ADV Part II

Form ADV Part 2B Brochure Supplement – Jeffery Townsend 

Item 3 – Disciplinary Information

Jeff has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Jeff is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchangetraded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commissionbased SAI account in addition to a Townsend advisory account. All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Jeff, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under
management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Jeff will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Jeff does not earn commissions in fee-based accounts.

Jeff will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Jeff discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Jeff which may be viewed by clients upon request. 

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Jeff’s advice or decides not to establish an account through SAI or an SAIapproved custodian, Jeff may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Jeff, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Jeff is independently licensed to sell insurance and annuity products through various insurance
companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products. Jeff may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations. Clients are never obligated or required to purchase insurance products from or through Jeff and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Rental Properties

Jeff spends a small amount of time on various activities for rental properties owned by a family trust and by
Townsend Capital, LLC.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Jeff receives no
other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. Shawn is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Jeff Townsend. Shawn can be contacted at 303-452-5986. 

Form ADV Part 2B Brochure Supplement – Shawn R. Kelly

Item 1 – Cover Page

Shawn R. Kelly
Townsend & Associates, Inc.
d/b/a Townsend
2761 W. 120th Ave., Suite 200
Westminster, CO 80234
Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Shawn R. Kelly (“Shawn”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement. Additional information about Shawn is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Shawn R. Kelly, Born 1975

Educational Background:

Effective Supervisory Management Course
Bachelor of Science in Business Administration, Doane College: 1999

Industry Licenses:

Series 7 (Registered Representative)
Series 66 (Series 66 (Uniform Combined State Law Agent))
Series 53 (Municipal Securities Security Principal)
Series 4 (Registered Options Principal)
Series 24 (Registered Principal)
Series 99 (Operations Professional)

Business Experience:

Townsend & Associates, Inc., President, 01/2019 to Present
Townsend & Associates, Inc., Chief Compliance Officer, 01/2008 to Present
Townsend & Associates, Inc., Producing Financial Advisor, Vice President, 01/2008 to 01/2019
Securities America Advisors, Inc., Registered Principal, 01/2008 to Present
U.S. Bank, Business Banking Officer, 08/2007 to 12/2007
Securities America Inc., Registered Representative, Compliance Examiner, 01/2000 to 08/2007
Securities America Advisors, Inc., Investment Advisor Representative, Compliance Examiner

Professional Designation:

Shawn Kelly has the Chartered Retirement Planning CounselorSM (CRPC®) designation.
Chartered Retirement Planning Counselorsm (CRPC®)
Chartered Retirement Planning Counselorsm (CRPC®); the College for Financial Planning® awards the
Chartered Retirement Planning Counselorsm and CRPC® designation to students who:
• successfully complete the program;
• pass the final examination; and
• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, selfregulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct. Conferment of the designation is contingent upon the College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Applicants must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam. Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period. Continued use of the CRPC® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC® designation by:
• completing 16 hours of continuing education;
• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and selfdisclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and
• paying a biennial renewal fee of $75.

Item 3 – Disciplinary Information

Shawn has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Shawn is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchangetraded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commissionbased SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Shawn, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its
compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Shawn will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Shawn does not earn commissions in fee-based accounts.

Shawn will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Shawn discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Shawn which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Shawn’s advice or decides not to establish an account through SAI or an SAIapproved custodian, Shawn may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Shawn, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Shawn is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products. Shawn may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations. Clients are never obligated or required to purchase insurance products from or through Shawn and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Shawn receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Theresa L. Thomas

Item 1 – Cover Page

Theresa L. Thomas Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Theresa L. Thomas (“Theresa”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Theresa is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Theresa L. Thomas, Born 1964

Education Background:

Attended Front Range Community College (no degree conferred)

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent) Series 63 (Securities Agent State Law)

Business Background:

Townsend & Associates, Inc., Investment Advisor Representative, 08/2007 to Present Townsend & Associates, Inc., Retirement Specialist, 10/2006 – 08/2007

Securities America Inc., Registered Representative, 12/2001 to Present;

