Tc Financial Management, Co. Inc.

TC Financial Management Co., Inc. 7811 Atlantic Ave, Suite A Margate, NJ 08402 609-487-1805 September 1, 2026 www.tcfinancialmgmt.com This Brochure provides information about the qualifications and business practices of TC Financial. If you have any questions about the contents of this Brochure, please contact us at above number or email douglas.cakert@tcfinmgt.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. TC Financial is a registered Investment Adviser with the Securities and Exchange Commission. 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 TC Financial also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes TC Financial Management Co., Inc. is required to disclose any material changes to this ADV Part 2A here in Item 2. There are no material changes to report at this time. 2  Item 3 -Table of Contents Item 2 – Material Changes .................................................................................................................................... 2 Item 3 -Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Business ................................................................................................................................... 4 Item 5 – Fees and Compensation.......................................................................................................................... 4 Item 6 – Performance-Based Fees and Side-By-Side Management ...................................................................... 6 Item 7 – Types of Clients ....................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 6 Item 9 – Disciplinary Information ....................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 10 Item 11 – Code of Ethics ..................................................................................................................................... 10 Item 12 – Brokerage Practices ............................................................................................................................ 10 Item 13 – Review of Accounts ............................................................................................................................. 13 Item 14 – Client Referrals and Other Compensation .......................................................................................... 13 Item 15 – Custody ............................................................................................................................................... 14 Item 16 – Investment Discretion......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information .......................................................................................................................... 14 ADV Part 2B: Thomas FX Cakert i ADV Part 2B: Douglas Cakert ii 3  Item 4 – Advisory Business TC Financial (TCF) is a Securities and Exchange Commission (SEC) Registered Investment Advisory Firm that was established in 1995. It is owned by Thomas FX Cakert, a Certified Financial Planner (CFP) and Retirement Income Certified Professional (RICP), and Douglas B Cakert, who is also a CFP. Investment Advisory Services_________________________________________________________________ TCF customizes its advisory services and builds out an investment allocation portfolio to the specific needs and goals of the client. The client's personal investment plan contains an asset allocation target of which TCF creates and manages a portfolio based on that plan and allocation targets through Morningstar Workstation, for research and portfolio constructions. Clients may impose restrictions on investing in certain securities or types of securities. TCF provides continuous advice to clients regarding the investment of their funds based on the individual needs of the client. Financial Planning Services___________________________________________________________________ For investment advisory clients, TCF develops financial plans and uses those plans to make the appropriate investments on their behalf in their advisory accounts. The first step is a one-on-one meeting where the client expresses their financial goals and tolerance for risk. From there TCF reviews the totality of a client’s financial circumstances, which include assets, liabilities, and overall cash flow. As of December 31, 2025, TC Financial had $122,726,140 under management; all of which was on a discretionary basis. Item 5 – Fees and Compensation A. Fees Charged TCF provides continuous advice to clients regarding the investment of funds based on individual needs and objectives. All individuals will be required to execute an agreement with TCF outlining the services to be performed, as well as the fees for those services. Clients are under no obligation at any time to engage or to continue to engage, TCF for investment services. If clients do not receive a copy of this brochure at least 48 hours prior to the execution of an agreement, clients may terminate the agreement within the first five (5) business days without penalty. TCF’s standard advisory fee is based on the market value of the assets under management and is calculated as follows: Annual Advisory Fee 1.