0001580642-18-001329.txt : 20180302 0001580642-18-001329.hdr.sgml : 20180302 20180302120301 ACCESSION NUMBER: 0001580642-18-001329 CONFORMED SUBMISSION TYPE: N-CSR PUBLIC DOCUMENT COUNT: 8 CONFORMED PERIOD OF REPORT: 20171231 FILED AS OF DATE: 20180302 DATE AS OF CHANGE: 20180302 EFFECTIVENESS DATE: 20180302 FILER: COMPANY DATA: COMPANY CONFORMED NAME: TIMOTHY PLAN CENTRAL INDEX KEY: 0000916490 IRS NUMBER: 597016828 STATE OF INCORPORATION: DE FILING VALUES: FORM TYPE: N-CSR SEC ACT: 1940 Act SEC FILE NUMBER: 811-08228 FILM NUMBER: 18660669 BUSINESS ADDRESS: STREET 1: 1055 MAITLAND CENTER COMMONS CITY: MAITLAND STATE: FL ZIP: 32759 BUSINESS PHONE: 4076441986 MAIL ADDRESS: STREET 1: 1055 MAITLAND CENTER COMMONS CITY: MAITLAND STATE: FL ZIP: 32759 0000916490 S000011344 Timothy Conservative Variable C000031436 Timothy Conservative Variable 0000916490 S000011345 Timothy Strategic Variable C000031437 Timothy Strategic Variable N-CSR 1 timothy_ncsr.htm N-CSR Blu Giant, LLC

 

 

united states
securities and exchange commission
washington, d.c. 20549

form n-csr

certified shareholder report of registered management
investment companies

Investment Company Act file number 811-08228

 

The Timothy Plan

(Exact name of registrant as specified in charter)

 

1055 Maitland Center Commons, Maitland, FL 32751

(Address of principal executive offices) (Zip code)

 

Art Ally, The Timothy Plan

1055 Maitland Center Commons, Maitland, FL 32751

(Name and address of agent for service)

 

Registrant's telephone number, including area code: 800-846-7526

 

Date of fiscal year end: 12/31

 

Date of reporting period: 12/31/17

 

Form N-CSR is to be used by management investment companies to file reports with the Commission not later than 10 days after the transmission to stockholders of any report that is required to be transmitted to stockholders under Rule 30e-1 under the Investment Company Act of 1940 (17 CFR 270.30e-1).  The Commission may use the information provided on Form N-CSR in its regulatory, disclosure review, inspection and policymaking roles.

 

A registrant is required to disclose the information specified by Form N-CSR, and the Commission will make this information public.  A registrant is not required to respond to the collection of information contained in Form N-CSR unless the Form displays a currently valid Office of Management and Budget ("OMB") control number.  Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 450 Fifth Street, NW, Washington, DC 20549-0609.  The OMB has reviewed this collection of information under the clearance requirements of 44 U.S.C. § 3507.

 

Item 1. Reports to Stockholders.

 

The Registrant’s audited annual financial reports transmitted to shareholders pursuant to Rule 30e-1 under the Investment Company Act of 1940 are as follows:

 

(GRAPHIC)

    ANNUAL REPORT
    December 31, 2017
     
     
     
     
     
  TIMOTHY PLAN VARIABLE SERIES
     
  Conservative Growth
Strategic Growth
     
     
     
     
     
     
     
     

 

 

December 31, 2017

 

Dear Timothy Plan Strategic Growth Variable and Conservative Growth Variable Shareholder:

 

Asset allocation has normally been, and we believe it continues to be, a very prudent approach to investing. As a review, your Timothy Plan Variable Fund investment is a compilation of most of Timothy’s underlying funds and, as such, your performance is directly related to the performance of those underlying funds, which performed well last year. The traditional funds were led by the International, Emerging Markets, and Israel Common Values Funds, all of which had total returns in excess of twenty percent (20%). Our larger domestic equity funds each had total returns over fifteen percent (15%), which also helped the allocation portfolios to do relatively well. Bonds were not in favor in 2017, so the allocations into the bond funds tended to cause pressure on the returns of the portfolios. For more complete details on the underlying traditional funds, please see the managers’ reports presented on the following pages.

 

Due to our fairly positive outlook for the economy in the year ahead, we have adjusted our positions in the underlying funds to the allocations shown below:

 

     Conservative Growth   Strategic Growth 
· Large/Mid-Cap Growth Fund   7.50%   10.00%
· Large/Mid-Cap Value Fund   8.50%   11.00%
· Small-Cap Value Fund   5.00%   6.00%
· Aggressive Growth Fund   4.00%   5.50%
· International Fund   10.50%   19.50%
· High-Yield Bond Fund   6.50%   6.50%
· Defensive Strategies Fund   11.00%   12.00%
· Fixed Income Fund   24.50%   5.00%
· Israel Common Values Fund   3.50%   5.00%
· Emerging Markets Fund   4.50%   7.00%
· Growth & Income Fund   9.50%   9.50%
· Cash   5.00%   3.00%

 

Even though the Portfolios have been designed to be conservatively allocated, we understand that expectations for a market correction following the market’s 2017 nearly unprecedented run-up may be unsettling for some investors. Please understand that our #1 concern is preservation of principal, and, even though we want to participate in the market’s strong upward trend, we will attempt to adjust our allocation above to changing market conditions.

 

As you know, no one can guarantee future performance. However, the one thing that I can assure you of is every one of our sub-advisors is doing their very best and our team here at Timothy is working very hard to provide you an investment in which you can feel comfortable.

