Firm profile

Creative Financial Designs, Inc..

KOKOMO, INCRD 109032Registration Status: ApprovedEffective since April 19, 2001SEC # 801-60153Latest ADV March 30, 2026

Creative Financial Designs, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Kokomo, IN. Its latest Form ADV filing, dated March 30, 2026, reports $2.9B in regulatory assets under management, 170 employees, 105 offices, and 15,029 accounts.

Assets Under Management
$2.9B
Employees
170
Offices
105 offices
Total Clients
10,566

Associated firm names

2 names listed
  • CFD INVESTMENTS, INC.
  • CREATIVE FINANCIAL DESIGNS, INC.

Leadership

2 roles identified
CCOMatthew O. Bahrenburg
CFOGregory J. Smith

Advisory services offered

6 types reported
Educational seminars/workshops
Financial Planning Services
Pension consulting services

Fee models offered

4 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

KOKOMO, Indiana, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Indiana

KOKOMOPrimary office · BRAZIL · GREENWOOD · MISHAWAKA · INDIANAPOLIS · FT. WAYNE · TIPTON · MARTINSVILLE

California

HOLLISTER

Idaho

BOISE

Illinois

URBANA · PEKIN · PEORIA

Kansas

LENEXA

Michigan

FLINT · SHELBY TOWNSHIP

Missouri

JOPLIN

Nebraska

LINCOLN

New Jersey

SUCCASUNNA

Ohio

CINCINNATI · BOWLING GREEN · GREENVILLE · BLUFFTON · ZANESVILLE

Tennessee

COOKEVILLE

25 office records listed · 105 total offices reported. 1 additional office addresses are undisclosed and are not mapped. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$2.9Bas of March 30, 2026
Discretionary99.1%
$2.9B
99% of total RAUM99.1%
Non-discretionary0.9%
$27M
1% of total RAUM0.9%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 94.8% of total clients.
Top client categories% of clientsClients
1
Individuals
94.8%
10,015
2
HNWI
4.4%
462
3
Corporations
0.4%
37
4
Charitable
0.3%
33
5
Pension Plans
0.2%
19

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$2.9B
Total Accounts15,029
10Y AUM Change+$2.0B (+220.5%)

Private Funds

Private funds reported by Creative Financial Designs, Inc..

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees170
Clients per Employee62:1
10Y Employee Change+15 (+9.7%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
OWENS FAMILY TRUST DATED 8/1/2007Direct owner · Schedule AInterest in CREATIVE FINANCIAL DESIGNS, INC.
50% to < 75%
BRENT ANTHONY OWENSDirect owner · Schedule AInterest in CREATIVE FINANCIAL DESIGNS, INC.
25% to < 50%
OWENS FAMILY TRUST DATED DECEMBER 2000Direct owner · Schedule AInterest in CREATIVE FINANCIAL DESIGNS, INC.
25% to < 50%
BRENT ANTHONY OWENSIndirect owner · Schedule BInterest in OWENS FAMILY TRUST DATED DECEMBER 2000
75%+
MICKEY LEE OWENSIndirect owner · Schedule BInterest in OWENS FAMILY TRUST DATED 8/1/2007
50% to < 75%
KATHRYN ELAINE OWENSIndirect owner · Schedule BInterest in OWENS FAMILY TRUST DATED 8/1/2007
50% to < 75%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Creative Financial Designs, Inc...

Reported ownership and control details

Form ADV · Filing date 2026-03-30 · Schedules A and B

13 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1BRENT ANTHONY OWENSPRESIDENT, DIRECTORIndividualCREATIVE FINANCIAL DESIGNS, INC.25% to less than 50%Code CYesPRESIDENT, DIRECTOR08/1997Schedule APDF page 42
2KREGG JERROD ROOZEDIRECTOR, VICE PRESIDENTIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesDIRECTOR, VICE PRESIDENT08/2009Schedule APDF page 42
3BROOKE LEIGH ROCKEYSECRETARY, DIRECTORIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesSECRETARY, DIRECTOR09/2009Schedule APDF page 42
4OWENS FAMILY TRUST DATED DECEMBER 2000SHAREHOLDERDomestic entityCREATIVE FINANCIAL DESIGNS, INC.25% to less than 50%Code CYesSHAREHOLDER03/2003Schedule APDF page 42
5MATTHEW O BAHRENBURGCHIEF COMPLIANCE OFFICERIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesCHIEF COMPLIANCE OFFICER04/2012Schedule APDF page 42
6MICKEY LEE OWENSDIRECTORIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesDIRECTOR10/2015Schedule APDF page 42
7CHRISTOPHER M ROCKEYDIRECTOR, TREASURERIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesDIRECTOR, TREASURER10/2012Schedule APDF page 42
8OWENS FAMILY TRUST DATED 8/1/2007SHAREHOLDERDomestic entityCREATIVE FINANCIAL DESIGNS, INC.50% to less than 75%Code DYesSHAREHOLDER03/2014Schedule APDF page 42
9Brigit R BraunDIRECTORIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NANoDIRECTOR12/2023Schedule APDF page 42
10GREGORY JOHN SMITHCHIEF FINANCIAL OFFICERIndividualCREATIVE FINANCIAL DESIGNS, INC.Less than 5%Code NAYesCHIEF FINANCIAL OFFICER01/2001Schedule APDF page 42
11MICKEY LEE OWENSTRUSTEEIndividualOWENS FAMILY TRUST DATED 8/1/200750% to less than 75%Code DYesTRUSTEE08/2007Schedule BPDF page 43
12KATHRYN ELAINE OWENSTRUSTEEIndividualOWENS FAMILY TRUST DATED 8/1/200750% to less than 75%Code DYesTRUSTEE08/2007Schedule BPDF page 43
13BRENT ANTHONY OWENSTRUSTEEIndividualOWENS FAMILY TRUST DATED DECEMBER 200075% or moreCode EYesTRUSTEE12/2000Schedule BPDF page 43