Ashton Financial Group, Vice President, Mortgage Loan Officer, 02/2005 to 10/2006; Denver Mortgage, Loan Officer, 06/2004 to 02/2005

Turning Point Financial Solutions, Inc., President, Insurance Agent, 03/2004 to 10/2006; Complete Spectrum Financial Services, Insurance Agent, 10/2001 to 09/2003

Complete Spectrum Lending, LLC, Mortgage Consultant, 12/2002 to 09/2003 Indianapolis Life Insurance, Insurance Agent, 07/2002 to 10/2006

Professional Designation:

Theresa Thomas has the Chartered Retirement Planning Counselor^SM (CRPC®) designation. Chartered Retirement Planning Counselor^sm (CRPC®)

Chartered Retirement Planning Counselor^sm (CRPC®); the College for Financial Planning^® award the Chartered Retirement Planning Counselor^sm and CRPC^® designation to students who:

• successfully complete the program;

• pass the final examination; and

• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, self- regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct. Conferment of the designation is contingent upon the College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Applicants must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam.

Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period.

Continued use of the CRPC^® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC^® designation by:

• completing 16 hours of continuing education;

• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and self- disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and

• paying a biennial renewal fee of $75.

Item 3 – Disciplinary Information

Theresa Thomas has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Theresa is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in her separate capacity as a registered representative of SAI, she may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, she may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Theresa, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Theresa will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Theresa does not earn commissions in fee-based accounts.

Theresa will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Theresa discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Theresa which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Theresa’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Theresa may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Theresa, in her capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Theresa is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, she can receive commissions for selling insurance products.

Theresa may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect her judgment when recommending products to clients. While she endeavors at all times to put the interest of her clients first as a part of her and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect her decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Theresa and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Theresa receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Theresa Thomas. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Mark E. Thomas

Item 1 – Cover Page

Mark E. Thomas

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Mark E. Thomas (“Mark”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Mark is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Mark E. Thomas, Born 1962

Educational Background:

Front Range Community College (no degree conferred)

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Experience:

Townsend & Associates, Inc., Investment Advisor Representative & Retirement Specialist, 02/2010 to Present;

Securities America Inc., Registered Representative, 02/2010 to Present LaFarge North America, Assistant Plant Manager, 12/2005 to 01/2010

Professional Designation:

Mark Thomas has the Chartered Retirement Planning Counselor^SM (CRPC®) designation. Chartered Retirement Planning Counselor^sm (CRPC®)

Chartered Retirement Planning Counselor^sm (CRPC®); the College for Financial Planning^® awards the Chartered Retirement Planning Counselor^sm And CRPC^® designation to students who:

• successfully complete the program;

• pass the final examination; and

• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, self- regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct. Conferment of the designation is contingent upon the

College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Applicants must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam.

Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period.

Continued use of the CRPC^® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC^® designation by:

• completing 16 hours of continuing education;

• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and self- disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and

• paying a biennial renewal fee of $75.

Item 3 – Disciplinary Information

Mark has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Mark is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Mark, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Mark will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Mark does not earn commissions in fee-based accounts.

Mark will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Mark

discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Mark which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Mark’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Mark may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Mark, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Mark is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products.

Mark may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’ overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Mark and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Mark receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. Shawn is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Mark Thomas. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Tiffany A. Brown

Item 1 – Cover Page

Tiffany A. Brown

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 28, 2020

This brochure supplement provides information about Tiffany A. Brown (“Tiffany”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Tiffany is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Tiffany A. Brown, Born 1978

Education Background:

Chadron State College, 2000

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Experience:

Townsend & Associates, Inc., Financial Planner, 10/2009 to Present; Townsend & Associates, Inc., Office Assistant, 10/2007 to 10/2009 Securities America Inc., Registered Representative, 01/2008 to Present;

Community First National Bank (now d/b/a Bank of the West), Credit Trainee, Financial Services Officer, 01/2002 to 10/2007.

