Description of Services and Fees Financial Designs Corporation ("FDC") is a registered investment advisor based in Claremont, California. We are organized as a corporation under the laws of the State of California. We have been providing investment advisory services since 1981. FDC Holdings Corporation is the principal owner. The 2008 Pavan Family Trust is the sole shareholder of FDC Holdings Corporation. Currently, we offer the following investment advisory services, which are personalized to each individual client:
• Financial Planning Services
• Portfolio Management Services/Wrap Fee Program
• Asset Allocation Service FDC is a fee-only independent financial advisor that provides wealth management services by incorporating financial planning, investment portfolio management and other aggregated financial services specializing in retirement planning. FDC utilizes an active management approach to investments and encourages clients to take as much of an active role as they desire. The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Financial Designs Corporation (FDC) and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Financial Planning Services We offer broad-based financial planning services. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. After specifying long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Portfolio Management Services/Wrap Fee Program We offer discretionary portfolio management services through the Financial Designs Wrap Fee Program. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. We are the portfolio manager and sponsor of the Financial Designs Wrap Fee Program. Our portfolio management services are offered through the Program for a single fee that includes administrative fees, portfolio management fees, and commissions. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately

purchasing the types of securities available in the program. In determining whether to establish a Financial Designs Wrap Fee Program account, a client should be aware that the overall cost to the client of the Program may be higher or lower than the client might incur by purchasing separately the types of securities available in the Program. In order to compare the cost of the Program with unbundled services, the client should consider the turnover rate in our investment strategies, trading activity in the account and standard advisory fees and brokerage commissions that would be charged at Schwab or at other broker- dealers and investment advisors. Depending upon the Program's annual percentage fee charged by our firm (see fee schedule below), the amount of portfolio activity in your account, and the value of custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if we were to negotiate transaction fees and seek best price and execution of transactions for your individual account. Transactions for your account must be executed by Charles Schwab and Co., Inc., ("Schwab") a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. To compare the cost of the wrap fee program with non-wrap fee portfolio management services, you should consider the frequency of trading activity associated with our investment strategies and the brokerage commissions charged by Schwab or other broker-dealers, and the advisory fees charged by investment advisors. For more information concerning the Wrap Fee Program, please see Appendix 1 to this Brochure. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a limited power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. Asset Allocation Services We offer discretionary or non-discretionary asset allocation services for participants of employer qualified plan investments (i.e. 401k, 457, 403b, etc. plans). For certain qualified plan participant accounts where the custodian is Charles Schwab & Co., Inc. we offer discretionary asset allocation services. Once you have retained our firm for asset allocation services, we will gather information about your financial situation and objectives, and assist you in determining your investment goals, objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with recommendations as to how to allocate your investments among categories of assets. We will then review your account on an ongoing basis. Where appropriate, we may provide you with recommendations to change your asset allocation in an effort to remain consistent with your stated financial objectives. You are free at all times to accept or reject any of our investment recommendations. You are solely responsible for implementing our recommendations. Unless you separately retain our services, we will not execute any transactions or changes in asset allocation on your behalf. Types of Investments We offer advice on, exchange traded funds (ETFs), investment company securities (mutual funds), fixed income securities and fixed annuities. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing. Wrap Fee Program Our investment or portfolio management services are offered solely through the Financial Designs Wrap Fee Program. We do not offer portfolio management services outside of the program or in a non-wrap capacity. Therefore, there are no differences in the portfolio management of client accounts. A portion of the wrap fee charged to clients is paid to Schwab for transaction costs. Assets under Management As of December 31, 2022, we manage $274,605,557 in client assets on a discretionary basis and $104,600,226 on a non-discretionary basis.