% .75% .625% .50% Account Value First $0 - $250,000 Amounts over $250,000 - $499,999 Amounts over $500,000 - $999,999 Amounts over $1,000,000 4  The fee is payable quarterly in advance and is based on the gross asset value as of the last market day of the previous quarter. The advisory fee is a tiered fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart and applying the fee to the gross asset value as of the last market day of the previous quarter. No increase in the annual fee shall be effective without agreement from the Client by signing a new agreement or amendment to their current advisory agreement. The first fee payment is due upon execution of the Investment Advisory Agreement and will be assessed pro-rata in the event the agreement is executed at any time other than the first business day of a calendar quarter. The pro-rata calculation will begin on the first day of the calendar month that follows the execution of the Investment Advisory Agreement (for example, if the Investment Advisory Agreement is executed in January, pro-rata billing will begin February 1st). Advisory fees are directly debited from client accounts. Clients may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period, based on the amount of time remaining in the billing period. Ongoing Financial Planning Ongoing Financial Planning services are included in the quarterly fee. Fee Payment B. TCF’s client advisory agreement authorizes the custodian of the client’s account to debit the account for the amount of TCF’s investment management fee and to directly remit that management fee to TCF in accordance with required SEC procedures. To implement that procedure, the client will provide written authorization permitting the advisory fees be deducted from their account held at the custodian. The custodian will send, at least quarterly, to client a statement reflecting the fee paid to TCF. All asset management fees will be calculated on a quarterly basis, in advance, and the value used will be the gross asset value as of the last market day of the previous quarter. The “gross” asset value relates to the limited number of clients who, at their own election, choose to have margin accounts, which may increase the amount of assets through borrowing. This means that if your annual fee is 1.00%, then each quarter we will multiply the value of your account by 1.00%, then divide 4 to calculate our fee. Additionally, to the extent there is cash in a client’s account, it will be included in the value for the purpose of calculating fees. Other Fees C. There are a number of other fees that can be associated with holding and investing in securities. You will be responsible for fees including transaction fees for the purchase or sale of a mutual fund or Exchange Traded Fund, or commissions for the purchase or sale of a stock. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the mutual fund manager. For complete discussion of expenses related to each mutual fund, you should read a copy of the prospectus issued by that fund. TCF can provide or direct you to a copy of the prospectus for any fund that we recommend to you. 5  Pro-rata fees D. If a client engages TCF to provide asset management services during a billing quarter, the fees for that quarter will be pro-rated according to the number of days left until the next quarter. Likewise, if a client terminates services during a quarter, the client will receive a refund for fees collected in advance but related to services that would have been provided from the date of termination through the end of the billing quarter. Advisory service contracts may be terminated on 30 days’ notice by either client or TCF. If contract is terminated, the unearned portion of any prepaid fee will be refunded to client. TCF will calculate the total fee that would be due for the quarter, divide the fee by the number of days in the quarter to arrive at a daily rate, count the number of days the client was or will be a client during that quarter (as applicable) and multiply that number by the daily rate. TCF will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de-linked”, meaning they will no longer be visible to TCF and will become a retail account with the custodian. Item 6 – Performance-Based Fees and Side-By-Side Management TCF 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). Item 7 – Types of Clients TCF provides portfolio management services to individuals, and trusts and estates. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Strategies A. TCF focuses on long-term investment objectives. We do not attempt to time the market or to make significant adjustments to take advantage of short-term market moves. We also do not use technical analysis to predict the direction of future market moves. Rather, our investment philosophy is grounded in the belief that the most appropriate strategy for the long-term investor is to have a properly allocated investment portfolio that matches investment objectives and risk-tolerance levels with the appropriate investment vehicles. TCF uses mutual funds rather than individual securities as the primary vehicle for the investment of client’s funds. Investing through no-load mutual funds provides a low-cost method of investing that we believe is more advantageous than individual securities. These advantages include: a higher degree of diversification which reduces risk; security selection by professional managers and analysts that have track records measured and monitored by independent services; a greater degree of flexibility which allows for adjustments to a portfolio quickly and easily without the costs associated with buying and selling individual securities. A Morningstar client questionnaire and/or personal consultations are used to clarify a client’s investment objectives and risk-tolerance level. Utilizing a computerized base of mutual funds that tracks risk-adjusted returns, an individualized portfolio of mutual funds is constructed to meet the client’s investment objectives 6  within the prescribed risk levels. B. Material Risks TCF’s primary strategies do not include frequent trading of securities. It is impossible to name all possible types of risks. Among the risks are the following: Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that while TCF does not consider short- term trading a strategy for its clients, trades may be made with frequency if conditions and client goals merit it. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. TCF endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an advisor who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the advisor to reach satisfactory investment conclusions. 