 

Sincerely,

Arthur D. Ally

President

1

 

Fund Performance - (Unaudited)
December 31, 2017
 
Conservative Growth Portfolio Variable Series

 

          5 Year    10 Year    Average Annual  
     1 Year    Average    Average    Total Return  
Fund/Index    Total Return    Annual Return    Annual Return    Since Inception (a)  
Timothy Conservative Growth Portfolio Variable Series    9.32%    4.89%    3.24%    4.28%  
Dow Jones Global Moderate Portfolio Index (b)    15.14%    8.11%    5.75%    7.26%  

 

(a)For the period May 1, 2002 (commencement of investment in accordance with objective) to December 31, 2017.

 

(b)Dow Jones Global Moderate Portfolio Index is based on the Dow Jones Relative Risk Index and consists of 60% equities and 40% fixed income.

 

Timothy Plan Conservative Growth Portfolio Variable Series vs. Dow Jones Global Moderate Portfolio Index

 

(LINE GRAPH)

 

The chart shows the value of a hypothetical initial investment of $10,000 in the Fund and the Dow Jones Global Moderate Portfolio Index on December 31, 2007 and held through December 31, 2017. The Dow Jones Global Moderate Portfolio Index is a widely recognized index that measures global stocks, bonds and cash which are in turn represented by multiple sub-indexes. Performance figures include the change in value of the investments in the indexes and the reinvestment of dividends. The total operating expense ratio (including indirect expenses), as stated in the Fund’s Prospectus dated April 30, 2017, is 1.73%. The index return does not reflect expenses, which have been deducted from the Fund’s return. The returns shown do not reflect deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares as well as other charges and expenses of the insurance contract, or separate account. THE FUND’S RETURN REPRESENTS PAST PERFORMANCE AND IS NOT PREDICTIVE OF FUTURE RESULTS.

2

 

Fund Performance - (Unaudited)
December 31, 2017
 
Strategic Growth Portfolio Variable Series

 

          5 Year    10 Year    Average Annual  
     1 Year    Average    Average    Total Return  
Fund/Index    Total Return    Annual Return    Annual Return    Since Inception (a)  
Timothy Strategic Growth Portfolio Variable Series    12.12%    6.45%    2.85%    4.17%  
Dow Jones Global Moderately Aggressive Portfolio Index (b)    19.08%    10.30%    6.37%    8.10%  

 

(a)For the period May 1, 2002 (commencement of investment in accordance with objective) to December 31, 2017.

 

(b)Dow Jones Global Moderately Aggressive Portfolio Index is based on the Dow Jones Relative Risk Index and consists of 80% equities and 20% fixed income.

 

Timothy Plan Strategic Growth Portfolio Variable Series vs. Dow Jones Global Moderately Aggressive Portfolio Index

 

(LINE GRAPH)

 

The chart shows the value of a hypothetical initial investment of $10,000 in the Fund and the Dow Jones Global Moderately Aggressive Portfolio Index on December 31, 2007 and held through December 31, 2017. The Dow Jones Global Moderately Aggressive Portfolio Index is a widely recognized index that measures global stocks, bonds and cash which are in turn represented by multiple sub-indexes. Performance figures include the change in value of the investments in the indexes and the reinvestment of dividends. The total operating expense ratio (including indirect expenses), as stated in the Fund’s Prospectus dated April 30, 2017, is 1.77%. The index return does not reflect expenses, which have been deducted from the Fund’s return. The returns shown do not reflect deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares as well as other charges and expenses of the insurance contract, or separate account. THE FUND’S RETURN REPRESENTS PAST PERFORMANCE AND IS NOT PREDICTIVE OF FUTURE RESULTS.

3

 

Fund Profile - Conservative Growth Portfolio Variable Series
December 31, 2017 (Unaudited)

 

Underlying Fund Allocations 
(% of Net Assets) 
Fixed Income Fund   24.85%
Defensive Strategies Fund   11.44%
International Fund   10.92%
Growth & Income Fund   9.74%
Large/Mid Cap Value Fund   8.79%
Large/Mid Cap Growth Fund   7.74%
High Yield Bond Fund   6.61%
Small Cap Value Fund   5.18%
Emerging Markets Fund   4.78%
Aggressive Growth Fund   4.16%
Israel Common Values Fund   3.68%
Money Market and Other Assets     
Less Liabilities   2.11%
    100.00%

 

Expense Example (Unaudited):

 

As a shareholder of the Fund, you incur two types of costs: direct costs, such as wire fees and low balance fees; and indirect costs, including management fees, and other Fund operating expenses. This example is intended to help you understand your indirect costs, also referred to as “ongoing costs” (in dollars), of investing in the Fund, and to compare these costs with the ongoing costs of investing in other mutual funds.

 

This example is based on an investment of $1,000 invested at the beginning of the period and held for the entire six-month period of July 1, 2017 through December 31, 2017.

 

Actual Expenses

 

The first line of the following table provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested at the beginning of the period, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the first line under the heading “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.

 

Hypothetical Example for Comparison Purposes

 

The second line of the table provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of other funds.

 

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any direct costs, such as wire fees or low balance fees. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these direct costs were included, your costs would be higher.

 

   Beginning Account   Ending Account   Expenses Paid 
   Value   Value   During Period* 
           7/1/2017 through 
   7/1/2017   12/31/2017   12/31/2017 
Actual  $1,000.00   $1,057.80   $1.50 
Hypothetical**  $1,000.00   $1,023.74   $1.48 

 

*Expenses are equal to the Fund’s annualized expense ratio of 0.29%, which is net of any expenses paid indirectly, multiplied by the average account value over the period, multiplied by 184 days/365 days (to reflect the partial year period). The Fund’s ending account value on the first line in the table is based on its actual total return of 5.78% for the six-month period of July 1, 2017 through December 31, 2017.

