handling customer funds & safeguarding client assets.

Custody Definition

An adviser has custody if it holds, directly or indirectly, client funds or securities, or has any authority to obtain possession of them.

An adviser would also have custody if a related person holds, directly or indirectly, client funds or securities, or had any authority to obtain possession of them in connection with advisory services provided to clients.

Custody generally includes:

• Having possession of client funds or securities unless the adviser returns them to the client within three days

• Any arrangement under which the adviser is authorized or permitted to withdraw client funds or securities based on its instructions, or

• Any capacity that gives the adviser legal ownership or access to client funds or securities.

Policy

Core Planning will not have physical custody of any client funds or securities.

It is the policy of Core Planning to never receive funds, securities, or checks made payable to a third party (such as a custodian).

Clients shall be instructed on the proper procedure to send funds to the proper destination via mail, Wire, ACH, branch location deposit, or another appropriate avenue.

If we inadvertently receive client funds or securities (such as checks made payable to Core Planning for investment but not for payment of advisory fees), we must return to the client the funds or securities within three (3) business days with instructions for the client on where they should send or take the funds or securities.

We will maintain client assets with a qualified custodian. We may have other forms of custody as defined by the appropriate rule. The CCO will determine whether or not the firm has custody and will ensure compliance with relevant custody rules including disclosure of custody on form ADV.

We currently have the following form(s) of custody: direct fee deduction.

Direct Fee Deduction

When Core Planning deducts advisory fees directly from client accounts, the following additional steps will be taken:

• Client will provide written authorization permitting the fees to be deducted from his or her account

• We will maintain client assets at a qualified custodian and ensure that the custodian segregates and identifies each client’s securities

• We will notify the client in writing of the custodian’s name, address, and the manner in which the client assets are maintained;

• We will ensure that the qualified custodian being used will deliver quarterly account statements to the client clearly showing management fee deductions for that time period

The CCO will periodically review and test the management fee calculations to ensure they are accurate based on the advisory contract.

Safeguarding Client Assets

In an effort to detect unauthorized or inappropriate activity in client accounts, the CCO will request reports that are available from each custodian and/or clearing firm holding client assets.

Such reports may include:

• Client change of address requests

• Requests to send documents (statements or reports) to addresses other than the home addresses listed on clients’ account documents

• Trading activity reports, including redemption and repurchase requests (most custodians have reports classified or named as exception reports to identify activities in clients’ accounts that are “exceptions” to the normal activities)

• Comparisons of IARs’ personal trading activity and IARs’ clients’ trading activity (most regulators will do a review of IARs’ personal accounts and do a partial comparison of clients’ account activity and holdings and IARs’ holdings and activity)

In addition to outside reports, the CCO will institute practices and procedures to monitor the firm’s IARs and personnel to look for such items as:

• Unapproved custom reports or statements produced by IARs or support staff

• Unapproved Outside Business Activities

• Communications from clients with questions about unapproved products or offerings