7  • Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently than larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited as compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short-term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • Concentration Risk. While TCF selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • Transition Risk. As assets are transitioned from a client’s prior advisors to TCF, there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Where possible, TCF will maintain securities that come from the client’s existing accounts and will not sell a security merely to push the portfolio into line with other accounts TCF manages. However, in some instances, selling a security is advisable despite costs. TCF’s goal is to minimize costs, which means that the overall transition process to TCF may take some time as cost considerations are compared with client needs. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of TCF may adversely affect the client's account values, as TCF’s recommendations may not be able to be fully implemented. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. In addition, significant restrictions may lead to TCF needing to increase the management fee rate. • Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had if the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. C. Security Types As discussed above, TCF primarily recommends mutual funds and ETFs. However, TCF may also utilize stocks and bonds. 8  Risks Associated with Securities Exchange Traded Funds: Prices may vary significantly from the Net Asset Value due to market condition. Certain Exchange Traded Funds may not track underlying benchmarks as expected. ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which the clients invest. Mutual Funds: When a client invests in open-end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client's overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). When selecting mutual funds that have multiple share classes for recommendation to clients, the Adviser will take into account the internal fees and expenses associated with each share class, as it is our policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. Fixed Income: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by the Fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. Equity Securities: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. REIT Exchange Traded Funds: REIT ETFs invest their assets primarily in equity REIT securities and other derivatives. They often have low expense ratios and passively track indexes for the larger real estate market. These REIT indexes include a number of different types of REITs as components. By tracking an index, an investor can gain exposure to the larger real estate sector without having to risk capital on one individual company. The ETF’s assets may be concentrated in one or more particular sectors or industries. It may be subject to the risk that economic, political or other conditions that have a negative effect on the relevant sectors or industries will negatively impact the ETF's performance to a greater extent than if the ETF’s assets were invested in a wider variety of sectors or industries. 9  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 your evaluation of TCF or the integrity of TCF’s management. TCF has had no legal or disciplinary events since its inception in 1995. Item 10 – Other Financial Industry Activities and Affiliations TCF has no other Financial Industry Activities or affiliations. Item 11 – Code of Ethics TCF is a fee-only investment advisor and accepts no commissions or any other compensation other than its investment advisory fee paid by clients. We do not act as principal in any transactions. TCF and its supervised persons have a fiduciary duty to all clients. TCF and its supervised persons will always act in each client’s best interests and will not at any time place their interests ahead of any client’s interests. This fiduciary duty is considered the core underlying principle for TCF’s Code of Ethics and personal trading policy and represents the expected basis for all supervised persons’ dealings with clients of TCF. TCF primary investment vehicle is no-load mutual funds. We do not use individual securities when developing client portfolios; and we do not use block trading. No supervised person may buy or sell individual securities for their own accounts, other than mutual funds, or, exchange traded funds (ETFs) without the permission of Douglas Cakert, CCO. TCF has a comprehensive code of ethics that all advisors and personnel are required to read and follow. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] TCF may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation. TCF will typically recommend that Clients establish their account[s] at Schwab Advisor Services (“Schwab”). Schwab is an independent and unaffiliated SEC and FINRA-registered broker-dealer and member SIPC and will serve as the Client’s “qualified custodian”. Schwab offers to independent investment Advisors services which include custody of securities, trade execution, clearance, and settlement of transactions. TCF maintains an institutional relationship with Schwab whereby TCF receives economic benefits from Schwab. Please see Item 14 below. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle 10  into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like TCF. They provide TCF and our clients with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help TCF manage or administer our clients’ accounts, while others help TCF manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to TCF. Following is a more detailed description of Schwab’s support services: Services that benefit you Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts Provide pricing and other market data Facilitate payment of our fees from our clients’ accounts Assist with back-office functions, recordkeeping, and client reporting • • • • Services that generally benefit only us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: 11  Publications and conferences on practice management and business succession Access to employee benefits providers, human capital consultants, and insurance providers • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment for our personnel. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We may have an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to TCF as part of our evaluation of these broker-dealers. Following are additional details regarding the brokerage practices of TCF: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. TCF does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, TCF receives certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals - TCF does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where TCF will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. TCF will not engage in any principal transactions (i.e., trade of any security from or to TCF’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). TCF will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. 12  B. Individual Account Trading The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. TCF will execute its transactions through the Custodian as authorized by the Client. TCF executes trades on an individual client account basis and does not aggregate, or "block," orders for a given security or holding across multiple client accounts. Because TCF primarily invests client assets in mutual funds, which transact at the fund’s end-of-day net asset value ("NAV"), the timing of order entry during the trading day generally has no bearing on the price a client receives, as all orders submitted on a given business day are executed at the same NAV. TCF also utilizes exchange-traded funds ("ETFs") in client portfolios. Unlike mutual funds, ETFs trade throughout the day at prevailing market prices, so the price received on an ETF trade may vary based on the time an individual order is entered. Because each account is traded separately, this variance does not raise the allocation concerns associated with block trading, and TCF does not favor any particular client in the sequencing or timing of order entry. Item 13 – Review of Accounts TCF provides continuous supervision of clients’ assets. Accounts are monitored regularly and are reviewed at least annually to determine if allocations are in line with the investment plan. The Strategic Asset Allocation Process is used to provide an appropriate rationale for making modifications to client portfolios. An annual analysis is performed to ensure the portfolio is performing in accordance with the stated objectives. Clients are provided with a detailed report showing the allocation of their assets and other characteristics of their portfolios. Annual returns are provided and compared to appropriate indices. All accounts are personally reviewed by Thomas FX Cakert, CFP and/or Douglas B Cakert, CFP. In addition to the annual report noted above provided by TCF, all clients receive either a monthly or quarterly statement, depending on account activity, from the custodian detailing the asset positions and any transactions that have occurred since the last statement; and a yearly statement specifying the interest and dividends earned and any capital gains or losses incurred during the year. Also, all confirmations for any trades in an account are sent directly to the client by the custodian. Item 14 – Client Referrals and Other Compensation A. Client Referrals TCF does not pay fees or any form of compensation to anyone for referrals. B. Other Compensation As referenced above, TCF may receive an indirect economic benefit from Schwab in the form of support services and/or products Schwab makes available to TCF. TCF’s clients do not pay more for investment transactions 13  effected and/or assets maintained at Schwab as a result of this arrangement. There is no corresponding commitment made by TCF to Schwab or any other any entity to invest any specific amount or percentage of client assets in any specific mutual funds, securities or other investment products as result of the above arrangement. Item 15 – Custody TCF does NOT maintain custody of your assets. Although, under government regulations, we are deemed to have custody of your assets if you authorize us to instruct Schwab to deduct our advisory fees directly from your account. Your assets must be maintained in an account at a ‘qualified custodian’. Client assets are held in individual accounts under client’s name by establishing an account at Charles Schwab & Co. and designating TCF as investment advisor. This structure provides access to thousands of no-load mutual funds with no transaction fees to buy or sell funds. Client receives either a monthly or quarterly statement, depending on account activity, from Schwab detailing all investments and transactions. Item 16 – Investment Discretion TCF usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is exercised in a manner consistent with the stated investment objectives for the particular client account. Item 17 – Voting Client Securities All clients may authorize TCF to vote proxies on their behalf. You always have the right to withdraw this authorization and vote proxies yourself. You can exercise this right by instructing us in writing to not vote proxies in your account. We will vote proxies in the best interests of its clients and in accordance with our established policies and procedures. Our firm will retain all proxy records for the requisite period of time, including a copy of each proxy statement received and a record of each vote cast. We will also retain a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third-party to cast a vote. Clients may obtain a copy of TCF’s proxy voting policies and procedures upon request. Clients may also obtain information from TCF about how we voted any proxies on behalf of their account(s). Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about TCF’s financial condition. TCF has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 14