risk of greater price fluctuations. REITs involve the risks of real estate investing, including declining property values. Commodities involve the risks of changes in market, political, regulatory, and natural conditions. The ultimate choice of the strategy or combination of strategies used by a client is a matter of choice of the financial advisor and/or client. FPI follows the directions of same in managing a client account. Securities markets are volatile and the strategies may under-perform various market indices and the various Investments themselves on an unmanaged basis. While Adviser's investment decisions may have been successful in the past or have demonstrated the possibilities of success in research studies, they may be changed or be ineffective as applied to future market environments. Adviser by necessity relies on information, data and software provided by third parties, whose reliability, while believed to be accurate, cannot be guaranteed and losses may result from reliance upon them. These are normal risks for which Adviser takes no responsibility beyond use of reasonable care in their selection. Strategies may be utilized as a part of a diversified investment approach combining other strategies with differing risk profiles. Consideration should be given to utilizing low correlated strategies and/or combining lower risk strategies with higher risk strategies in order to reduce the overall risk of client's portfolio. Notwithstanding the selection of multiple strategies to achieve diversification, the fact that several strategies may, in part, draw upon substantially similar investment vehicles will, under certain circumstances, result in different portfolios holding the same or similar asset classes. This potential investment concentration in a particular asset class increases risk for the period during which such concentration exists. For example, Select Alternatives, QFC Select Alternatives, QFC Liquid Alternatives, Lifetime Evolution and QFC Lifetime Evolution, among others, include precious metals as a potential asset class for investment. As the result of an initial period of market strength in that asset class, all of those portfolios might hold precious metals investments. All of the strategies described are managed by Adviser with the objective of attaining the highest appreciation potential while seeking to manage risk at a level that Adviser deems acceptable. Certain of the strategies have risks specific to their design. Investments may experience material drawdowns during any period of general weakness in the financial markets. Withdrawals required by a client during any such period may materially reduce overall investment performance of Investments managed in a strategy. Investing in securities involves risk of loss that clients should be prepared to bear. In addition to the Key Risks bullets provided in each strategy description above, clients should carefully read the following risk factors. Index and Leveraged Funds (Including Inverse Funds). Investment vehicles utilized include one or more index Investments designed to have a targeted positive or negative correlation to the underlying index. A positively correlated index Investment appreciates in value when the underlying index increases. A negatively correlated (inverse) index Investment appreciates in value when the underlying index decreases. Leveraged Investments are designed to have a multiple of the return of the underlying index — for example, a 2X leveraged Investment seeks to return twice the daily return of the underlying index. Inverse and leveraged funds are reset daily; over periods longer than one day, returns may differ significantly from the stated multiple due to compounding effects. International Investments. When investing in international securities, the program's return will be affected by the fluctuating value of the U.S. dollar in relation to foreign currencies and political events in foreign countries. Precious Metals Investments. Adviser may make substantial allocations to precious metals equity Investments which invest their assets predominantly in the shares of companies engaged in exploration, recovery, refinement, and sale of precious metals. Precious metals are highly volatile and speculative assets. 37 #119-0326 Part 2A of Form ADV Firm Brochure  Proprietary / Non-Diversified Funds. Adviser serves as sub-adviser to Advisors Preferred, LLC to provide investment advisory services for selective equity and income mutual funds including the Quantified Gold Futures Tracking Fund and the Quantified family of funds (collectively, 'Affiliated Funds'). These funds may be concentrated in specific sectors or markets and carry higher concentration risk than broadly diversified funds. Strategy Risk and Concentrated Investments. Research data generally tends to indicate a Beta less than that of the S&P 500; therefore, some strategies may be characterized as having low to moderate risk even though they may utilize Investments with a high correlation to a particular sector, geographic area, or style of investing. Concentrated positions increase the potential impact of adverse performance in the concentrated area. Income Investments. Income Investments may include exposure to alternative investments, U.S. Treasury bonds and notes, government-sponsored enterprises, corporate obligations, mortgage and asset-backed securities, zero coupon bonds, convertible bonds, high-yield bonds, and foreign bonds. Income investments are subject to interest rate risk, credit risk, and, for foreign bonds, currency and political risk. Use of Leverage in Bond Strategies. Some programs employ daily trading and leveraged index funds. Inverse funds are also used. The standard deviation of such programs, while less than that of a major stock market index, is more than is typical for bond investment programs. Use of Cryptocurrency. Some funds may utilize cryptocurrency futures. The risks of utilizing cryptocurrency futures are related to their volatility. They are high- risk and speculative. Volatile and unexpected changes in the cryptocurrency market could have a material adverse effect on investments. Absolute Return Strategies. The goal of Absolute Return money managers is to achieve positive returns regardless of financial market returns or benchmarks. They seek to do this using non-traditional investment techniques and asset classes. There is no guarantee that absolute return objectives will be achieved. SRI/BRI and Faith-Based Strategy Risk. QFC For A Better World, Classic Better World, and QFC Classic Better World, together with QFC Common Ground BRI/SRI, utilize Investments that restrict investment in their portfolio companies to achieve socially responsible or faith-based objectives. Such screening restricts the investment universe and may result in underperformance relative to unrestricted strategies. Implementation of Strategy Changes. As an investment advisory firm, Adviser is geared to monitor its proprietary trading signals and to be prepared to promptly direct such trades; those resulting from other sources are outside the flow of the firm's proprietary systems. As a result, implementation of changes to strategies involving non-proprietary signals, including sub-adviser signals, may not be made at an optimal time. Market Risk. Participation in management programs subjects investors to financial marketplace risks. There is no guarantee that the investment objectives will be achieved. Third-Party Risk. Third parties (including broker-dealers, registered representatives, DAF providers, CTA providers, insurance agents, market data providers, plan administrators, investment advisers, sub-advisers, custodians, and other service providers) may fail to perform their obligations, fail to provide accurate information, or otherwise cause harm to Adviser's ability to manage client accounts. 