 

**Assumes a 5% return before expenses.

4

 

Fund Profile - Strategic Growth Portfolio Variable Series
December 31, 2017 (Unaudited)

 

Underlying Fund Allocations 
(% of Net Assets) 
International Fund   19.72%
Defensive Strategies Fund   12.13%
Large/Mid Cap Value Fund   11.06%
Large/Mid Cap Growth Fund   10.03%
Growth & Income Fund   9.47%
Emerging Markets Fund   7.23%
High Yield Bond Fund   6.43%
Small Cap Value   6.04%
Aggressive Growth Fund   5.55%
Israel Common Values Fund   5.12%
Fixed Income Fund   4.93%
Money Market and Other Assets     
Less Liabilities   2.29%
    100.00%

 

Expense Example (Unaudited):

 

As a shareholder of the Fund, you incur two types of costs: direct costs, such as wire fees and low balance fees; and indirect costs, including management fees, and other Fund operating expenses. This example is intended to help you understand your indirect costs, also referred to as “ongoing costs” (in dollars), of investing in the Fund, and to compare these costs with the ongoing costs of investing in other mutual funds.

 

This example is based on an investment of $1,000 invested at the beginning of the period and held for the entire six-month period of July 1, 2017 through December 31, 2017.

 

Actual Expenses

 

The first line of the following table provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested at the beginning of the period, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the first line under the heading “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.

 

Hypothetical Example for Comparison Purposes

 

The second line of the table provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare ongoing costs of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of other funds.

 

Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any direct costs, such as wire fees or low balance fees. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these direct costs were included, your costs would be higher.

 

   Beginning Account   Ending Account   Expenses Paid 
   Value   Value   During Period* 
           7/1/2017 through 
   7/1/2017   12/31/2017   12/31/2017 
Actual  $1,000.00   $1,076.40   $2.56 
Hypothetical**  $1,000.00   $1,022.74   $2.50 

 

*Expenses are equal to the Fund’s annualized expense ratio of 0.49%, which is net of any expenses paid indirectly, multiplied by the average account value over the period, multiplied by 184 days/365 days (to reflect the partial year period). The Fund’s ending account value on the first line in the table is based on its actual total return of 7.64% for the six-month period of July 1, 2017 through December 31, 2017.

 

**Assumes a 5% return before expenses.

5

 

Schedule of Investments
Conservative Growth Portfolio Variable Series
As of December 31, 2017

 

Shares      Fair Value 
         
     MUTUAL FUNDS (A) - 97.9%     
 94,889   Timothy Plan Aggressive Growth Fund *  $792,327 
 186,368   Timothy Plan Defensive Strategies Fund   2,178,638 
 92,023   Timothy Plan Emerging Markets Fund   911,032 
 466,241   Timothy Plan Fixed Income Fund   4,732,343 
 165,387   Timothy Plan Growth & Income Fund   1,855,640 
 134,882   Timothy Plan High Yield Bond Fund   1,259,796 
 206,588   Timothy Plan International Fund   2,080,339 
 45,328   Timothy Plan Israel Common Values Fund   701,678 
 169,284   Timothy Plan Large/Mid Cap Growth Fund   1,474,464 
 87,285   Timothy Plan Large/Mid Cap Value Fund   1,674,120 
 50,700   Timothy Plan Small Cap Value Fund   986,117 
           
     TOTAL MUTUAL FUNDS (Cost $17,396,588)   18,646,494 
           
     MONEY MARKET FUND - 2.3%     
 432,933   Fidelity Institutional Money Market Funds - Government Portfolio, 1.14% (B) (Cost $432,933)   432,933 
           
           
     TOTAL INVESTMENTS (Cost $17,829,521) - 100.2%  $19,079,427 
     OTHER ASSETS IN EXCESS OF LIABILITIES - NET - (0.2)%   (33,087)
     TOTAL NET ASSETS - 100.0%  $19,046,340 

 

*Non-income producing security.

 

(A)Affiliated Funds - Class A.

 

(B)Variable rate security; the rate shown represents the yield at December 31, 2017.

 

The accompanying notes are an integral part of these financial statements.

6

 

Schedule of Investments
Strategic Growth Portfolio Variable Series
As of December 31, 2017

 

Shares      Fair Value 
         
     MUTUAL FUNDS (A) - 97.7%     
 145,131   Timothy Plan Aggressive Growth Fund *  $1,211,846 
 226,437   Timothy Plan Defensive Strategies Fund   2,647,044 
 159,422   Timothy Plan Emerging Markets Fund   1,578,276 
 105,977   Timothy Plan Fixed Income Fund   1,075,667 
 184,191   Timothy Plan Growth & Income Fund   2,066,628 
 150,229   Timothy Plan High Yield Bond Fund   1,403,137 
 427,313   Timothy Plan International Fund   4,303,047 
 72,159   Timothy Plan Israel Common Values Fund   1,117,020 
 251,398   Timothy Plan Large/Mid Cap Growth Fund   2,189,673 
 125,894   Timothy Plan Large/Mid Cap Value Fund   2,414,642 
 67,766   Timothy Plan Small Cap Value Fund   1,318,051 
           
     TOTAL MUTUAL FUNDS (Cost $19,531,567)   21,325,031 
           
     MONEY MARKET FUND - 2.4%     
 522,646   Fidelity Institutional Money Market Funds - Government Portfolio, 1.14% (B) (Cost $522,646)   522,646 
           
     TOTAL INVESTMENTS (Cost $20,054,213) - 100.1%  $21,847,677 
     OTHER ASSETS IN EXCESS OF LIABILITIES - NET - (0.1)%   (24,793)
     TOTAL NET ASSETS - 100.0%  $21,822,884 

 

*Non-income producing security.