Professional Designations:

Tiffany holds the following professional designations:

¹Chartered Retirement Planning Counselor^SM (CRPC®)

²Certified Financial Planner™ (CFP®) Chartered Retirement Planning Counselor^sm (CRPC®)

¹Chartered Retirement Planning Counselor^sm (CRPC®); the College for Financial Planning^® awards the Chartered Retirement Planning Counselor^sm And CRPC^® designation to students who:

• successfully complete the program;

• pass the final examination; and

• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, self- regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to

their professional or business conduct. Conferment of the designation is contingent upon the College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Applicants must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam.

Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period.

Continued use of the CRPC^® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC^® designation by:

• completing 16 hours of continuing education;

• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and self- disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and

• paying a biennial renewal fee of $75.

Certified Financial Planner™ (CFP®)

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements

; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory information may also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Tiffany acknowledges her responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that her conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Tiffany has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Tiffany is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in her separate capacity as a registered representative of SAI, she may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, she may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Tiffany, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Tiffany will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Tiffany does not earn commissions in fee-based accounts.

Tiffany will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. Typically, l 12b-1 fees are received only in commission-based brokerage accounts. However, such fees can be earned in fee-based accounts managed by Tiffany if 12b- 1 fee paying mutual funds are held in the managed account. For ERISA accounts, there is an offset for any amount of 12b-1 fees. Tiffany discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Tiffany which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Tiffany’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Tiffany may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Tiffany, in her capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Tiffany is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, she can receive commissions for selling insurance products.

Tiffany may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect her judgment when recommending products to clients. While she endeavors at all times to put the interest of her clients

first as a part of her and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect her decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Tiffany and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Tiffany receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Tiffany Brown. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Andrew W. Hanna

Item 1 – Cover Page

Andrew W. Hanna Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120th Ave., Suite 200

Westminster, CO 80234

303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Andrew W. Hanna (“Andrew”) that supplements the Townsend & Associates, Inc. doing business as Townsend disclosure brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive Townsend & Associates’ brochure or if you have any questions about the contents of this supplement.

Additional information about Andrew is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Andrew W. Hanna, Born 1979

Educational Background:

Doane College, Bachelor’s in Business Administration/Management: 2002

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Investment Advisor Representative, 01/2015 to Present; Securities America Advisors, Investment Advisor Representative, 01/2015 to Present; Securities America, Inc., Registered Representative, 08/2014 to Present;

AMG National Trust Bank, Banking Officer, 01/2014 to 07/2015; Bank of the West, Banking Officer, 06/2010 to 01/2014; and

US Bank, Banking Officer, 06/2002 to 06/2010.

Professional Designations

Andrew Hanna has the Chartered Retirement Planning Counselor^SM (CRPC®) designation. Chartered Retirement Planning Counselor^sm (CRPC®)

Charter Retirement Planning Counselor (CRPC^®); the College for Financial Planning^® awards the CHARTERED RETIREMENT PLANNING COUNSELOR^SM AND CRPC^® designation to students who:

• successfully complete the program;

• pass the final examination; and

• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, self- regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct. Conferment of the designation is contingent upon the College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Students must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam.

Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period.

Continued use of the CRPC^® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC^® designation by:

• completing 16 hours of continuing education;

• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and self- disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and

• paying a biennial renewal fee of $75.

Item 3 – Disciplinary Information

Andrew has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Andrew W. Hanna is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission-based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Andrew, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Andrew will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Andrew does not earn commissions in fee-based accounts.

Andrew will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage

accounts. Andrew discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Andrew which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Andrew’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Andrew may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Andrew, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Item 5 – Additional Compensation

Mr. Hanna’s annual compensation is based, in part, on the amount of assets under management that he introduces to Townsend. Accordingly, Mr. Hanna may have a conflict of interest as he may receive a one- time bonus for recommending Townsend to clients for investment advisory services, as the recommendation could be made on the basis of compensation to be received, rather than on a client’s or prospective client’s best interests.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Andrew W. Hanna. Shawn Kelly can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Steven K. Carlisle

Item 1 – Cover Page

Steven K. Carlisle

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120th Ave., Suite 200

Westminster, CO 80234

303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Steven Carlisle (“Steven”) that supplements the Townsend & Associates, Inc. doing business as Townsend disclosure brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive Townsend & Associates’ brochure or if you have any questions about the contents of this supplement.