38 #119-0326 Part 2A of Form ADV Firm Brochure  Suitability Profiles. For many strategies Adviser provides suitability-based profiles with names such as, without limitation, Conservative, Moderate, Balanced, Growth, or Aggressive. Clients should draw no conclusions from such names about the risk level of the strategies — the names refer to suitability profiles, not to specific risk or return targets. Frequency of Trading. The number of trades in the strategies offered is likely to be substantially higher than in typical traditional investment accounts, which may result in substantially more recordkeeping for client. Many of the trading signals give rise to short-term gains or losses. Trading Restrictions. Investment Families may impose other trading restrictions that could delay full implementation of a strategy change request or new client investment. These restrictions may or may not be disclosed by the Investment Family prior to imposition. Account Liquidity Reserve. A portion of client accounts may be maintained in cash equivalent investments by the custodian to facilitate trade settlements in client's account and satisfy invoicing. This may reduce client returns. Terminations. Either party upon receipt of written notice may terminate the investment management contract. If a termination request is received from client, Adviser shall notify the Investment Family(ies) within 5 business days and request liquidation to a money market fund. Redemption Fees / Exchange Fees. Certain Investments and/or custodians may impose substantial redemption charges or exchange fees on Investments held for less than a minimum period. While best efforts will be made to avoid such charges, they may be unavoidable in some circumstances. Mutual Fund Distributions. By design, mutual funds do not have the ability to fully control the size and timing of year-end distributions. The distributions are often impacted by the timing and success of trading within the fund during the course of the year. Tax Considerations. Generally, Adviser attempts to accomplish the investment objectives of the strategies with short-term trading that will generate taxable short-term gains or losses if realized in a taxable account, other than to the extent that Adviser may specifically take into account tax considerations upon client request. Strategy Names. Many strategies, although in different programs, have similar or identical names. Investors should read carefully the strategy description for the program they intend to invest in for the characteristics of that specific strategy. Cybersecurity and Technology Risk. Adviser and its third-party service providers rely on technology systems, networks, software, and data to operate Adviser's investment management business. These systems are subject to cybersecurity threats including unauthorized access, data breaches, ransomware, and service disruptions. A significant cybersecurity event could result in loss or misappropriation of client data, financial loss, business disruption, and regulatory scrutiny. Adviser maintains cybersecurity policies and procedures designed to protect client data and firm systems, but no system can provide absolute protection against all threats. See also the Cybersecurity Disclosure in End Matter. 39 #119-0326 Part 2A of Form ADV Firm Brochure  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 the evaluation of Flexible Plan Investments, Ltd. or the integrity of its management in providing investment advisory services. No information is applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations Section 10.A – Other Compensation Security Benefit Life Insurance Company. Under an amended 2004 agreement with Security Benefit Life Insurance Company, Adviser is paid a 25 basis points annual fee on accounts managed in its AdvisorDesigns, AdvanceDesigns, EliteDesigns, and EliteDesigns II variable annuity products. Adviser does not receive any transaction-based compensation from Security Benefit. Section 10.B1 – Compensation-Bearing Affiliations and Conflicts The following relationships involve compensation paid to or by Adviser that may create conflicts of interest. Each is disclosed fully below. See also Section 4.G (Conflicts of Interest — At a Glance) for a summary. Advisors Preferred LLC ("AP"). Pursuant to a contract with AP, Flexible, acting in the capacity of a sub-adviser, provides investment advisory services for select equity, income, derivative and ETF Investments that Flexible also may use in selected strategies, regardless of the Investments described as being utilized elsewhere in this Brochure. If these Investments are used in client’s portfolio, since Flexible would receive a fee for its sub-adviser activities, clients will receive a pro-rata fee credit of their account’s portion of the sub-advisory fee against their advisory fees. Additionally, Flexible provides model strategies to AP utilizing the Quantified Funds. These strategies are offered by AP to third parties through a subscription-based service. Pursuant to a contract with AP, executed in July 2023, Flexible, acting in the capacity as a consultant, provides advice and training relating to the marketing of AP Funds to financial professionals. As compensation for these services, Flexible receives an annual marketing consulting fee paid in monthly installments. Further, Adviser and AP (via Ceros) entered into a Payment Agent agreement in which, in part, Adviser will forward payments from Ceros, on behalf of the respective fund, to broker/dealers who offer, sell or promote shares of the Funds. AP is a federally registered investment adviser and is the adviser of Quantified Gold Futures Tracking Fund, Quantified Gold Futures Tracking Portfolio and 13 Quantified Funds (Affiliated Funds). The Funds are distributed by Ceros Financial Services, Inc. (member FINRA/SIPC). AP is a wholly-owned subsidiary of Ceros Financial Services, Inc. While Adviser makes no payments to AP for strategy recommendations, AP is compensated by the Funds in its role as investment adviser to the Funds on the basis of assets under management in the Funds. AP is located at 1445 Research Boulevard, Suite 530, Rockville, MD 20850. See Items 4.G, 5.D, and 8. AtCap Partners, LLC ("AtCap"). Pursuant to a contract with AtCap, Flexible, acting in its capacity as a co-adviser, provides investment advisory services to Fidelity Institutional Wealth Services, Group Retirement Plan participants through AtCap's management platform. In respect of its services, Adviser receives a fee from AtCap pursuant to negotiated rates. AtCap is an affiliate of Ceros Financial Services, Inc. Disciplined Wealth Management, LLC ("DWM"). DWM is under contract with Adviser to provide all buy and sell directions for management of client accounts in Adviser's strategies known as the 'Market Leaders' strategies and the Low Volatility/Rising Dividends strategy. In respect of its services, Adviser pays DWM a signal fee equal to generally 20% of the Net Advisory Fee (total advisory fee less solicitor/co-adviser portion) received by Adviser on accounts using DWM signals. Additionally, Adviser pays DWM a signal fee equal to 20% of the net sub-advisory fees received from AP for AUM in the Market Leaders Fund, Rising Dividend Tactical Fund and Tactical Sectors Fund that is not otherwise utilized in Advisor strategies. 40 #119-0326 Part 2A of Form ADV Firm Brochure  Hg Capital Advisors, LLC ("Hg"). Hg is under contract with Adviser to provide all buy and sell directions for management of client accounts in Adviser's strategies known as 'WP Aggressive,' 'WP Growth,' and 'WP Moderate.' In respect of its services, Adviser pays Hg a signal fee equal to generally 20% of the Net Advisory Fee received by Adviser on accounts using Hg signals. STF Management, LLC. STF Management is under contract with Adviser to provide marketing services related to the Self-Adjusting Trend Following ('STF') strategy. In respect of its services, Adviser pays STF Management a marketing allowance based upon that portion of each client account utilizing the STF strategy. The amount of the allowance is dependent upon the extent of the assets of the account devoted to STF, as follows: (i) $1,000 for each $2,500,000 of STF assets held in Qualified Client Accounts the value of which is $500,000 or less; (ii) $750 for each $2,500,000 of STF assets held in Qualified Client Accounts the value of which is greater than $500,000 but less than $1,000,000; and (iii) $500 for each $2,500,000 of STF assets held in Qualified Client Accounts the value of which is greater than $1,000,000. The above tiered schedule does not apply to the assets under management in the Quantified STF Funds (“STF Fund AUM”) Adviser pays STF Management an amount equal to: (i) 12.5% of the monthly sub-advisory fees received from Advisors Preferred, pursuant to the “Subadviser” section of the of the Quantified Funds Prospectus, arising from the use of the QSTFX and QSTAX funds on the initial $200,000,000.00 of STF Fund AUM; (ii) 10% of the monthly sub-advisory fees received from Advisors Preferred, pursuant to the “Subadviser” section of the of the Quantified Funds Prospectus, arising