American Financial Management, Ltd. (“AFM”) is an SEC Registered Investment Advisor. We provide Asset Allocation Risk Management Services on a discretionary basis in addition to financial planning. As of September 12, 2023, Brad Clough (CRD no. 6852913) acquired AFM and he acts as the President & Chief Compliance Officer of AFM. Throughout this brochure, “we” “us” or “our” refers to American Financial Management, Ltd., and “you” or “your” refers to the client or proposed client. Mutual Fund/Variable Annuity Services consist of a mutual fund/variable annuity contract sub-account conversion management service using mutual fund/variable contract sub-accounts of the client’s choice in consultation with the client’s contact at AFM that may be an AFM investment advisory representative or a third -party promoter to AFM. AFM provides management services concerning the exchange between mutual fund/variable annuity contract sub-accounts. AFM neither recommends the mutual fund/variable contract group/company or the investments involved, nor the sale or redemption of any mutual fund/variable annuity contract shares/units, other than for conversion or advisory fee liquidation as authorized by the client. The advisory client's personal or individual needs should be determined by the client in consultation with their investment advisory representative or third- party promoter. Each Investment Advisory Agreement contains a confidential client profile, obtained by the investment adviser representative or third- party promoter used for determining the goals, objectives, risk profile, and suitability with their client’s strategy selection. When selecting the strategy, the client agrees to consider personal risk tolerance and financial goals in assessing AFM’s Asset Allocation/Risk Management program and ability to sustain a loss. Each client’s account in the program is managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of their account. Clients can place or modify reasonable restrictions on the management of their account. Managed Services AFM also provides advisory services that include discretionary portfolio management. We work with clients to assess their risks, objectives and suitability regarding their assets and identify the level of return required to meet each client’s objectives. Once the client’s objectives are determined, we design a portfolio to meet the clients’ goals. We invest through mutual funds bought at NAV and also have a managed stock account which is invested in stocks and

ETFs. Based on the client's situation, we structure their portfolio based on the client’s goals and risk tolerance. Clients may impose restrictions on investing in certain securities or types of securities. Our firm accepts discretionary authority to manage accounts on behalf of investment advisory clients. For each managed account, the client completes a “Discretionary Authorization and Limited Power of Attorney” authorizing our firm to make discretionary exchanges in the mutual fund, variable annuity sub-accounts, investment offerings at Charles Schwab under an investment advisory agreement between the advisory client and AFM. This allows us to exchange and update investment allocations as needed without requiring the retail investors pre-approval on an ongoing basis until the investor notifies us in writing to discontinue management services. AFM also offers financial planning services and may provide those services complimentary to existing investment management clients, at AFM’s discretion. AFM will at least annually contact clients to see if there are any updates to their financial situation or investment objectives and to determine if the client wishes to impose a new restriction or modify an existing one. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Act (ERISA) and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: ● Meet a professional standard of care when making investment recommendations (give prudent advice); ● Never put our financial interests ahead of yours when making recommendations (give loyal advice); ● Avoid misleading statements about conflicts of interest, fees, and investments; ● Follow policies and procedures designed to ensure that we give advice that is in your best interest; ● Charge no more than a level fee that is reasonable for our services; and ● Give you basic information about conflicts of interest. AFM does not offer a wrap fee program Assets Under Management As indicated in our ADV Part 1 on file with the SEC, as of December 31, 2023, we manage approximately $33,423,445 in client assets on a discretionary basis. AFM does not manage non-discretionary accounts.