Additional information about Steven is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Steven Carlisle, Born 1971

Educational Background:

University of Nebraska-Lincoln, Bachelor’s Degree in Biology; 1994

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Investment Advisor Representative, 09/2016 to Present; Securities America, Inc., Registered Representative, 09/2016 to Present;

TCM Securities, Inc., Registered Representative, 04/2016 to 08/2016; Northwestern Mutual Life Insurance Company, Agent, 10/2014 to 04/2016;

Northwestern Mutual Investment Services LLC, Registered Representative, 10/2014 to 04/2016; Sandoz, Inc., Analytical Science and Tech Logistics Manager, 09/2003 to 07/2014

Professional Designations

Steven Carlisle has the Chartered Retirement Planning Counselor^SM (CRPC®) designation. Chartered Retirement Planning Counselor^sm (CRPC®)

Charter Retirement Planning Counselor (CRPC^®); the College for Financial Planning^® awards the CHARTERED RETIREMENT PLANNING COUNSELOR^SM AND CRPC^® designation to students who:

• successfully complete the program;

• pass the final examination; and

• comply with the Code of Ethics, which includes agreeing to abide by the Standards of Professional Conduct and Terms and Conditions. Applicants must also disclose of any criminal, civil, self- regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct. Conferment of the designation is contingent upon the

College for Financial Planning’s review of matters either self-disclosed or which are discovered by the College that are required to be disclosed.

Students must sign and return the Code of Ethics forms within six months of passing the final exam. Failure to complete and submit the forms within this time frame may result in termination of the individual’s candidacy. If an individual wishes to apply for authorization to use the Marks in the future, he or she may be required to fulfill the initial designation requirements in place at the time of passing the exam.

Successful students receive a certificate and are granted the right to use the designation on correspondence and business cards for a two-year period.

Continued use of the CRPC^® designation is subject to ongoing renewal requirements. Every two years individuals must renew their right to continue using the CRPC^® designation by:

• completing 16 hours of continuing education;

• reaffirming to abide by the Standards of Professional Conduct, Terms and Conditions, and self- disclose any criminal, civil, self-regulatory organization, or governmental agency inquiry, investigation, or proceeding relating to their professional or business conduct; and

• paying a biennial renewal fee of $75.

Item 3 – Disciplinary Information

Steven has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Steven Carlisle is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange-traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission-based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Steven, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Steven will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Steven does not earn commissions in fee-based accounts.

Steven will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets,

therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Steven discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Steven which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Steven’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Steven may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Steven, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Steven is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products.

Steven may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Steven and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Mr. Carlisle’s’ annual compensation is based, in part, on the amount of assets under management that he introduces to Townsend. Accordingly, Mr. Carlisle may have a conflict of interest as he may receive a one- time bonus for recommending Townsend to clients for investment advisory services, as the recommendation could be made on the basis of compensation to be received, rather than on a client’s or prospective client’s best interests.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Steven Carlisle. Shawn Kelly can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Christine White

Item 1 – Cover Page

Christine White

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 28, 2020

This brochure supplement provides information about Christine White that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Christine is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Christine White, Born 1988

Education Background:

Temple University, Bachelor’s Degree in Health & Exercise Science Temple University, Master of Science Degree in Kinesiology

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Experience:

Townsend & Associates, Inc., Financial Planner, 12/2016 to Present; Townsend & Associates, Inc., Registered Office Assistant, 01/2016 to 12/2016; Securities America, Inc., Registered Representative, 12/2016 to Present;

1847 Financial, Advisor, 12/2014 to 12/2015; Penn Mutual, Agent, 12/2014 to 12/2015;

HTK, Registered Broker, 12/2014 to 12/2015; and

VIDA Fitness, Instructor/Personal Training Manager, 11/2012 to 11/2014

Professional Designations:

Christine White has the Certified Financial Planner™ (CFP®) designation. Certified Financial Planner

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements

; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory information may also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Christine acknowledges her responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that her conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Christine has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Christine is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in her separate capacity as a registered representative of SAI, she may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, she may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Christine, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Christine will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Christine does not earn commissions in fee-based accounts.