from the use of the QSTFX and QSTAX funds on STF Fund AUM from $200,000,01.00 to $300,000,000.00; and (iii) 7.5% of the monthly sub-advisory fees received from Advisors Preferred, pursuant to the “Subadviser” section of the of the Quantified Funds Prospectus, arising from the use of the QSTFX and QSTAX funds on any STF Fund AUM in excess of $300,000,001.00. Jerry C. Wagner. Mr. Wagner, President of Flexible Plan Investments, Ltd., is a licensed attorney at law and spends an immaterial amount of his time in that capacity. Mr. Wagner is President and 100% owner of Dynamic Performance Publishing, Inc., a financial publishing company. Additionally, certain Flexible Plan employees perform services for DPP for which time Flexible Plan is reimbursed. Avant Capital Management ("AVANT"). Adviser is under contract with AVANT for the use of AVANT's buy and sell signals for utilization in Adviser's capacity as sub-adviser to the Quantified Gold Futures Tracking Fund. In respect of its services, Adviser pays AVANT a fee equal to a percentage of the net advisory fee received by Adviser on accounts using AVANT signals. ProfitScore Capital Management, Inc. ("PCM"). PCM is under contract with Adviser to provide all buy and sell directions for management of client accounts in Adviser's strategies known as 'Strategic High Yield Bond' and 'WP Income Builder.' In respect of its services, Adviser pays PCM a signal fee equal to generally 20% of the Net Advisory Fee received by Adviser on accounts using PCM signals. Advisor may utilize PCM’s volatility score for any of its strategies, and it may employ PCM as a Commodity Trading Advisor (CTA) for various of Advisor’s sub-advised funds managed with AP. In such event, the CTA customarily charges a fee equal to 2% of the nominal value of the accounts managed by the CTA. Global View Capital Management ("GVCM"). GVCM serves as a Portfolio Manager to Adviser for GPS Model Portfolios, as well as for stand-alone strategies known as Tactical Emerging Markets, Global Macro Equity-Tactical and Global Macro Income-Tactical (the “GVCM Strategies”). In respect of its services, Adviser pays GVCM a fee equal to 5% of the Net Advisory Fee received from those client accounts utilizing the GPS Model Portfolios and 20% of the Net Advisory Fee received from those client accounts utilizing the GVCM Strategies. No payment of the GPS Model Portfolio fee is made on assets upon which a fee is otherwise charged. Active Investment Management ("AIM"). AIM is under contract with Adviser to provide buy and sell directions for management of client accounts in an Adviser strategy known as Contrarian S&P Trading. In respect of its services, Adviser pays AIM a fee equal to generally 20% of the Net Advisory Fee received by Adviser on accounts using AIM signals. 41 #119-0326 Part 2A of Form ADV Firm Brochure  Section 10.B2 – Platform and Operational Relationships The following relationships are primarily operational or involve only the Affiliated Fund sub-advisory fee as compensation. See Section 10.B1 above for relationships with additional conflict-bearing compensation flows. GWM Holdings Inc. ("GWM") — Geneos Axiom. Adviser is under contract with GWM to provide certain model portfolios for the Geneos Axiom strategist program. GWM pays Adviser an annual fee on that portion of assets managed by Adviser pursuant to a tiered rate schedule (amended on October 29, 2018) predicated on the aggregate assets in each account under management as follows: 40 basis points on assets up to $500,000, 35 basis points on assets from $500,001 to $1 million and 25 basis points on assets over $1 million. Envestnet. Adviser is under contract with Envestnet to provide certain model portfolios for their strategist program. Envestnet pays Adviser an annual fee of 33 to 50 basis points on all non QFC model assets under management, billed quarterly. Other model portfolios exclusively utilize QFC Strategies comprised solely of mutual funds sub-advised by Adviser from which Adviser is only compensated by the funds as a sub-advisor. Adhesion. Adviser is under contract with Adhesion to provide certain model portfolios for their platform. All model portfolios exclusively utilize QFC Strategies comprised solely of mutual funds sub-advised by Adviser, for which Adviser is only paid the Affiliated Fund sub- advisory fee. Money Manager X-Change ("MMX") Program — Axos. Adviser is under contract with Axos to provide portfolio management services through participation in the Axos MMX program at its normal fee rates. In respect of its services, Adviser pays Axos an annual program fee of 10 basis points on assets under management billed quarterly. Orion Portfolio Solutions, LLC ("OPS"). Adviser is under contract with OPS to provide certain model portfolios for their platform. All model portfolios exclusively utilize QFC Strategies comprised solely of mutual funds sub-advised by Adviser, for which Adviser is only paid the Affiliated Fund sub-advisory fee. SMArtX Advisory Solutions LLC ("SMArtX"). Adviser is under contract with SMArtX to provide certain model portfolios for their platform. All model portfolios exclusively utilize QFC Strategies comprised solely of mutual funds sub-advised by Adviser, for which Adviser is only paid the Affiliated Fund sub-advisory fee. Amplify Technology, LLC ("Amplify"). Adviser is under contract with Amplify to provide certain model portfolios for their platform. Amplify pays Adviser an annual fee of 90 basis points on all assets under management in model portfolios that do not utilize QFC Strategies, currently Strategic High Yield Bond and Volatility Adjusted NASDAQ. For all model portfolios which utilize QFC Strategies, comprised solely of mutual funds sub- advised by Adviser from which Adviser is only paid its Affiliated Fund sub-advisory fee, Amplify makes no additional payment to Adviser. Schwab. Adviser makes model portfolios available for retirement plan accounts on the Schwab Model Market Center Platform. All model portfolios exclusively utilize QFC Strategies comprised solely of mutual funds sub-advised by Adviser, for which Adviser is only paid the Affiliated Fund sub-advisory fee. 42 #119-0326 Part 2A of Form ADV Firm Brochure  Trading Services. Adviser makes available third-party trading or account-management technology to facilitate order routing, trade execution, model management, or performance reporting. The Adviser does not serve as sub-advisor, exercise investment discretion, and does not provide individualized advice. System users retain sole responsibility for all investment decisions and account supervision. Client assets remain held with an independent qualified custodian, and system users do not have authority to withdraw client funds or securities. Annuity Price Center. Adviser operated the "Annuity Price Center" as a division within its operations center. Institutions and other industry end users received a limited license of Adviser's proprietary software program, which permitted such users to access Adviser's database of daily variable annuity sub-account prices. Adviser and its licensees used the information for current and historical pricing of variable annuity and variable life insurance investments. Annuity Price Center was closed on May 15, 2023. Section 10.C – Indirect Retirement Account Services American Trust & Savings Bank ("ATSB"). Adviser is under contract with American Trust to provide certain investment strategies to ATSB for use on its retirement plan platform. Adviser provides Flexible Leaders strategy models (Conservative, Conservative Growth, Moderate Growth, Growth, and Aggressive Growth) under two (2) separate programs: 1) The Flexible Leaders strategy models are provided as a retirement plan investment option to plans referred by American Trust solicitor representatives. In respect of its services in this program, American Trust pays Adviser a sub-advisory fee of 40 basis points annually applied against assets invested in the models. This fee is not charged to clients and Adviser charges no separate advisory fee to clients in this program; 2) Flexible Leaders strategy models are also provided to retirement plans referred to ATSB by Adviser’s solicitor representatives. See fee schedule, contained herein, under Group Retirement Plans at American Trust. In addition to the aforementioned fee, American Trust pays Adviser a one-time finder’s fee of 0.05% but not less than $500 on each retirement plan so referred. This finder’s fee is paid by American Trust and is not charged