 

(A)Affiliated Funds - Class A.

 

(B)Variable rate security; the rate shown represents the yield at December 31, 2017.

 

The accompanying notes are an integral part of these financial statements.

7

 

Statements of Assets and Liabilities
December 31, 2017

 

   CONSERVATIVE GROWTH   STRATEGIC GROWTH 
   PORTFOLIO   PORTFOLIO 
   VARIABLE SERIES   VARIABLE SERIES 
           
ASSETS:          
Investments in affiliated securities, at cost  $17,396,588   $19,531,567 
Investments in unaffiliated securities, at cost   432,933    522,646 
Investments in affiliated securities, at value  $18,646,494   $21,325,031 
Investments in unaffiliated securities, at value   432,933    522,646 
Receivable for fund shares sold   42    1,485 
Dividends and interest receivable   794    715 
Prepaid expenses and other assets   6    176 
Total Assets   19,080,269    21,850,053 
           
LIABILITIES:          
Accrued advisory fees   1,371    1,916 
Payable for fund shares redeemed   2,507    3,916 
Payable to related parties   7,131    3,532 
Accrued expenses   22,920    17,805 
Total Liabilities   33,929    27,169 
           
Net Assets  $19,046,340   $21,822,884 
           
NET ASSETS CONSIST OF:          
Paid in capital ($0 par value, unlimited shares authorized)  $17,790,063   $20,530,319 
Accumulated undistributed net investment income   172,238    191,600 
Accumulated net realized loss from investments   (165,867)   (692,499)
Net unrealized appreciation on investments   1,249,906    1,793,464 
Net Assets  $19,046,340   $21,822,884 
           
Net Assets  $19,046,340   $21,822,884 
Shares of beneficial interest outstanding   1,675,131    1,935,992 
Net Asset Value (Net Assets/shares outstanding), offering price and redemption price per share  $11.37   $11.27 

 

The accompanying notes are an integral part of these financial statements.

8

 

Statements of Operations
For the Year Ended December 31, 2017

 

   CONSERVATIVE GROWTH   STRATEGIC GROWTH 
   PORTFOLIO   PORTFOLIO 
   VARIABLE SERIES   VARIABLE SERIES 
           
Investment Income:          
Dividend income from affiliated funds  $253,588   $281,391 
Interest income from unaffiliated funds   7,444    6,044 
Total Investment Income   261,032    287,435 
           
Operating Expenses:          
Administration fees   34,270    41,000 
Investment advisory fees   20,682    22,378 
Audit fees   13,000    13,000 
Printing expenses   6,920    6,220 
Custody fees   4,380    5,160 
Compliance officer fees   2,373    2,642 
Trustees’ fees   1,748    2,563 
Insurance expenses   2,046    970 
Other expenses   3,364    1,860 
Total Operating Expenses   88,783    95,793 
Net Investment Income   172,249    191,642 
           
Net Realized and Unrealized          
Gain from Investments:          
Capital gain dividends from affiliated funds   204,222    272,825 
Net realized gain from investments in affiliated funds   222,001    71,988 
Change in unrealized appreciation (depreciation) on affiliated investments   1,238,967    2,037,392 
Net Realized and Unrealized Gain from Investments   1,665,190    2,382,205 
           
Net Increase in Net Assets Resulting From Operations  $1,837,439   $2,573,847 

 

The accompanying notes are an integral part of these financial statements.

9

 

Statements of Changes in Net Assets

 

   CONSERVATIVE GROWTH   STRATEGIC GROWTH 
   PORTFOLIO   PORTFOLIO 
   VARIABLE SERIES   VARIABLE SERIES 
                 
   Year Ended   Year Ended   Year Ended   Year Ended 
   December 31,   December 31,   December 31,   December 31, 
   2017   2016   2017   2016 
Operations:                    
Net investment income  $172,249   $108,412   $191,642   $82,570 
Capital gain dividends from affiliated investments   204,222    53,908    272,825    63,125 
Net realized gain (loss) from investments in affiliated funds   222,001    (563,096)   71,988    (932,636)
Net change in unrealized appreciation (depreciation) on affiliated investments   1,238,967    1,810,927    2,037,392    2,081,673 
Net increase in net assets resulting from operations   1,837,439    1,410,151    2,573,847    1,294,732 
                     
Distributions to Shareholders:                    
Net investment income   (108,268)   (172,776)   (82,352)   (90,200)
Net realized gain on Investments       (1,667,282)       (1,958,053
Total dividends and distributions to shareholders   (108,268)   (1,840,058)   (82,352)   (2,048,253)
                     
Share Transactions of Beneficial Interest:                    
Net proceeds from shares sold   2,191,098    1,170,364    456,205    979,629 
Reinvestment of dividends   108,268    1,840,058    82,352    2,048,253 
Cost of shares redeemed   (8,079,256)   (5,471,868)   (4,738,353)   (3,079,210)
Net decrease in net assets from share transactions of beneficial interest   (5,779,890)   (2,461,446)   (4,199,796)   (51,328)
                     
Total Decrease in Net Assets   (4,050,719)   (2,891,353)   (1,708,301)   (804,849)
                     
Net Assets:                    
Beginning of year   23,097,059    25,988,412    23,531,185    24,336,034 
End of year*  $19,046,340   $23,097,059   $21,822,884   $23,531,185 
* Includes accumulated undistributed net investment income at end of year  $172,238   $108,257   $191,600   $82,310 
                     
Share Activity:                    
Shares sold   199,635    108,510    43,086    96,574 
Shares reinvested   9,754    176,082    7,562    204,213 
Shares redeemed   (741,776)   (507,956)   (447,878)   (293,455)
Net increase (decrease) in shares of beneficial interest outstanding   (532,387)   (223,364)   (397,230)   7,332 

 

The accompanying notes are an integral part of these financial statements.

