Disclosures

Disclosures and Policies

In the course of doing business with cfd Investments, Inc. or Creative Financial Designs, Inc., you share personal and financial information with us. We treat this information as confidential and recognize the importance of protecting access to it.

You may provide information when communicating with us in writing, electronically, or by phone. For instance, information may come from your applications, your requests for forms or literature or your transactions with us. On occasion, such information may come from consumer reporting agencies and those providing services to us.

We do not sell information about our clients (whether current or former) to third parties. We do not disclose this information to third parties unless it is necessary to process a transaction or service an account. We may also disclose this information if otherwise legally permitted or required.

We maintain physical, electronic and procedural safeguards to protect information about our clients. Access to such information is limited to those who need it to perform their jobs, such as servicing your accounts or resolving problems or to inform you of products or services. Our Compliance Manual as well as our contracts with employees and agents restricts the use of your nonpublic personal information to those who need it to perform their jobs, such as servicing your accounts or resolving problems, and require that it be held in strict confidence.

We may share information between the two companies in the course of providing or offering products and services to best meet your investing needs. We may also share that information with companies performing administrative or marketing services for either company or with a business partner with whom we are developing or offering investment products. However, use of information about our clients in such cases is severely restricted – the other party is prohibited from sharing or using it for any other purpose.

Finally, in order to assist in the timely transition of your account in the event that your financial adviser leaves us and becomes associated with another securities firm, we may provide your client information to your financial adviser and/or the broker/dealer that your financial adviser becomes associated with. If you would prefer that we not disclose your information in that circumstance, you must let us know, in writing, addressed to cfd Investments, Inc., 2704 South Goyer Road, Kokomo, IN 46902, Attn: Chief Compliance Officer

Effective: March 15, 2017

The Financial Industry Regulatory Authority, Inc. (FINRA) requires member firms such as cfd Investments, Inc., to implement plans for the continuation of business in the event of a significant business disruption (SBD). A SBD refers to local or regional events such as natural disasters, fires, and power outages, acts of malice or terrorism, and technical infrastructure disruptions.

In accordance with FINRA’s rules, cfd Investments, Inc. has developed and implemented a Business Continuity Plan (BCP). Among other steps, we have created secondary business locations as back-ups to our normal business location and have arranged for back-up electronic storage of certain firm records. We have also arranged for alternative communication resources for both our internal associates and our external customers, financial advisers, and vendor partners.

The purpose of our Firm’s BCP is to ensure that we are able to continue our business activities and continue serving our financial advisers and our customers with the least possible impact in the event of any of the disruptive events described above actually occurring or in the case of other unforeseen circumstances.

Upon request, we will provide additional information about cfd Investments, Inc.’s BCP. Please contact us at 1-800-745-7776 if you have any questions.

Best Interest

We operate in the best interst of the client, always putting you and your investment objectives first.

SEC

Creative Financial Designs is an Investment Adviser registered with the United States Securities and Exchange Commission.

Client First

Our commitment is to serve you in the same manner which we would desire to be served.

FIRM OF INTEGRITY

Our key strengths include our commitment to being a firm of integrity regardless of circumstances, our commitment to helping our advisers serve their clients in the manner we would like to be served if we were in their circumstances, and our commitment to placing our mission of helping people achieve their goals and objectives before the commission earned by our Advisers.

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