to client. clients previously utilizing American Trust have been transitioned to Mid Atlantic Trust Company, see below. ePlan. Mutual funds sub-advised by Adviser are utilized on retirement plans of this company. No separate charge or agreement with Adviser is required. Model portfolios of the fund allocations for various suitability profiles are provided by Adviser for use on this platform. PCS Retirement, LLC ("PCS"). Adviser makes model portfolios available for Adviser’s Strategic Advantage 401(k) retirement plan accounts at Axos, for which the PCS recordkeeping platform acts as sub-custodian. All of the model portfolios exclusively utilize mutual funds sub-advised by Adviser for which Adviser is only paid the Affiliated Fund sub-advisory fee. Adviser currently provides core fiduciary services, QFC Market Leaders, QFC Faith Focused Investing, and QFC Multi-Strategy Portfolios. Strategy offerings are subject to change. Additional QFC strategies may be made available. Mid Atlantic Trust Company ("Mid Atlantic"). Adviser makes model portfolios available for retirement plan accounts on the Mid Atlantic ModelxChange® Platform. All model portfolios exclusively utilize mutual funds sub-advised by Adviser for which Adviser is only paid the Affiliated Fund sub-advisory fee. While all QFC strategies may be made available, Adviser currently provides QFC Market Leaders, QFC Multi-Strategy Core, and QFC All-Terrain. Strategy offerings are subject to change Matrix Trust Company ("Matrix"). Adviser makes model portfolios available for retirement plan accounts on the Matrix Platform. All model portfolios exclusively utilize mutual funds sub-advised by Adviser for which Adviser is only paid the Affiliated Fund sub-advisory fee. While all QFC strategies may be made available, Adviser currently provides QFC Market Leaders and QFC Multi-Strategy Core. Strategy offerings are subject to change 43 #119-0326 Part 2A of Form ADV Firm Brochure  Item 11 – Code of Ethics Code of Ethics. Adviser has adopted a Code of Ethics for all supervised persons as governance for the conduct of its business and fiduciary duty to its clients. Certain conduct is singled out for prohibition. Other conduct is expressly authorized. In general, Adviser's employees are prohibited from placing their own interests ahead of those of Adviser's clients. The Code of Ethics is available upon written request. Participation or Interest in Client Transactions. Adviser, at its discretion, effectuates transactions in the Investments discussed in Item 8 pursuant to a limited power of attorney contained in each investment management agreement or pursuant to a sub-adviser agreement. With respect to Adviser's investment trading strategy, Adviser or its employees may have a position or interest in the Investments utilized by its clients. However, since open-end mutual funds by their nature have large diversified portfolios, and, as all strategy trades made on a given day are assigned the same buy or sell price, there is no allocation policy necessary for such shares or for those shares which have specific morning trading closes as well as end of day closes, but see Allocation of Trades below; Adviser does not restrict its employees or agents with respect to trading in such Investments provided, however, Adviser does not permit its employees to trade on the basis of material, non-public information, or to direct trades of mutual funds or variable annuity sub-accounts as to which Adviser serves as adviser or sub-adviser (“Reportable Funds”) in a capacity other than as an employee of Adviser Employee Personal Securities Trading. At any time Adviser's investment trading strategies involve the purchases and sales of securities other than obligations of the United States, shares of registered open-end mutual funds and/or variable annuity/life sub-accounts (but not including Reportable Funds), Adviser’s stated policy requires that no employee with prior trading knowledge (hereinafter "Associate") shall purchase or sell any security (other than obligations of the United States or shares of registered open end investment companies, excluding Reportable Funds) contemporaneous with a trade of such security by a Reportable Fund. Further, none of Adviser’s Access Persons may acquire an interest in an Initial Public Offering or pursuant to a Private Placement unless such person first obtains the written approval of Adviser’s Chief Compliance Officer. Allocation of Trades. Adviser does not have an allocation policy for mutual fund transactions (see above under “Participation or Interest in client Transactions”) because all Investment transactions (trades) for a strategy, executed on the same day, have the same price. However, Adviser also trades ETFs and ETNs and while all buy or sell trades, on the same platform, executed on the same day are generally accounted for the same price, if Adviser executes trades at differing prices, all trades will be allocated on a “pro rata” basis. In doing so, Adviser will seek to ensure that all clients are treated fairly and equally and to prevent a conflict of interest. Flexible Plan Investments offers investment advice in several programs where investment signals may be provided for identical investment instruments that trade throughout the day. In the event FPI recommends or otherwise effects the purchase or sale of a security for all accounts within a particular strategy, then FPI may have to effect similar transactions through a large number of broker- dealers or market centers. Depending on the liquidity of the security and the size of the transaction, among other factors, FPI may utilize a trade rotation process where one group of clients may have a transaction effected before or after another group of FPI clients, so as to limit the market impact of the transaction. FPI’s trade rotation process is developed and administered at Adviser’s discretion, consistent with its fiduciary duty and best execution obligations, in order to equitably allocate transactions across the entire client base (by trading platform) so that each group of clients can expect over time to receive executions at the beginning, middle and the end of the rotation. As a result, clients should understand that FPI’s trade rotation process may result in a transaction being effected in their account that occurs near or at the end of the FPI’s rotation and such transactions may significantly bear the market price impact, if any, of those trades executed earlier in the rotation. Given the number of platforms on which Adviser’s strategies are implemented, trade sequencing may result in differences in execution timing and price. While Adviser seeks equitable treatment over time, execution prices may vary among clients. 44 #119-0326 Part 2A of Form ADV Firm Brochure  FPI’s trade rotation policy utilizes an A to Z format. Each time a strategy change is made to a model strategy, that change will be communicated in order to platform A, platform B, etc. FPI’s directly traded discretionary client accounts will be considered a platform in the rotation. Each time a strategy change is made, the trading/communication rotation will be advanced by one platform. For example, for the first strategy change, communication/trading will be to platform A, platform B, platform C. The next strategy change the order will be platform B, platform C, platform A, etc. Item 12 – Brokerage Practices Occasionally Adviser may suggest the broker or brokers to be utilized. Normally client is already utilizing a specific broker or specifies a broker to be used. Adviser may have some clients who do not specify a broker, and in those cases, Adviser may suggest a broker. Some strategies are customized for specific brokerage platforms and may charge fees, utilize Investments unavailable on other platforms or, conversely, not use Investments available on other platforms. As a result, strategy performance may differ between platforms. Adviser seeks to obtain best execution for client transactions, considering factors such as price, liquidity, execution capability, and overall transaction costs. Adviser does not receive soft-dollar benefits that affect its brokerage selection decisions. In trading client mutual fund accounts, Adviser uses Investments that do not charge a trading or sales commission for their purchase. With respect to clients who have participated in registered investment company investment programs the investment companies utilize specific commission schedules. Most provide for discounts based upon the