a non-registered individual may engage in high-level, non-discretionary discussions related to investments, provided they do not provide specific investment advice or make recommendations on particular securities.

Specifically, a non-registered individual may:

• Clearly state that investment management is provided by R N Croft Financial Group Inc.
• Maintain a clear distinction between your role (e.g., financial planner) and Croft’s role (portfolio manager).
• Use only Croft-approved marketing materials when discussing investment management.
• Discuss investment concepts, portfolio construction principles, and general asset-allocation frameworks at a high level
• Explain the structure, objectives, and mandate of investment portfolios or pooled funds in descriptive terms
• Provide educational information about risk, diversification, market conditions, and investment strategies
• Discuss how investment mandates align with a client’s stated financial goals, risk tolerance, and time horizon
• Facilitate communication between the client and the registered Portfolio Manager or Advising Representative
• Submit all references to Croft (email signatures, websites, social media, etc.) to compliance@croftgroup.com or kmulders@croftgroup.com for approval before use

A non-registered individual may not:

• Call yourself a Portfolio Manager, Investment Advisor, or similar unless you’re licensed.
• Co-brand services or imply that you directly manage investments.
• Use performance data or investment commentary unless it is provided or approved by Croft.
• Recommend, select, or opine on specific securities, funds, or trades
• Provide personalized investment advice or suitability determinations
• Exercise discretion over investment decisions or portfolio changes
• Represent themselves as acting in a registered advising capacity

All investment recommendations, suitability assessments, and discretionary decisions remain the sole responsibility of the appropriately registered Portfolio Manager or Advising Representative.