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/30/2026 2:06:27 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies1 Yes1 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?Yes
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?Yes
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions2 Yes3 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions3 Yes1 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?Yes
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?Yes
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 6 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

criminal · block 1PDF pages 43–44
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5428315
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COVERT, ZACHARY, W
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
regulatory · block 1FORTIN, J., STANDISHPDF pages 44–46
Advisory affiliate name — filed text
FORTIN, J., STANDISH
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
3008070
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FORTIN, J., STANDISH
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation

If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 2BEASLEY, RUSSELL, BRIANPDF pages 46–47
Advisory affiliate name — filed text
BEASLEY, RUSSELL, BRIAN
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
3230076
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BEASLEY, RUSSELL, BRIAN
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 3BETENBAUGH, PAUL, MARTINPDF pages 48–49
Advisory affiliate name — filed text
BETENBAUGH, PAUL, MARTIN
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
5222485
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BETENBAUGH, PAUL, MARTIN
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 4PDF pages 49–51
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
25427
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CFD INVESTMENTS, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
5295661
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BAHRENBURG, MATTHEW, O
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 5PDF pages 51–53
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 212,300.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $569,516, PREJUDGMENT INTEREST OF $108,424, AND A CIVIL MONEY PENALTY OF $212,300; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THIS ORDER.
Other filed details

Description of allegations — filed text

THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ISSUED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST CREATIVE FINANCIAL DESIGNS, INC. ("CREATIVE" OR "RESPONDENT"). THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY BY CREATIVE, A REGISTERED INVESTMENT ADVISER, IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE RECEIPT OF CERTAIN REVENUE SHARING PAYMENTS BY ITS AFFILIATED BROKER-DEALER, CFD INVESTMENTS, INC. ("CFD"). FIRST, FROM JANUARY 2014 THROUGH MARCH 2019 (THE "RELEVANT PERIOD"), CREATIVE PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES") INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THE CLIENTS. CFD AND CREATIVE'S INVESTMENT ADVISER REPRESENTATIVES, IN THEIR CAPACITY AS REGISTERED REPRESENTATIVES OF CFD, RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS, BUT CREATIVE DID NOT ADEQUATELY DISCLOSE THIS CONFLICT OF INTEREST IN ITS FORMS ADV OR OTHERWISE. FURTHER, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN OTHER SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE TO THE CLIENTS, CREATIVE BREACHED ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS. SECOND, DURING THE RELEVANT PERIOD, CREATIVE FAILED TO DISCLOSE TO ITS CLIENTS COMPENSATION THAT CFD RECEIVED THROUGH AGREEMENTS WITH TWO THIRD-PARTY BROKER-DEALERS (THE "CLEARING BROKERS") AND CONFLICTS ARISING FROM THAT COMPENSATION. PURSUANT TO THE AGREEMENTS, THE CLEARING BROKERS AGREED TO SHARE WITH CFD CERTAIN REVENUES THAT THE CLEARING BROKERS RECEIVED FROM THE MUTUAL FUNDS THAT CREATIVE RECOMMENDED TO ITS CLIENTS. CLEARING BROKER 1 AGREED TO SHARE WITH CFD A CERTAIN PERCENTAGE OF REVENUE THAT CLEARING BROKER 1 RECEIVED FROM THE MUTUAL FUNDS FOR PERFORMING CERTAIN ADMINISTRATIVE SERVICES (REFERRED TO AS THE "NETWORKING REVENUE PROGRAM"). CLEARING BROKER 2 AGREED TO SHARE WITH CFD A PORTION OF REVENUE THAT CLEARING BROKER 2 RECEIVED FROM THE MUTUAL FUNDS IN CLEARING BROKER 2'S NO-TRANSACTION-FEE ("NTF") MUTUAL FUND PROGRAM (THE "NTF PROGRAM"). THESE PAYMENTS TO CFD CREATED A CONFLICT OF INTEREST IN THAT THEY PROVIDED A FINANCIAL INCENTIVE FOR CREATIVE TO FAVOR THE MUTUAL FUNDS IN THE NETWORKING REVENUE AND NTF PROGRAMS OVER OTHER INVESTMENTS WHEN GIVING INVESTMENT ADVICE TO ITS ADVISORY CLIENTS. FURTHERMORE, CREATIVE FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND REVENUE SHARING PRACTICES. CREATIVE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE").