dollar amount invested. Some provide for back-end redemption fees in lieu of front-end fees. Clients should note that fees or commissions of investment companies, brokers, or custodians are in addition to management fees incurred for Adviser's services. Benefits from Broker-Dealers and Other Parties. Adviser receives from certain broker-dealers, trust companies, mutual funds, variable annuities, and other investment advisers’ computer software and services related to account management that permit Adviser to better monitor client accounts and execute trading in Investments. Adviser also receives research, educational information, and training programs from such parties, as well as occasional conference attendance, travel and lodging, and gifts of nominal value. Certain of the support services and/or products received may assist Adviser in marketing and in managing and administering client accounts. Others do not directly provide such assistance but assist Adviser's research and investment methodology. Soft-Dollar Reconciliation. The benefits described above — including computer software and services, training programs, conference attendance, travel and lodging, and gifts of nominal value — are not soft-dollar arrangements within the meaning of Section 28(e) of the Securities Exchange Act of 1934. Adviser does not direct client brokerage transactions to any broker in exchange for any of these benefits. The benefits are provided by third parties in connection with Adviser's overall business relationship with those parties, not in exchange for client order flow. The services received by Adviser are not related to the amount of transaction fees paid by clients and, therefore, clients are not charged increased transaction fees by such persons by reason of the services provided to Adviser. Adviser may also suggest that clients use a custodian other than a broker-dealer, such as a bank or trust company. All such custodians are unaffiliated with Adviser. Any such custodian is under separate contract with the client for custodial and reporting services. CCO Consulting Services. Adviser's Chief Compliance Officer ("CCO") remains available to address any questions that a client or prospective client may have regarding the above arrangements and any corresponding perceived conflicts of interest. Adviser's CCO also provides compliance consulting services to Ceros Financial Services, Inc. in exchange for a nominal amount of additional compensation. The CCO's consulting services to Ceros do not affect Adviser's investment recommendations or brokerage practices. 45 #119-0326 Part 2A of Form ADV Firm Brochure  Item 13 – Review of Accounts Reports and other communications described below may be delivered to clients by surface mail, email, or posting on Adviser's flexibleplan.com or ontargetinvesting.com websites. Monthly/Quarterly Review. Investment advisory accounts are computer-tracked by employees of Adviser from statement data received from the Investment vehicles or brokerage firm through which the Investment is purchased. Such data is compared against the model strategy's current allocation to monitor for any deviations. Accounts are reviewed when fees are billed. In addition to the receipt of such data, requests by a client, or the passage of time (the ending of a month or quarter), Adviser also performs an automated review of each client account to determine if strategy changes are appropriate. Adviser conducts a similar review at the time of a change of address request and a request fora distribution to a third party. Because verification of these requests may take time and involve the availability and responsiveness of the client and/or its agent, there may be a delay occasioned in implementing such a request. Furthermore, accounts, including in-house accounts, are periodically reviewed utilizing Advisers MBA tool, discussed below. Again, this review is subject to client and agent availability and responsiveness. It is also reasonably available upon client’s or Agent’s request. Reporting. In addition to the reports described herein that are sent directly by Adviser, clients receive from an independent qualified custodian, not less frequently than quarterly, an account statement detailing the account's investment activity, earnings and distributions, additions and withdrawals, fees deducted, and beginning and ending account values. Clients should rely on custodial statements as the official record of account holdings and transactions. Adviser newsletters are sent quarterly. Invoices show the value of the account at the end of the quarterly or monthly period billed. A Weekly Update is provided to clients describing the firm's investment perspective and any strategy changes made during the preceding week. Furthermore, financial advisors and their firms are provided with daily account information related to accounts upon which they are the solicitor or co-advisor, together with analytical screens to continually access suitability and performance. OnTarget Investing. OnTarget Investing is a monthly reporting process employed by Adviser. The process seeks to provide client and Adviser with the tools to monitor whether client investments are actually performing in a manner that fits with client suitability questionnaire responses and is consistent with expectations based on the benchmarks of their individual strategy portfolios. For new clients, this process is intended to let client know their relative performance from the beginning through utilizing each strategies individual benchmark. OnTarget client statements and proposals show new and existing clients their Investment Portfolio Rating and translate what that means in terms of the types of Investments used and the expectations applicable to each category of Investment. The rating is based on Client’s latest Suitability Questionnaire on file with Adviser. In the client statements, one of five (5) styles is referenced: Conservative, Moderate, Balanced, Growth or Aggressive. A Market Commentary is provided dealing with the general action of the stock, bond and international markets during the quarter (to put the actions of client accounts in a market perspective) and also a discussion of the significant changes that occurred in each client’s portfolio during the quarter is provided. Risk and Volatility tools are included and are designed to give clients perspective on the risk being taken in their respective portfolios compared to popular market indexes. The Barometer compares the volatility (the variability in the value) of each client’s portfolio to that of the indexes. A Risk Target may be provided that focuses on the historical downside of the strategies employed in each client’s portfolio and relates it to the downside of the S&P 500 and NASDAQ stock market indices. Finally, the OnTarget Monitor applies the 46 #119-0326 Part 2A of Form ADV Firm Brochure  power of Monte Carlo analysis, using hundreds of computer simulations to generate projections of the probability outcomes for each client’s account utilizing the benchmarks of the strategies employed. It allows Adviser to chart a probability-derived path for each client’s Investments during their investment time horizon consistent with the assumptions disclosed, and then tracks their actual account progress against that pathway. The OnTarget Monitor and risk measurement tools are provided for information purposes only. They are designed to alert clients and their advisors to risk and return information about their investments. They are not meant to suggest specific courses of action other than the suggestion to consult with clients when strategies are found to be “in the red or yellow”. The ultimate choice of the strategy or combination of strategies used by a client is a matter of choice of the financial advisor and/or client. FPI follows the directions of same in managing a client account. As a part of the Adviser’s internal strategy-level review procedures a weekly report using the Monte Carlo analysis is generated for Adviser Strategic Solutions’ and ETF strategies from actual model account data. Strategies found to be “in the red or yellow” on the underlying Monte Carlo report are flagged, and remedial action may be taken with respect to the strategy on the strategy-level after an Adviser determined period of low probability performance. My Business Analyzer (MBA). My Business Analyzer (MBA) is a reporting tool made available to financial representatives and their firms, located on Adviser's website. The