Christine will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. Typically, 12b-1 fees are received only in commission-based brokerage accounts. However, such fees can be earned in fee-based accounts managed by Christine if 12b-1 fee paying mutual funds are held in the managed account. For ERISA accounts, there is an offset

for any amount of 12b-1 fees. Christine discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Christine which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Christine’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Christine may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Christine, in her capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Christine is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, she can receive commissions for selling insurance products.

Christine may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect her judgment when recommending products to clients. While she endeavors at all times to put the interest of her clients first as a part of her and Townsend’ overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect her decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Christine and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Christine receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Christine White. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Antwann Jamar Holmes

Item 1 – Cover Page

Antwann Jamar Holmes Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Antwann Holmes (“Antwann”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Antwann is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Antwann Holmes, Born 1982

Educational Background:

Arizona State University, Bachelor’s Degree in Global Business Management & Leadership

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Experience:

Townsend & Associates, Inc., Financial Planner, 11/2016 to Present; Securities America Inc., Registered Representative, 12/2016 to Present. Personal Capital Advisors Corporation, Advisor, 03/2015 to 11/2016 PriceWaterhouseCoopers, Associate, 12/2008 to 02/2015

Professional Designations:

Antwann has the Certified Financial Planner™ (CFP®) designation. Certified Financial Planner

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP

Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements

; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any

involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory information may also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Antwann acknowledges his responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that his conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Antwann has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Antwann is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Antwann, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Antwann will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Antwann does not earn commissions in fee-based accounts.

Antwann will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Antwann discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Antwann which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Antwann’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Antwann may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Antwann, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Antwann receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. Shawn is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Antwann Holmes. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Derek S. Cheshire

Item 1 – Cover Page

Derek S. Cheshire Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Derek S. Cheshire (“Derek”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Derek is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Derek S. Cheshire, Born 1979

Education Background:

New Mexico State University, Bachelor’s Degree in Finance

University of Colorado at Denver, Master of Business Administration Degree

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Inc., Investment Advisor Representative, 02/2019 to Present US Bancorp Investments, Wealth Management Advisor, 04/2017 to 02/2019;

Ethos Financial Partners, Associate Financial Advisor, 03/2013 to 03/2017

Professional Designation:

Derek Cheshire holds the following professional designations:

1. Accredit Portfolio Management Advisor (APMA^SM)

2. Certified Financial Planner™ (CFP®) Accredited Portfolio Management Advisor^SM (APMA^SM)

Individuals who hold the APMA^SM designation have completed a course of study encompassing client assessment and suitability, risk/return, investment objectives, bond and equity portfolios, modern portfolio theory and investor psychology. Students have hands-on practice in analyzing investment policy statements, building portfolios, and making asset allocation decisions including sell, hold, and buy decisions within a client’s portfolio. The program consists of two parts designed for a total of approximately 120-150 hours of study. The first part includes an 11 module self-study course with an online, proctored exam. Students successfully completing the exam matriculate to the second part of the program. That part consists of a four week, instructor-led, online graduate course requiring successful completion of several graded

assignments involving investor policy statements, portfolio construction, asset allocation, and portfolio buy, sell, and hold decisions. The program must be completed within one year from enrollment.

Certified Financial Planner™ (CFP®)

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements

; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory information may also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Derek acknowledges his responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that his conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Derek Cheshire has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Derek is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Derek, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Derek will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account

through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Derek does not earn commissions in fee-based accounts.

Derek will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Derek discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Derek which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Derek’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Derek may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Derek, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Derek is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products.