Sanction detail — filed text

RESPONDENT IS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; SHALL PAY DISGORGEMENT OF $569,516, PREJUDGMENT INTEREST OF $108,424, AND A CIVIL MONEY PENALTY OF $212,300; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THIS ORDER.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/25/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20081
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ISSUED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT
TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS
ACT OF 1940 ("ADVISERS ACT") AGAINST CREATIVE FINANCIAL DESIGNS, INC. ("CREATIVE" OR "RESPONDENT"). THE COMMISSION FINDS THAT THESE
PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY BY CREATIVE, A REGISTERED INVESTMENT ADVISER, IN CONNECTION WITH ITS MUTUAL
FUND SHARE CLASS SELECTION PRACTICES AND THE RECEIPT OF CERTAIN REVENUE SHARING PAYMENTS BY ITS AFFILIATED BROKER-DEALER, CFD
INVESTMENTS, INC. ("CFD"). FIRST, FROM JANUARY 2014 THROUGH MARCH 2019 (THE "RELEVANT PERIOD"), CREATIVE PURCHASED, RECOMMENDED,
OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT
COMPANY ACT OF 1940 ("12B-1 FEES") INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THE CLIENTS. CFD
AND CREATIVE'S INVESTMENT ADVISER REPRESENTATIVES, IN THEIR CAPACITY AS REGISTERED REPRESENTATIVES OF CFD, RECEIVED 12B-1 FEES IN
CONNECTION WITH THESE INVESTMENTS, BUT CREATIVE DID NOT ADEQUATELY DISCLOSE THIS CONFLICT OF INTEREST IN ITS FORMS ADV OR
OTHERWISE. FURTHER, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN
OTHER SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR
CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE TO THE CLIENTS, CREATIVE BREACHED ITS DUTY TO SEEK BEST
EXECUTION FOR THOSE TRANSACTIONS. SECOND, DURING THE RELEVANT PERIOD, CREATIVE FAILED TO DISCLOSE TO ITS CLIENTS COMPENSATION
THAT CFD RECEIVED THROUGH AGREEMENTS WITH TWO THIRD-PARTY BROKER-DEALERS (THE "CLEARING BROKERS") AND CONFLICTS ARISING FROM
THAT COMPENSATION. PURSUANT TO THE AGREEMENTS, THE CLEARING BROKERS AGREED TO SHARE WITH CFD CERTAIN REVENUES THAT THE
CLEARING BROKERS RECEIVED FROM THE MUTUAL FUNDS THAT CREATIVE RECOMMENDED TO ITS CLIENTS. CLEARING BROKER 1 AGREED TO SHARE
WITH CFD A CERTAIN PERCENTAGE OF REVENUE THAT CLEARING BROKER 1 RECEIVED FROM THE MUTUAL FUNDS FOR PERFORMING CERTAIN
ADMINISTRATIVE SERVICES (REFERRED TO AS THE "NETWORKING REVENUE PROGRAM"). CLEARING BROKER 2 AGREED TO SHARE WITH CFD A PORTION
OF REVENUE THAT CLEARING BROKER 2 RECEIVED FROM THE MUTUAL FUNDS IN CLEARING BROKER 2'S NO-TRANSACTION-FEE ("NTF") MUTUAL FUND
PROGRAM (THE "NTF PROGRAM"). THESE PAYMENTS TO CFD CREATED A CONFLICT OF INTEREST IN THAT THEY PROVIDED A FINANCIAL INCENTIVE FOR
CREATIVE TO FAVOR THE MUTUAL FUNDS IN THE NETWORKING REVENUE AND NTF PROGRAMS OVER OTHER INVESTMENTS WHEN GIVING INVESTMENT
ADVICE TO ITS ADVISORY CLIENTS. FURTHERMORE, CREATIVE FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND
SHARE CLASS SELECTION PRACTICES AND REVENUE SHARING PRACTICES. CREATIVE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE
COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD
INITIATIVE").

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/25/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 212,300.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT INTEREST ON DISGORGEMENT
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
RESPONDENT IS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS
OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; SHALL PAY DISGORGEMENT OF
$569,516, PREJUDGMENT INTEREST OF $108,424, AND A CIVIL MONEY PENALTY OF $212,300; AND SHALL COMPLY WITH THE UNDERTAKINGS
ENUMERATED IN THIS ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RESPONDENT WILLFULLY VIOLATED
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE RESPONDENT
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $569,516, PREJUDGMENT INTEREST OF
$108,424, AND A CIVIL MONEY PENALTY OF $212,300; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THIS ORDER.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.