MBA provides financial representatives access to the latest business data, including account summaries, strategy performance, and client reports. Item 14 – Client Referrals and Other Compensation Co-Adviser Model. Under the co-adviser business model, Flexible is introduced to clients by the co-adviser who accepts fiduciary responsibility to undertake management of the client relationship and monitor Flexible's activities and performance on behalf of the client. Solicitor Model. In the context of its solicitor business model, Adviser is introduced to clients by solicitor firms such as broker-dealers, other investment advisers, and other qualified persons that serve as solicitor for Adviser, none of whom are affiliated with Adviser. Co-adviser and solicitor firms receive ongoing annual compensation from Adviser as part of the total advisory fee collected from client accounts. Consistent with the fee structure disclosed in Item 5 of this brochure, the total advisory fee collected by Adviser from each client account consists of two components: (1) Adviser's (FPI's) retained advisory fee for investment management services, which is tiered by account size and decreases as balances grow; and (2) a flat-rate annual compensation component for the co-adviser or solicitor, which is selected by the financial adviser within the ranges established by the applicable Third Party Fee Agreement and does not change with account size. This flat-rate component is collected by Adviser from the client's account and paid through to the co-adviser's or solicitor's employing or contracting firm. Agents are never paid directly by Adviser. The specific rates applicable to each client's account are set forth in the Separate Written Disclosure attached to the client's IMA. See Item 5.E for program-by- program fee schedules. On larger accounts, because FPI's tiered advisory fee decreases substantially at higher AUM tiers while the co-adviser or solicitor's flat rate remains constant, the Co-adviser or Solicitor may receive a higher percentage of the combined fee than Adviser retains. This is a material conflict of interest that is disclosed in Section 4.G and managed through fee caps and mandatory Separate Written Disclosure. Clients are encouraged to review their Separate Written Disclosure carefully. Adviser may provide marketing support or services to assist its co-advisers and solicitors and their firms. This support may take the form of payment of certain expenses, such as fees to allow Adviser to participate in sales conferences of the firms, to present seminars for prospective and existing clients, to cover expenses for attendance at informational meetings held by Adviser, and reimbursement of costs for sales promotional activities. 47 #119-0326 Part 2A of Form ADV Firm Brochure  Co-adviser and solicitor firms may receive additional sales compensation, directly or indirectly, from mutual funds or insurance products that may have been purchased by client during and prior to entering the management. In all cases, the firms have significant financial incentives to recommend Adviser over other available advisers or services. Optional Establishment Fee: In addition to the ongoing annual advisory fee, for applicable accounts (see Item 5.E), at the option of the financial adviser, Adviser charges a one–time, non-refundable Establishment Fee of up to 1.20% of the initial investment. Of this fee, 0.20% is retained by Adviser (FPI) and up to 1.00% is paid to the Solicitor or Co-Adviser. The Establishment Fee will be deemed earned by the Solicitor firm only if client was referred in the first instance to Adviser by the firm and client had not been previously referred to Adviser by any other party. Regional Business Consultants, Internal Business Consultants, and Internal Associates. Adviser pays Regional Business Consultants ("RBCs"), Internal Business Consultants ("IBCs"), and Internal Associates ("IAs") to solicit clients for its management. RBCs, IBCs, and IAs are employees of Adviser. Payments may take the form of salaries, commissions, finder's fees, reimbursement of third-party expenses, or any or all of such payments. Adviser pays all RBCs, IBCs, and IAs a base salary and compensation based in whole or in part on revenues generated or assets placed under management from the RBC's, IBC's, and IA's geographic territory. Such compensation is separately negotiated. Client pays no additional fee by reason of the payment of these fees. RBCs and IBCs may also sell the Quantified Funds; they are compensated and supervised by Ceros for this activity pursuant to a separate independent contractor agreement. Payment Agent Arrangement: Adviser also forwards payments from the Affiliated Funds' distributor (Ceros Financial Services, Inc.) to broker-dealers who offer, sell, or promote Adviser Class shares of the Affiliated Funds. While the strategies offered are different for Investor and Adviser share class investors, this arrangement creates an incentive for financial representatives to recommend Adviser Class shares over Investor Class shares because Adviser Class shares generate a 60 basis point marketing fee. See Items 5.F and 10.B1 for full disclosure of this arrangement. SDBA Share-Class Differential: Clients accessing Adviser's QFC strategies through Self-Directed Brokerage Accounts (SDBA) may hold either Investor Class or Adviser Class shares of the Quantified Funds. While the strategies offered are different for Investor and Adviser share class investors, Adviser Class shares carry higher internal fund expenses and generate the 60 basis point marketing fee described above, which is paid to the financial adviser’s Firm. Clients should discuss with their financial representative which share class applies to their SDBA account and the cost implications. See Items 5.F and 8.I. Item 15 – Custody Adviser does not provide custodial services to its clients. Client assets are held with non-affiliated "qualified custodians." However, Adviser has authority to debit fees directly from client accounts, and therefore Adviser is deemed to have constructive custody of those assets for regulatory purposes. Clients should receive account statements directly from qualified custodians not less frequently than quarterly and are urged to carefully review those statements and to promptly report any discrepancies to Adviser. Adviser statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation and performance measurement methodologies of certain securities. Item 16 – Investment Discretion Adviser obtains advance, one-time written discretionary authority to execute the type of transactions it deems necessary to implement the investment strategy selected by client. However, such discretion does not extend to withdrawal of client funds except where client has authorized withdrawal in payment of fees, such as investment advisory fees, establishment fees or set-up fees due Adviser, and then only to the extent of such fees. Adviser, at its discretion, effectuates transactions in the Investments discussed in Item 8 pursuant to a limited power of attorney contained in each investment management agreement or pursuant to a sub-adviser agreement. Client may impose reasonable restrictions on the management of client’s account. In the event that a requested restriction is clearly inconsistent with Adviser’s stated investment strategy or client’s stated investment objectives, or is fundamentally inconsistent with the operation of Adviser’s program, client will be advised in writing that client’s requested restriction is deemed unreasonable and client 48 #119-0326 Part 2A of Form ADV Firm Brochure  will be afforded opportunity to restate client’s restriction. If client is unable or unwilling to modify an unreasonable restriction, this Agreement may be terminated. Item 17 – Voting Client Securities As a matter of firm policy and practice, Adviser does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for all securities maintained in client's portfolios. Generally, Adviser neither advises nor acts on behalf of clients with respect to voting proxies. Clients wishing to discuss proxy voting should contact their custodian directly. Item 18 – Financial Information Registered investment advisers are required in this Item to provide clients with certain financial information or disclosures about Adviser's financial condition. Adviser has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and Adviser has not been the subject of a bankruptcy proceeding. See also: Cybersecurity