Drake & Associates LLC

Item 5).

Management risk. Investments managed by us vary with the success and failure of our
investment strategies, research, analysis and determination of portfolio securities.

Foreign investments risks. Non-U.S. investments, currency and commodity investments
may contain additional risks associated with government, economic, political or
currency volatility.

Emerging markets risks. Emerging markets can experience high volatility and risk in the
short term.
Liquidity risks. Generally, assets are more liquid if many investors are interested in a
standardized product, making the product relatively easy to convert into cash.
Specialized investments may have reduced liquidity.
Bond risks. Investments in bonds involve interest rate and credit risks. Bond values
change according to changes in interest rates, inflation, credit climate and issue credit
quality. Interest rate increases will reduce the value of a bond. Longer term bonds are
more susceptible to interest rate variations than shorter term, lower yield bonds.

Sector risks. Investing in a particular sector is subject to cyclical market conditions and
changes.

Tax risks. Our strategies and investments may have unique and significant tax
implications. D&A will manage portfolios with an awareness of tax implications, but
long-term wealth compounding is our primary consideration. Regardless of account size
or other factors, D&A strongly recommends that its clients continuously consult with a
tax professional prior to and throughout the investing of clients' assets.
Investment Strategies

D&A will generally implement client portfolios into the following investment strategies:

    •   ETF Capital Preservation Plus
    •   ETF Income Plus
    •   ETF Conservative Growth
    •   ETF Moderate Growth
    •   ETF Growth
    •   ETF Growth Plus
    •   ETF Aggressive Growth
    •   IQ Core Conservative
    •   IQ Famous Brands
    •   IQ Large Cap Growth
    •   PC Income Strategy
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.

C. Risks of Specific Securities Utilized

D&A generally seeks investment strategies that do not involve significant or unusual risk
beyond that of the general domestic and/or international equity markets. However, it will
utilize short sales, margin transactions, and options writing. Short sales, margin
transactions, and options writing generally hold greater risk of capital loss and clients
should be aware that there is a material risk of loss using any of those strategies.
Past performance is not a guarantee of future returns. Investing in securities involves a

 risk of loss that you, as a client, should be prepared to bear.

Item 7: Types of Clients

D&A generally provides investment advice and/or management supervisory services to the
following types of clients:

          ❖ Individuals
          ❖ High-Net-Worth Individuals

Minimum Account Size

There is an account minimum, $250,000, which may be waived by the investment advisor, based
on the needs of the client and the complexity of the situation.