Derek may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Derek and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Derek receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Derek Cheshire. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Richard Harrison

Item 1 – Cover Page

Richard Harrison

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Richard Harrison (“Richard”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Richard is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Richard Harrison, Born 1986

Education Background:

University of Idaho, Bachelor’s Degree in Business Finance and Economics

Industry Licenses:

Series 7 (Registered Representative)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Inc., Investment Advisor Representative, 04/2019 to Present Securities America, Inc., Registered Representative, 04/2019 to Present;

TIAA-CREF, Wealth Management Advisor, 07/2014 to 03/2019 USAA, Financial Advisor, 11/2012 to 07/2014

Professional Designation:

Richard Harrison has the Certified Financial Planner™ (CFP®) designation. Certified Financial Planner™ (CFP®)

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any

bankruptcy disclosures in the past ten years. Additional regulatory information may also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Richard acknowledges his responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that his conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Richard Harrison has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Richard is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Richard, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Richard will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Richard does not earn commissions in fee-based accounts.

Richard will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Richard discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Richard which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Richard’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Richard may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Richard, in his capacity as a SAI registered

representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Richard is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products.

Richard may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Richard and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Mr. Hanna’s annual compensation is based, in part, on the amount of assets under management that he introduces to Townsend. Accordingly, Mr. Hanna may have a conflict of interest as he may receive a one- time bonus for recommending Townsend to clients for investment advisory services, as the recommendation could be made on the basis of compensation to be received, rather than on a client’s or prospective client’s best interests.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Richard Harrison. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Jonathan Amick

Item 1 – Cover Page

Jonathan Amick

Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Jonathan Amick (“Jonathan”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Jonathan is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Jonathan Amick, Born 1984

Education Background:

Metropolitan State University, Bachelor’s Degree in Business Administration

Industry Licenses:

None.

Business Background:

Townsend & Associates, Inc., Financial Planner, 07/2019 to Present Jonny Moneyseed, Consultant, 10/2016 to 07/2019

Zions Bancorporation, Assistant Vice President, Wealth Planning Analyst, 05/2011 to 10/2016

Professional Designation:

Jonathan Amick has the Certified Financial Planner™ (CFP®) designation. Certified Financial Planner™ (CFP®)

Certified Financial Planner Board of Standards, Inc. (“CFP Board”) owns the CFP® certification mark, the CERTIFIED FINANCIAL PLANNER™ certification mark, and the CFP® certification mark (with flame design) logo in the United States (these marks are collectively referred to as the “CFP® marks”). The CFP Board authorizes use of the CFP® marks by individuals who successfully complete the CFP Board’s initial and ongoing certification requirements.

The CFP^® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP^® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 86,000 individuals have obtained CFP^® certification in the United States.

To attain the right to use the CFP^® marks, an individual must satisfactorily fulfill the following requirements:

• Education – Complete a college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services or an accepted equivalent, including completion of a financial plan development capstone course, and attain a Bachelor’s Degree from an accredited college or university. CFP Board’s financial planning subject areas include professional conduct and regulation, general principles of financial planning, education planning, risk management and insurance planning, investment planning, income tax planning, retirement savings and income planning, and estate planning;

• Examination – Pass the comprehensive CFP^® Certification Examination. The examination, administered in 6 hours, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances;

• Experience – CFP Board requires 6,000 hours of experience through the Standard Pathway, or 4,000 hours of experience through the Apprenticeship Pathway that meets additional requirements

; and

• Ethics – Agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct, which put clients’ interest first; acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures; comply with the Financial Planning Practice Standards which determine what clients should reasonably expect from the financial planning engagement and complete a CFP^® Certification Application which requires disclosure of an individual’s background, including involvement in any criminal, civil, governmental, or self-regulatory agency proceeding or inquiry, bankruptcy, customer complaint, filing, termination/internal reviews conducted by the individual’s employer or firm.

Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP^® marks:

• Continuing Education – Complete 30 hours of continuing education hours accepted by the CFP Board every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and

• Ethics – CFP® professionals agree to adhere to the high standards of ethics and practice outlined in CFP Board’s Code of Ethics and Standards of Conduct and to acknowledge CFP Board’s right to enforce them through its Disciplinary Rules and Procedures. The Code of Ethics and Standards of Conduct require that CFP Professionals provide financial planning services in the best interests of their clients.

• Certification Application – Properly complete a Certification Application to (i) acknowledge voluntary adherence to the terms and conditions of certification with CFP Board and (ii) disclose any involvement in criminal and civil proceedings, inquiries or investigations, bankruptcy filings, internal reviews and customer complaints.

CFP^® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP^® certification.

You may verify an individual’s CFP® certification and background through the CFP Board. The verification function will allow you to verify an individual’s certification status, CFP Board’s disciplinary history and any bankruptcy disclosures in the past ten years. Additional regulatory information may

also be found through FINRA’S BrokerCheck and the SEC’s Investment Adviser Public Disclosure databases, which are free tools that may be used to conduct research on the background and experience of CFP® professionals and those who held CFP® certification at one time, including with respect to employment history, regulatory actions, and investment-related licensing information, arbitrations, and complaints.

CFP Acknowledgment: Jonathan acknowledges his responsibility as a CFP® Professional to adhere to the standards that have been established in the CFP Board’s Standards of Professional Conduct. If you become aware that his conduct may violate the Standards of Professional Conduct, you may file a complaint with the CFP Board at www.CFP.net/complaint.

Item 3 – Disciplinary Information

Jonathan Amick has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Insurance Agent

Townsend & Associates, Inc. doing business as Townsend is a licensed insurance entity in several states. Additionally, Jonathan is independently licensed to sell insurance and annuity products through various insurance companies as well as through Townsend & Associates as a licensed insurance entity. When acting in this capacity, he can receive commissions for selling insurance products.

Jonathan may also receive other incentive awards for the recommendation/sale of annuities and other insurance products. The receipt of compensation and other incentive benefits may affect his judgment when recommending products to clients. While he endeavors at all times to put the interest of his clients first as a part of his and Townsend’s overall fiduciary duty to clients, clients should be aware that the receipt of commissions and additional compensation itself creates a conflict of interest, and may affect his decision making process when making recommendations.

Clients are never obligated or required to purchase insurance products from or through Jonathan and may choose any independent insurance agent and insurance company to purchase insurance products. Regardless of the insurance agent selected, the insurance agent or agency will receive normal commissions from the sale.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Jonathan receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Jonathan Amick. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Kaitlin Elizabeth Bell

Item 1 – Cover Page

Kaitlin Elizabeth Bell Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Kaitlin Elizabeth Bell (“Kaitlin”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Kaitlin is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Kaitlin Elizabeth Bell, Born 1986

Education Background:

Colorado State University, Bachelor’s Degree in Business Finance with a concentration in Investment Analysis

Industry Licenses:

Series 7 (Registered Representative)

Series 9 (General Securities Sales Supervisor) Series 10 (General Securities Sales Supervisor) Series 63 (Securities Agent State Law)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Inc., Client Services, 02/2017 to Present Securities America, Inc., Registered Representative, 03/2017 to Present

Charles Schwab & Co., Inc., Senior Specialist Trading Operations, 08/2012 to 02/2017

Item 3 – Disciplinary Information

Kaitlin Elizabeth Bell has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Kaitlin is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in her separate capacity as a registered representative of SAI, she may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, she may suggest

that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Kaitlin, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Kaitlin will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Kaitlin does not earn commissions in fee-based accounts. Kaitlin will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Kaitlin discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Kaitlin which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Kaitlin’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Kaitlin may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Kaitlin, in her capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Kaitlin receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Kaitlin Elizabeth Bell. Shawn can be contacted at 303-452-5986.