10

 

Financial Highlights
Conservative Growth Portfolio Variable Series

 

Selected data based on a share outstanding throughout each year presented.

 

   For the Year   For the Year   For the Year   For the Year   For the Year 
   ended   ended   ended   ended   ended 
   December 31,   December 31,   December 31,   December 31,   December 31, 
   2017   2016   2015   2014   2013 
                     
Net asset value, beginning of year  $10.46   $10.69   $12.03   $12.66   $11.61 
INCOME (LOSS) FROM INVESTMENT OPERATIONS:                         
Net investment income (A)   0.09    0.05    0.07    0.15    0.23 
Net realized and unrealized gain (loss) on investments   0.88    0.57    (0.42)   0.18    0.94 
Total from investment operations   0.97    0.62    (0.35)   0.33    1.17 
LESS DISTRIBUTIONS:                         
From net investment income   (0.06)   (0.08)   (0.16)   (0.29)   (0.12)
From net realized gains on investments       (0.77)   (0.83)   (0.67)    
Total distributions   (0.06)   (0.85)   (0.99)   (0.96)   (0.12)
Net asset value, end of year  $11.37   $10.46   $10.69   $12.03   $12.66 
Total return (B)   9.32%   5.85%   (2.90)%   2.60%   10.10%
RATIOS/SUPPLEMENTAL DATA:                         
Net assets, end of year (in 000’s)  $19,046   $23,097   $25,988   $31,296   $35,159 
Expenses (C)   0.42%   0.43%   0.29%   0.47%   0.39%
Net investment income (C)(D)   0.82%   0.44%   0.60%   1.12%   1.86%
Portfolio turnover rate   23%   21%   33%   15%   21%

 

 

(A)Per share amounts calculated using average shares method, which more appropriately presents the per share data for the year.

 

(B)Total return in the above table represents the rate that the investor would have earned or lost on an investment in the Fund assuming reinvestment of dividends.

 

(C)These ratios exclude the impact of expenses of the underlying security holdings as represented in the Schedule of Investments.

 

(D)Recognition of net investment income by the Fund is affected by the timing of the declaration of dividends by the underlying investment companies in which the Fund invests.

 

The accompanying notes are an integral part of these financial statements.

11

 

Financial Highlights
Strategic Growth Portfolio Variable Series
 
Selected data based on a share outstanding throughout each year presented.

 

   For the Year   For the Year   For the Year   For the Year   For the Year 
   ended   ended   ended   ended   ended 
   December 31,   December 31,   December 31,   December 31,   December 31, 
   2017   2016   2015   2014   2013 
                     
Net asset value, beginning of year  $10.09   $10.46   $11.65   $11.67   $9.94 
INCOME (LOSS) FROM INVESTMENT OPERATIONS:                         
Net investment income (A)   0.09    0.04    0.04    0.14    0.26 
Net realized and unrealized gain (loss) on investments   1.13    0.53    (0.48)   0.05    1.54 
Total from investment operations   1.22    0.57    (0.44)   0.19    1.80 
LESS DISTRIBUTIONS:                         
From net investment income   (0.04)   (0.04)   (0.16)   (0.21)   (0.07)
From net realized gains on investments       (0.90)   (0.59)        
Total distributions   (0.04)   (0.94)   (0.75)   (0.21)   (0.07)
Net asset value, end of year  $11.27   $10.09   $10.46   $11.65   $11.67 
Total return (B)   12.12%   5.48%   (3.73)%   1.59%   18.15%
RATIOS/SUPPLEMENTAL DATA:                         
Net assets, end of year (in 000’s)  $21,823   $23,531   $24,336   $31,391   $27,423 
Expenses (C)   0.43%   0.39%   0.30%   0.45%   0.42%
Net investment income (C)(D)   0.86%   0.34%   0.32%   1.14%   2.43%
Portfolio turnover rate   33%   32%   33%   15%   17%

 

 

(A)Per share amounts calculated using average shares method, which more appropriately presents the per share data for the year.

 

(B)Total return in the above table represents the rate that the investor would have earned or lost on an investment in the Fund assuming reinvestment of dividends.

 

(C)These ratios exclude the impact of expenses of the underlying security holdings as represented in the Schedule of Investments.

 

(D)Recognition of net investment income by the Fund is affected by the timing of the declaration of dividends by the underlying investment companies in which the Fund invests.

 

The accompanying notes are an integral part of these financial statements.