Disclosure (End Matter) for a description of Adviser's cybersecurity safeguards and incident notification procedures. Privacy Notice The following notice is furnished to clients and prospective clients in compliance with SEC Regulation S-P: Flexible Plan Investments, Ltd. ("Flexible Plan," "we," "us," or "our") is committed to protecting your privacy. To provide the products and services you expect from us, we necessarily need to collect and use certain information about you. We are also committed to the responsible use of your information and protecting your individual privacy rights. We and other financial companies choose how we share your personal information. Federal and state law gives you the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Personal Information We Collect. For purposes of this Policy, "Personal Information" is defined as information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular consumer or household. This section describes the categories of Personal Information we may collect or have collected from or about you within the last twelve (12) months. Categories Examples Business Purpose Identifiers Name, address, email, SSN, IP address, account name Account setup, authentication, regulatory compliance Personal Information Account management and servicing Name, signature, SSN, address, phone, employment history Financial Information Suitability assessment, advisory services Account number, income, investment objectives, net worth, tax bracket Age, race, medical condition (if disclosed) Regulatory compliance only Protected Classification Characteristics Commercial Information Account review and reporting Products or services purchased, investment history Sensory Data Audio/video recordings (if calls recorded) Quality assurance Internet/Network Activity IP address, browsing history on our sites Website security and analytics Personal Information does not include: • Publicly available information from government records. • De-identified or aggregated consumer information. 49 #119-0326 Part 2A of Form ADV Firm Brochure  Sources of Personal Information. Flexible Plan may collect Personal Information from: the application and/or account creation process; web-based or other forms completed by consumer or consumer's authorized representative; consumer transactions with or through Flexible Plan; consumer's registered investment adviser if the RIA uses Flexible Plan's technology to manage the consumer's assets; social media and online forums when consumer interacts with Flexible Plan pages; direct communications between Flexible Plan and consumer; and third- party service providers. Purposes for Collection and Use of Personal Information. In the last twelve (12) months, we may have used Personal Information to: identify you as our customer; conduct regular business including processing your requests and providing advisory services; market additional services; conduct research; provide education and training to our workforce; ensure legal compliance; measure and analyze website traffic; customize your website experience; protect against security incidents and prevent fraud; and as otherwise permitted or required by law. How We Share Your Personal Information. We may share your Personal Information with: our service providers; our agents and representatives; our business referral sources; your agents, representatives, and any other persons acting on your behalf; persons authorized by applicable law; persons to whom you have consented to disclosure; and as otherwise required by applicable law. Securing Your Personal Information. We use commercially reasonable safeguards to protect your information from unauthorized use, access, and disclosure. Our employees are trained to handle Personal Information responsibly and are required to follow our policies regarding its use and protection. Cookies and Similar Technology. Flexible Plan uses various tools to collect data when you visit our sites and apps, including cookies, pixels, web beacons, and other similar technologies. These technologies may be used to enhance your experience, analyze site traffic, and provide personalized content. Your web browser can be set to reject cookies, but some website functionality may be lost as a result. Your Rights Regarding Your Personal Information. Federal law gives consumers and customers the right to limit some but not all sharing of their information. You may opt out of sharing by calling 1-800-347-3539 or emailing gsmith@flexibleplan.com. If you provide us with a mobile phone number, you are agreeing to SMS communication with Flexible Plan. Information collected for SMS consent will not be shared with third parties or affiliates. See also: Cybersecurity Disclosure (below) for information about how Adviser protects the electronic security of your Personal Information. Cybersecurity Disclosure The following disclosure describes Adviser's cybersecurity policies and procedures. Cybersecurity risk is also addressed in Item 8, Section L (Consolidated Risk Factors). Clients should read both disclosures. Written Cybersecurity Policy. Adviser has adopted a written cybersecurity policy designed to protect the confidentiality, integrity, and availability of client data and firm systems. The policy is reviewed at least annually and updated to reflect changes in Adviser's business and the threat environment. Technical and Administrative Safeguards. Adviser's cybersecurity program is designed to include reasonable technical and administrative safeguards, which may include: access controls and user authentication procedures designed to limit system access to authorized personnel; encryption of sensitive client data in transit and at rest; network monitoring and intrusion detection systems; regular security training for all employees; and periodic testing of systems and controls. Third-Party and Vendor Oversight. Adviser engages third-party service providers, technology vendors, and custodians who may access, store, or process client data. Adviser's cybersecurity program is designed to include reasonable due diligence on third-party service providers and requirements that such providers maintain appropriate security measures. 50 #119-0326 Part 2A of Form ADV Firm Brochure  Incident Response. Adviser maintains an incident response plan designed to guide its response to cybersecurity incidents. In the event of a cybersecurity incident that Adviser determines has materially affected or is reasonably likely to materially affect clients, Adviser will notify affected clients in accordance with applicable regulatory requirements. Internet Transmission Limitation. Communications transmitted via the internet, including through Adviser's client portals, websites, or email, are subject to interception or disruption by third parties. Adviser's technical safeguards are designed to reduce this risk but cannot eliminate it. Clients are encouraged to use secure connections and to report any suspected unauthorized access to their accounts immediately. Reporting Contact. Clients who have questions about Adviser's cybersecurity practices, or who believe they have experienced a security incident involving their account, should contact the Compliance Department at: 800-347-3539 or gsmith@flexibleplan.com. 51 #119-0326 Part 2A of Form ADV Firm Brochure  Appendix A – Grandfathered Fee Schedules APPLIES ONLY TO CLIENTS CURRENTLY BILLED UNDER THESE SCHEDULES. THESE RATES ARE NOT OFFERED TO NEW ACCOUNTS. IF YOU ARE UNSURE WHICH FEE SCHEDULE APPLIES TO YOUR ACCOUNT, PLEASE REFER TO YOUR MOST RECENT INVOICE OR CONTACT THE COMPLIANCE DEPARTMENT AT 800-347-3539. Note Regarding FPI/Solicitor Fee Split: The grandfathered fee schedules set forth below reflect combined total advisory fee rates established under prior agreements. These agreements predate the current FPI/solicitor fee split structure described in Item 5.E. For grandfathered accounts, the allocation between FPI's retained advisory fee and the Solicitor or Co-adviser's compensation is governed by the terms of the client's specific Investment Management Agreement and applicable Third Party Fee Agreement, as disclosed in the Separate Written Disclosure attached to the client's IMA. FFS Accounts Established Prior to January 18, 2018. For accounts utilizing the FFS fee schedule and established prior to the January 18, 2018 reduction in the maximum allowable advisory fee to 2.25%, the following maximum advisory fee rates continue to apply: 2.6% on the first $500,000 of assets; 2.35% on the next $500,001 to $999,999; and 2.10% on the next $1,000,000 and up. Single Fee Rate Structure — July 1, 2003 through January 19, 2018. A single fee rate structure on new sales was effective July 1, 2003 and remained effective through January 19, 2018 for all services named below. Annual fees are billed pro-rata in arrears at the end of each calendar quarter at an annual rate of 2.6% on the first $100,000 of assets; 1.8% on the next $400,000; and 1.5% on assets in excess of $500,000 and up to $1,000,000; and 1% on all assets in excess of $1,000,000. Fees in The Flex Plan are set as described under the Group Retirement Plan section of Item 5. Accounts Established September 1, 2007 through March 31, 2019. (1) The fee rate (not to exceed 2% annually, subject to a quarterly $130 minimum account maintenance fee) is governed by the terms and conditions in client's specific Investment Management Agreement; (2) for accounts established through soliciting firms that executed a Flexible Fee Addendum and pursuant to Adviser's Flexible Fee Schedule, the maximum fee rate is 2.6% annually (also subject to the quarterly $130 minimum). The fee amounts are those specified in client's specific FFS version of the IMA. Accounts Established After March 31, 2009 (Small Account Provisions under Prior Schedules). For accounts established after March 31, 2009 under the applicable fee structure then in effect: (1) the quarterly $130 minimum account maintenance fee is eliminated; (2) for accounts established with an initial value of less than $25,000, a non-refundable Small Account Set-Up Fee is charged equal to the lesser of 3% of the account initial value or $350; and (3) the Establishment Fee cannot be charged to an account that incurs a Small Account Set-Up Fee. Advisory fee rate shall not exceed 2.0% for any tier of Billable Balance for accounts subject to a Small Account Set-Up Fee. 52 #119-0326 Part 2A of Form ADV Firm Brochure  Supplement Jerry C. Wagner Flexible Plan Investments, Ltd. 3883 Telegraph Rd., Suite 100 Bloomfield Hills, MI 48302 800-347-3539 Item 1 March 31, 2026 This Brochure Supplement provides information about Jerry C. Wagner, a supervised person, which supplements Flexible Plan Investments, Ltd.’s Brochure. You should have received a copy of that Brochure. Please contact our Compliance Department at 800- 347-3539 or gsmith@flexibleplan.com if you did not receive Flexible Plan Investments, Ltd.’s Brochure or if you have any questions about the contents of this supplement. Additional information about Jerry C. Wagner is available on the SEC’s website at www.adviserinfo.sec.gov. 1 #119-0326 Part 2A of Form ADV Firm Brochure  Item 2 – Educational Background and Business Experience Jerry C. Wagner, JD is President and Chief Investment Officer of Flexible Plan Investments, Ltd. Mr. Wagner was born in 1947. He holds the degree of Juris Doctor awarded by the University of Michigan in 1973 and degrees of Masters in Labor & Industrial Relations (1970) and Bachelor of Arts (1969) from Michigan State University. Mr. Wagner has been a member of the State Bar of Michigan since 1973. He has been the principal investment officer for Flexible Plan Investments, Ltd. since 1981. Mr. Wagner has a Series 65. His business experience for the last 5 years is as follows: Flexible Plan Investments, Ltd. Investment Adviser President and CEO February 1981 to Present Wagner and Associates Attorney at Law Founded in 1988 to Present State Bar of Michigan Member 1973 to Present Dynamic Performance Publishing, Inc. Financial Publishing Company President and 100% Owner June 2013 to Present Item 3 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4 – Other Business Activities Mr. Wagner is not involved in any other investment related business but he is a licensed attorney at law and Member of the State Bar of Michigan; was a general partner in Welch Wagner Associates, a real estate partnership management company. He spends an immaterial amount of his time in these capacities. Mr. Wagner is President and 100% owner of a publishing company, Dynamic Performance Publishing, Inc., which publishes The Proactive Advisor Magazine and various other financial publications. Item 5 – Additional Compensation Mr. Wagner does not receive any additional compensation beyond his salary, bonus and Sub-chapter S earnings from his controlling ownership of Adviser, a Michigan Sub-chapter S corporation and from his 100% ownership of Dynamic Performance Publishing, Inc., a Michigan Sub-chapter S Corporation. Item 6 – Supervision Although Mr. Wagner is an attorney knowledgeable in securities law, his advisory activity is monitored through the firm’s Compliance Department. 2 #119-0326 Part 2A of Form ADV Firm Brochure  Supplement Daniel Poppe, CFA Flexible Plan Investments, Ltd. 3883 Telegraph Rd., Suite 100 Bloomfield Hills, MI 48302 800-347-3539 Item 1 March 31, 2026 This Brochure Supplement provides information about Daniel Poppe, CFA, a supervised person, which supplements Flexible Plan Investments, Ltd.’s Brochure. You should have received a copy of that Brochure. Please contact the Compliance Department at 800- 347-3539 or gsmith@flexibleplan.com if you did not receive Flexible Plan Investments, Ltd.’s Brochure or if you have any questions about the contents of this supplement. 3 #119-0326 Part 2A of Form ADV Firm Brochure  Item 2 – Educational Background and Business Experience Daniel Poppe, CFA, Portfolio Manager. Mr. Poppe was born in 1996. He holds a Bachelor of Science degree in Finance as well as one in Business Economics from Oakland University where he graduated magna cum laude. Mr. Poppe holds the designation of Chartered Financial Analyst (CFA)*. His business experience for the last 5 years is as follows: Flexible Plan Investments, Ltd. Portfolio Manager March 2024 – Current Senior Research Analyst 2022 – March 2024 Research Analyst 2021 – 2022 Junior Research Analyst 2019 - 2021 *A Chartered Financial Analyst (CFA) is obtained through a graduate level self-study program and examination. This program emphasizes real-world investment analysis and portfolio management skills in combination with high ethical and professional standards. Item 3 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4 – Other Business Activities Mr. Poppe does not engage in any other investment related business or in any other non-investment related business. Item 5 – Additional Compensation Mr. Poppe does not receive any additional compensation beyond his salary and bonus. Item 6 – Supervision Mr. Poppe works directly under the supervision of Jerry C. Wagner, President and Chief Investment Officer. Mr. Poppe’s activity is also monitored through the firm’s Compliance Department. 4 #119-0326 Part 2A of Form ADV Firm Brochure  Supplement Noah Campbell Flexible Plan Investments, Ltd. 3883 Telegraph Rd., Suite 100 Bloomfield Hills, MI 48302 800-347-3539 Item 1 March 31, 2026 This Brochure Supplement provides information about Noah Campbell, a supervised person, which supplements Flexible Plan Investments, Ltd.’s Brochure. You should have received a copy of that Brochure. Please contact the Compliance Department at 800- 347-3539 or gsmith@flexibleplan.com if you did not receive Flexible Plan Investments, Ltd.’s Brochure or if you have any questions about the contents of this supplement. 5 #119-0326 Part 2A of Form ADV Firm Brochure  Item 2 – Educational Background and Business Experience Noah Campbell, Portfolio Manager. Mr. Campbell was born in 1997. He holds a Bachelor of Science degree in Finance from The King’s College where he graduated cum laude. His business experience for the last 5 years is as follows: Flexible Plan Investments, Ltd. Portfolio Manager November 2025 – Current STF Management, LP Portfolio Specialist April 2022 - October 2025 AllianceBerstein Senior Associate June 2019 – April 2022 Item 3 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of each supervised person providing investment advice. No information is applicable to this Item. Item 4 – Other Business Activities Mr. Campbell does not engage in any other investment related business or in any other non-investment related business. Item 5 – Additional Compensation Mr. Campbell does not receive any additional compensation beyond his salary and bonus. Item 6 – Supervision Mr. Campbell works directly under the supervision of Jerry C. Wagner, President and Chief Investment Officer. Mr. Campbell’s activity is also monitored through the firm’s Compliance Department. 6 #119-0326 Part 2A of Form ADV Firm Brochure