Form ADV Part 2B Brochure Supplement – Nathaniel Francescato

Item 1 – Cover Page

Nathaniel Francescato Townsend & Associates, Inc. d/b/a Townsend

2761 W. 120^th Ave., Suite 200

Westminster, CO 80234

Ph: 303-452-5986

Date of Supplement: February 29, 2020

This brochure supplement provides information about Nathaniel Francescato (“Nathaniel”) that supplements the Townsend & Associates Inc. doing business as Townsend brochure. You should have received a copy of that brochure. Please contact Shawn Kelly at 303-452-5986 if you did not receive the Townsend brochure or if you have any questions about the contents of this supplement.

Additional information about Nathaniel is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Nathaniel Francescato, Born 1990

Education Background:

Bachelor of Science in Business Administration in Finance and Accounting, University of Denver: 2011

Industry Licenses:

Series 7 (Registered Representative) Series 24 (Registered Principal) Series 63 (Securities Agent State Law)

Series 66 (Uniform Combined State Law Agent)

Business Background:

Townsend & Associates, Inc., Compliance Specialist, 01/2020 to Present Scottrade, Compliance Examiner, 06/2010 to 04/2018

Item 3 – Disciplinary Information

Nathaniel Francescato has no legal or disciplinary events to report.

Item 4 – Other Business Activities

Registered Representative of Securities America, Inc.

Nathaniel is separately licensed as a registered representative with Securities America, Inc. (“SAI”) an SEC registered broker-dealer. When acting in his separate capacity as a registered representative of SAI, he may sell, for commissions, general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and variable annuity and variable life products to advisory clients. As such, he may suggest that advisory clients implement investment advice by purchasing securities products through a commission- based SAI account in addition to a Townsend advisory account.

All commissions earned for brokerage transactions are assigned to a master business account maintained by the branch office. All individuals that are registered representatives with SAI are also investment advisor representatives of Townsend. None of these individuals, including Nathaniel, directly receive commissions earned for brokerage transactions. All individuals affiliated with the branch office are strictly compensated by salary, which salary is calculated based upon the value of that individual’s client assets under management and does not account for brokerage commissions. Additionally, all clients served by any individual affiliated with the Townsend branch office receive financial planning services pursuant to a financial planning advisory services agreement with Townsend. As a result, any client who has a commission-based SAI account is also an advisory client of Townsend. Townsend has a fiduciary duty to act in the best interests of all advisory clients and the Townsend branch office has structured its compensation to individuals affiliated with the branch in a manner that is intended to eliminate any incentive to recommend commission-based products. Nathaniel will discuss the advantages and disadvantages of establishing a fee-based account through Townsend versus establishing a commission-based account through SAI with each client. Townsend does not require its advisor representatives to encourage clients to implement investment advice through SAI.

Nathaniel does not earn commissions in fee-based accounts. Nathaniel will receive 12b-1 fees from certain mutual fund companies as outlined in the fund’s prospectus. Any 12b-1 fees are treated in the same manner as other brokerage compensation, and are assigned to a master business account maintained by the Townsend branch office. 12b-1 fees come from fund assets, therefore, indirectly from client assets. 12b-1 fees are received only in commission-based brokerage accounts. Nathaniel discusses with clients the selection of a 12b-1 paying mutual fund or other trail paying mutual funds. Townsend maintains records of all 12b-1 fee payments to Nathaniel which may be viewed by clients upon request.

Clients are never obligated or required to establish accounts through Townsend or SAI. However, if a client does not choose to accept Nathaniel’s advice or decides not to establish an account through SAI or an SAI- approved custodian, Nathaniel may not be able to implement transactions for the client. Clients should understand that, due to certain regulatory constraints, Nathaniel, in his capacity as a SAI registered representative must place all purchases and sales of securities products in commission-based brokerage accounts through SAI or its other approved institutions.

Item 5 – Additional Compensation

Other than the fees detailed in the Townsend Form ADV Part 2A Disclosure Brochure, Nathaniel receives no other compensation related to advisory services provided to clients.

Item 6 – Supervision

Shawn Kelly is the Chief Compliance Officer of Townsend. He is responsible for developing, overseeing and enforcing the firm’s compliance programs that have been established to monitor and supervise the activities and services provided by the firm and its representatives, including Nathaniel Francescato.

Shawn can be contacted at 303-452-5986.