12

 

Notes to Financial Statements
December 31, 2017
 
Conservative and Strategic Growth Portfolio Variable Series

 

Note 1 | Significant Accounting Policies

 

The Timothy Plan Conservative Growth Portfolio Variable Series (“Conservative Growth Portfolio”) and the Timothy Plan Strategic Growth Portfolio Variable Series (“Strategic Growth Portfolio”) (individually the “Fund”, collectively the “Funds”) were organized as diversified series of The Timothy Plan (the “Trust”). The Trust is an open-ended investment company established under the laws of Delaware by an Agreement and Declaration of Trust dated December 16, 1993 (the “Trust Agreement”). The Funds are intended to serve as investment vehicles for variable life insurance, variable annuity and group annuity products of insurance companies or for qualified plans. They are offered only to separate accounts established by various insurance companies and to certain eligible qualified retirement plans. The Conservative Growth Portfolio’s primary objective is moderate long-term capital growth, with a secondary objective of current income only to the extent that the Timothy Funds in which the Conservative Growth Portfolio invests seek current income. The Strategic Growth Portfolio’s primary investment objective is medium to high levels of long-term capital growth, with a secondary objective of current income only to the extent that the Timothy Funds in which the Strategic Growth Portfolio invests seek current income. The Conservative Growth Portfolio seeks to achieve its investment objectives by investing primarily in the following Timothy Funds which are other series of the Trust: Small Cap Value Fund, Large/Mid Cap Value Fund, Large/Mid Cap Growth Fund, Fixed Income Fund, Aggressive Growth Fund, High Yield Bond Fund, International Fund, Israel Common Values Fund, Defensive Strategies Fund, Emerging Markets Fund and Growth & Income Fund. The Conservative Growth Portfolio also invests in the Fidelity Institutional Money Market Funds – Government Portfolio, an unaffiliated mutual fund. The Strategic Growth Portfolio seeks to achieve its investment objectives by investing primarily in the following Timothy Funds which are other series of the Trust: Small Cap Value Fund, Large/Mid Cap Value Fund, Large/Mid Cap Growth Fund, Fixed Income Fund, Aggressive Growth Fund, High Yield Bond Fund, International Fund, Israel Common Values Fund, Defensive Strategies Fund, Emerging Markets Fund and Growth & Income Fund. The Strategic Growth Portfolio also invests in the Fidelity Institutional Money Market Funds – Government Portfolio, an unaffiliated mutual fund. Each Fund is one of a series of Funds currently authorized by the Board of Trustees (the “Board”). Timothy Partners, Ltd., (“TPL” or the “Advisor”) is the Investment Advisor for the Funds.

 

The following is a summary of significant accounting policies consistently followed by the Funds in the preparation of their financial statements. The policies are in conformity with accounting principles generally accepted in the United States of America (“GAAP”) for investment companies. The Funds are investment companies and accordingly follow the investment company accounting and reporting guidance of the Financial Accounting Standards Board Accounting Standards Codification Topic 946 Financial Services – Investment Companies. The Funds are investment companies and accordingly follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board (FASB) Accounting Standard Codification Topic 946 “Financial Services – Investment Companies”.

 

A. SECURITY VALUATION AND FAIR VALUE MEASUREMENTS

 

Fair value is defined as the price that a Fund would receive upon selling an investment in a timely transaction to an independent buyer in the principal or most advantageous market of the investment. GAAP established a three-tier hierarchy to maximize the use of observable market data and minimize the use of unobservable inputs and to establish classification of fair value measurements for disclosure purposes.

 

Inputs refer broadly to the assumptions that market participants would use in pricing the asset or liability, including assumptions about risk (the risk inherent in a particular valuation technique used to measure fair value including such a pricing model and/or the risk inherent in the inputs to the valuation technique). Inputs may be observable or unobservable. Observable inputs are inputs that reflect the assumptions market participants would use in pricing the asset or liability developed based on market data obtained from sources independent of the reporting entity. Unobservable inputs are inputs that reflect the reporting entity’s own assumptions about the assumptions market participants would use in pricing the asset or liability developed based on the best information available in the circumstances.

 

VALUATION OF FUND OF FUNDS

 

A Fund may invest in portfolios of open-end or closed-end investment companies (the “Underlying Funds”). The Underlying Funds value securities in their portfolios for which market quotations are readily available at their market values (generally the last reported sale price) and all other securities and assets at their fair value based upon methods established by the Board of Trustees of the Underlying Funds.

 

Open-ended funds are valued at their respective net asset values as reported by such investment companies. The shares of many closed-end investment companies, after their initial public offering, frequently trade at a price per share, which is different than the net asset value per share. The difference represents a market premium or market discount of such shares. There can be no assurances that the market discount or market premium on shares of any closed-end investment company purchased by the Fund will not change.

 

The Trust utilizes various methods to measure the fair value of all of its investments on a recurring basis. GAAP establishes a hierarchy that prioritizes inputs to valuation methods. The three levels of input are:

 

Level 1 – quoted prices in active markets for identical securities

13

 

Notes to Financial Statements
December 31, 2017
 
Conservative and Strategic Growth Portfolio Variable Series

 

Level 2 – other significant observable inputs (including, but not limited to, quoted prices for an identical security in an inactive market, quoted prices for similar securities, interest rates, prepayment speeds, credit risk, etc.)

 

Level 3 – significant unobservable inputs (including each Fund’s own assumptions in determining fair value of investments based on the best information available)

 

The inputs used to measure fair value may fall into different levels of the fair value hierarchy. In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety is determined based on the lowest level input that is significant to the fair value measurement in its entirety.

 

Each Fund purchases Class A Shares of the Timothy Funds at net asset value without any sales charges. Investments in mutual funds, including money market mutual funds, are generally priced at the ending Net Asset Value (“NAV”) provided by the service agent of the funds. These securities will be categorized as Level 1 securities.

 

The Board has delegated to the Advisor responsibility for determining the value of Fund portfolio securities under certain circumstances. Under such circumstances, the Advisor will use its best efforts to arrive at the fair value of a security held by each Fund under all reasonably ascertainable facts and circumstances. The Advisor must prepare a report for the Board not less than quarterly containing a complete listing of any securities for which fair value pricing was employed and detailing the specific reasons for such fair value pricing. The Board has adopted written policies and procedures to guide the Advisor with respect to the circumstances under which, and the methods to be used, fair value pricing is utilized. Good faith pricing is permitted if, in the Advisor’s opinion, the validity of market quotations appears to be questionable based on factors such as evidence of a thin market in the security based on a small number of quotations, a significant event occurs after the close of a market but before the Funds’ NAV calculation that may affect a security’s value, or the Advisor is aware of any other data that calls into question the reliability of market quotations.

