FORM ADV PART 2A BROCHURE - brookstonecm.com

1 form ADV part 2A BROCHURE . February 23, 2018. form ADV part 2A BROCHURE . BROOKSTONE CAPITAL MANAGEMENT, LLC. 1745 S . NAPERVILLE ROAD, SUITE 200. WHEATON, IL 60189. FIRM CRD/ IARD # 141413. SEC FILE # 801-68010. 630-653-1400 (PHONE). 630-653-4925 (FAX). This BROCHURE provides information about the qualifications and business practices of Brookstone Capital Management. If you have any questions about the contents of this BROCHURE , please contact us at The information in this BROCHURE has not been approved or verified by the United States Securities and Exchange Commission or by any state securities REV :FEB232018 ADV2A HB. authority. Additional information about Brookstone Capital Management is also available on the SEC's website at Brookstone Capital Management is a Registered Investment Advisor.

2 Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. BROOKSTONE CAPITAL MANAGEMENT | 2018 Brookstone Capital Management, LLC. All rights reserved. MATERIAL CHANGES. This ADV part 2 BROCHURE has been reviewed and is current. SEC Rule 204-3(b)(2) allows a summary page be provided in the event material changes are made to this BROCHURE . If you receive a summary page of material changes and would like to obtain a current copy of the entire BROCHURE , please contact either Brookstone Capital Management or your Investment Advisor Representative for a complete copy. No material changes have been made since the previous BROCHURE dated December 5, 2017. BROOKSTONE CAPITAL MANAGEMENT | 2018 Brookstone Capital Management, LLC.

3 All rights reserved. form ADV part 2A - DISCLOSURE BROCHURE . Page 3 of 20. TABLE OF CONTENTS. MATERIAL CHANGES 2. ADVISORY BUSINESS 4. DISCLOSED FEES AND COMPENSATION 6. TYPES OF CLIENTS 9. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 10. DISCIPLINARY INFORMATION 15. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 15. CODE OF ETHICS AND PERSONAL TRADING 16. BROKERAGE PRACTICES 16. REVIEW OF ACCOUNTS 18. CLIENT REFERRALS AND OTHER COMPENSATION 19. CUSTODY OF CLIENT FUNDS AND SECURITIES 19. INVESTMENT DISCRETION 20. VOTING CLIENT SECURITIES 20. FINANCIAL INFORMATION 20. BROOKSTONE CAPITAL MANAGEMENT | form ADV part 2A - DISCLOSURE BROCHURE . Page 4 of 20. ADVISORY BUSINESS. ABOUT US. Founded in 2006, Brookstone Capital Management, LLC (Brookstone) is an be made to you.

4 A written disclosure document will be provided to you that;. investment advisory firm providing fee based asset management services for clients, as well as comprehensive financial planning services. 1. Discloses that the advisor is a fiduciary in this transaction and is using impartial conduct standards in making the recommendation. Brookstone is a Registered Investment Advisor with the SEC, and owned by 2. Describes the advisor relationship with the insurance company. Dean Zayed. Mr. Zayed received his Bachelor of Arts Degree in Economics 3. Discloses the fee or commission that is being received as a from Northwestern University. He completed the Business Institutions percentage of the premium. Program, the undergraduate Leadership Program and was a member of 4. Discloses any material conflicts of interest including any additional Omicron Delta Epsilon Economics Honor Society.

5 He received his Juris Doctor compensation that may be received. degree from Northwestern University School of Law. He received his Master's Degree in Taxation (LLM) from Chicago-Kent College of Law. Dean is a SERVICES WE OFFER. Certified Financial Planner (CFP ) and holds an Illinois insurance license for Brookstone provides Asset Management and Financial Planning Services for life, health and long-term care, in addition to being an Investment Advisor its clients, each of which is more fully described below. Clients collaborate Representative. Mr. Zayed is the President and CEO of Brookstone and with Investment Advisor Representatives (IARs) to determine which services provides the firm with principal management. to employ to best help clients reach their financial goals.

6 INVESTMENT ADVISORY FIDUCIARY STANDARD ASSET MANAGEMENT SERVICES. As investment advisors, Brookstone and its IARs act as fiduciaries for all of our Brookstone's principal service is providing fee-based investment advisory investment management clients. This means that we have an obligation to services. Brookstone manages investment portfolios, on a discretionary act in the best interests of our clients and to provide investment advice in the basis, according to the client's objectives. Brookstone obtains data from clients' best interests. We avoid engaging in any activity that could create a potential clients addressing financial objectives, needs, risk tolerance, conflict of interest with any client; however, if a conflict of interest does arise, investment horizon and other pertinent information.

7 This information is full disclosure of that conflict will be made to the client. Reasonable care gathered and reported on an Investment Policy Statement (IPS) and Risk must be employed to avoid misleading clients and full and fair disclosure of Profile Questionnaire and is analyzed by Brookstone IARs. Once the analysis all material facts (including fees) to clients and prospective clients will be is completed, the IAR develops an investment strategy with the potential made. client that addresses specific investment styles and allocation of the client's assets. Brookstone may use a combination of equities, mutual funds, We fulfil our fiduciary obligations by collecting information about you and exchange traded funds, structured products (including certificates of deposit your investment goals so that our recommendations are customized to be in and notes), individual bonds, and options in securities to accomplish these your best interests.

8 We disclose all fees, and conflicts, in this BROCHURE and in objectives. Brookstone may partner with Sub-Advisory firms to create and the client agreement (Investment Policy Statement parts A and B) which are manage portfolio strategies. A client's portfolio is allocated according to the acknowledged by your signature. client's risk profile and documented on the IPS. ANNUITY RECOMMENDATIONS Brookstone may use Unified Managed Accounts (UMA) whenever possible. This allows for multiple strategies to be managed and held within the same Most Brookstone investment advisor representatives also provide insurance account. Accounts holding options cannot participate in UMA. or annuities to their clients when appropriate. When acting in the capacity of insurance agents, the Department of Labor (DOL) Fiduciary Rule imposes a In addition, Brookstone offers asset management services to clients through fiduciary duty and impartial conduct standard upon any retirement account customized individual investment accounts.

9 In such accounts, clients may (IRA, Roth IRA, 401k, etc.), including those invested in Fixed Index Annuities. authorize Brookstone IARs to purchase and sell mutual funds, exchange Using impartial conduct standards means that the recommendation has to traded funds, equities, fixed income securities and other securities authorized be in the client's best interest based on their unique situation including by Brookstone on a discretionary basis pursuant to investment objectives financial situation, investment objective and goals, time horizon, risk chosen by the client. Clients should refer to the individual mutual fund or ETF. tolerance, etc. Additionally, only reasonable compensation can be received prospectus for the risks associated with each specific fund. Some of these and no misleading statements can be made to the client.

10 Currently, for any available mutual funds may be owned by Kaizen Advisory, LLC (Kaizen), an qualified account annuity recommendation, certain disclosures will need to SEC registered investment advisor. Mr. Zayed has an ownership interest in BROOKSTONE CAPITAL MANAGEMENT | form ADV part 2A - DISCLOSURE BROCHURE . Page 5 of 20. Kaizen, which creates a conflict of interest in that Mr. Zayed has a financial Perkins & Zayed, PC for estate planning services, the client will be required to incentive to promote Kaizen advised investments and to use them as part of enter into a separate written agreement for such services, and pay applicable Brookstone portfolios. Clients are under no obligation to invest in Kaizen legal fees. Clients should be aware that any applicable legal fees will be in advised investments and may choose a non-Kaizen advised investment addition to and separate from the financial planning fees incurred for services solution.