 

The following is a summary of the inputs used to value the Conservative Growth Portfolio’s investments as of December 31, 2017:

 

Assets  Level 1   Level 2   Level 3   Total 
Mutual Funds  $18,646,494   $   $   $18,646,494 
Money Market Fund   432,933            432,933 
Total   $19,079,427   $   $   $19,079,427 

 

The following is a summary of the inputs used to value the Strategic Growth Portfolio’s investments as of December 31, 2017:

 

Assets  Level 1   Level 2   Level 3   Total 
Mutual Funds  $21,325,031   $   $   $21,325,031 
Money Market Fund   522,646            522,646 
Total   $21,847,677   $   $   $21,847,677 

 

Refer to the Schedules of Investments for underlying Fund allocations.

 

The Conservative Growth Portfolio and the Strategic Growth Portfolio did not hold any assets at any time during the reporting period in which significant unobservable inputs were used in determining fair value; therefore, no reconciliation of Level 3 securities is included for this reporting period. During the year ended December 31, 2017, there were no transfers between Levels 1 and 2. The Funds’ policy is to recognize transfers at the end of the period.

 

B. INVESTMENT INCOME AND SECURITIES TRANSACTIONS

 

Security transactions are accounted for on the date the securities are purchased or sold (trade date). Cost is determined and gains and losses are based on the identified cost basis for both financial statement and federal income tax purposes. Dividend income is recognized on the ex-dividend date. Interest income and expenses are recognized on an accrual basis.

 

C. NET ASSET VALUE PER SHARE

 

Net asset per share of the capital stock of each Fund is determined daily as of the close of trading on the New York Stock Exchange by dividing the value of its net assets by the number of Fund shares outstanding.

 

D. FEDERAL INCOME TAXES

 

It is the policy of each Fund to continue to comply with all requirements under subchapter M of the Internal Revenue Code applicable to regulated investment companies and to distribute substantially all of its taxable income to its shareholders. Each Fund also intends to distribute sufficient net investment income and net capital gains, if any, so that it will not be subject to excise tax on undistributed income or gains. Therefore, no federal income tax or excise provision is required.

14

 

Notes to Financial Statements
December 31, 2017
 
Conservative and Strategic Growth Portfolio Variable Series

 

Management has analyzed the Funds’ tax positions and has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken on returns filed for the open tax years (2014-2016) or expected to be taken in the Funds’ 2017 tax returns. The Funds recognize interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statements of Operations. For the year ended December 31, 2017, the Funds did not incur any interest or penalties. The Funds are not subject to examination by U.S. federal tax authorities for tax years before 2014 and are not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will change materially within the next twelve months.

 

E. USE OF ESTIMATES

 

In preparing financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.

 

F. DISTRIBUTIONS TO SHAREHOLDERS

 

Distributions to shareholders, which are determined in accordance with income tax regulations, are recorded on the ex-dividend date. The treatment for financial reporting purposes of distributions made to shareholders during the year from net investment income or net realized capital gains may differ from their ultimate treatment for federal income tax purposes. These differences are caused primarily by differences in the timing of the recognition of certain components of income, expense or realized capital gain for federal income tax purposes. Where such differences are permanent in nature, they are reclassified in the components of net assets based on their ultimate characterization for federal income tax purposes. Any such reclassifications will have no effect on net assets, results of operations, or net asset values per share of the Funds. There were no such reclassifications.

 

G. EXPENSES

 

Expenses incurred by the Trust that do not relate to a specific Fund of the Trust are allocated to the individual Funds based on each Fund’s relative net assets or an appropriate basis (as determined by the Board).

 

H. INDEMNIFICATION

 

The Trust indemnifies its officers and trustees for certain liabilities that may arise from the performance of their duties to the Trust. Additionally, in the normal course of business, the Funds enter into contracts that contain a variety of representations and warranties and which provide general indemnities. The Funds’ maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Funds that have not yet occurred. However, based on experience, the Funds expect the risk of loss due to these warranties and indemnities to be remote.

 

Note 2 | Purchases and Sales of Securities

 

The following is a summary of the cost of purchases and proceeds from the sale of securities, other than short-term investments, for the year ended December 31, 2017:

 

Funds  Purchases   Sales 
Conservative Growth Portfolio  $4,680,025   $9,846,140 
Strategic Growth Portfolio   7,246,358    10,777,108 

 

Note 3 | Aggregate Unrealized Appreciation and Depreciation

 

The identified cost of investments in securities owned by each Fund for federal income tax purposes, and their respective gross unrealized appreciation and depreciation at December 31 2017, were as follows:

 

       Gross Unrealized   Gross Unrealized   Net Unrealized 
Funds  Tax Cost   Appreication   Depreciation   Appreciation 
Conservative Growth Portfolio  $17,901,881   $1,402,425   $(224,879)  $1,177,546 
Strategic Growth Portfolio   20,126,814    1,813,014    (92,151)   1,720,863 

 

Note 4 | Investment Advisory Agreement and Transactions with Related Parties

 

Timothy Partners, Ltd. is the Investment Advisor for the Funds pursuant to an Amended and Restated Investment Advisory Agreement (the “Agreement”) that was renewed by the Board on February 17, 2017. TPL supervises the investment of the assets of each Fund’s portfolio in accordance with the objectives, policies and restrictions of the Funds. Under the terms of the Agreement, TPL receives a fee, accrued daily and paid

15

 

Notes to Financial Statements
December 31, 2017
 
Conservative and Strategic Growth Portfolio Variable Series

 

monthly, at an annual rate of 0.10% of the average daily net assets of each Fund. Total fees earned by TPL during the year ended December 31, 2017 were $20,682 and $22,378 for the Conservative Growth Portfolio and the Strategic Growth Portfolio, respectively. The Conservative Growth Portfolio and the Strategic Growth Portfolio owed TPL $1,371 and $1,916, respectively, at December 31, 2017. An officer and trustee of the Trust is also an officer of the Advisor.

 

Gemini Fund Services, LLC (“GFS”) provides administrative, fund accounting, and transfer agency services to the Funds pursuant to agreements with the Trust, for which it receives from each Fund: (i) basis points in decreasing amounts as assets reach certain breakpoints; and (ii) any related out-of-pocket expenses. Fees are billed monthly as follows:

 

Fund Accounting and Fund Administration Fees:

 

Fund Complex Base annual fee:

 

25 basis points (0.25%) on the first $200 million of net assets

15 basis points (0.15%) on the next $200 million of net assets;

8 basis points (0.08%) on the next $600 million of net assets; and

6 basis points (0.06%) on net assets greater than $1 billion.

 

Transfer agency fees for the Funds are combined with the Fund Accounting and Fund Administration fees under the Trust’s agreement with GFS. Therefore, there is no separate base annual fee per Fund.

 

Note 5 | Control Ownership

 

The beneficial ownership, either directly or indirectly, of more than 25% of the voting securities of a Fund creates the presumption of control of the Fund under Section 2(a) 9 of the Investment Company Act of 1940. As of December 31, 2017, American United Life Insurance Co. (“AUL”) held for the benefit of others, in aggregate, approximately 89% of the Conservative Growth Portfolio and approximately 86% of the Strategic Growth Portfolio.

 

Note 6 | Distributions to Shareholders and Tax Components of Capital

 

The tax character of distributions paid during 2017 and 2016 were as follows:

 

   Conservative Growth   Strategic Growth 
   Portfolio   Portfolio 
2017          
Ordinary Income  $108,268   $82,352 
   $108,268   $82,352 
2016          
Ordinary Income  $172,776   $90,200 
Long-Term Capital Gain   1,667,282    1,958,053 
   $1,840,058   $2,048,253 

 

As of December 31, 2017, the components of distributable earnings on a tax basis were as follows:

 

   Conservative Growth   Strategic Growth 
   Portfolio   Portfolio 
Undistributed Ordinary Income  $172,238   $191,600 
Capital Loss Carry Forward   (93,507)   (619,898)
Unrealized Appreciation (Depreciation)   1,177,546    1,720,863 
   $1,256,277   $1,292,565 

 

The difference between book basis and tax basis unrealized appreciation (depreciation) is primarily attributable to the tax deferral of losses on wash sales in the amount of $72,360 and $72,601 for the Conservative Growth Portfolio and the Strategic Growth Portfolio, respectively.

 

At December 31, 2017, the Portfolios had capital loss carry forwards (“CLCF”) for federal income tax purposes available to offset future capital gains as follows:

 

   Non-Expiring   Non-Expiring         
Funds  Short-Term   Long-Term   Total   CLCF Utilized 
Conservative Growth Portfolio  $2,302   $91,205   $93,507   $418,615 
Strategic Growth Portfolio   9,183    610,715    619,898    331,944 

16

 

Notes to Financial Statements
December 31, 2017
 
Conservative and Strategic Growth Portfolio Variable Series

 

Note 7| Underlying Investment in Other Investment Companies

 

The Conservative Growth Portfolio currently seeks to achieve its investment objectives by investing a portion of its assets in the Timothy Plan Fixed Income Fund (the “Security”). The Portfolio may redeem its investments from the Security at any time if the Advisor determines that it is in the best interest of the Portfolio and its shareholders to do so.

 

The performance of the Portfolio may be directly affected by the performance of the Security. The annual report of the Security, along with the report of the independent registered public accounting firm is included in the Security’s N-CSRs available at www.sec.gov. As of December 31, 2017, 24.8% of the Conservative Growth Portfolio’s net assets were invested in the Timothy Plan Fixed Income Fund.

 

Note 8 | Investments in Affiliated Companies

 

An affiliated company is a company in which a Fund has ownership of at least 5% of the voting securities. A company which is an affiliate of the Funds at December 31, 2017, is noted in the Funds’ Schedules of Investments. The Strategic Growth Portfolio, investing primarily in the following Timothy Funds which are other series of the Trust: Small Cap Value Fund, Large/Mid Cap Value Fund, Large/Mid Cap Growth Fund, Fixed Income Fund, Aggressive Growth Fund, High Yield Bond Fund, International Fund, Israel Common Values Fund, Defensive Strategies Fund, Emerging Markets Fund and Growth & Income Fund are mutual funds which are considered affiliates because they are under control of the same investment advisor. The Conservative Growth Portfolio, investing primarily in the following Timothy Funds which are other series of the Trust: Small Cap Value Fund, Large/Mid Cap Value Fund, Large/Mid Cap Growth Fund, Fixed Income Fund, Aggressive Growth Fund, High Yield Bond Fund, International Fund, Israel Common Values Fund, Defensive Strategies Fund, Emerging Markets Fund and Growth & Income Fund are mutual funds which are considered affiliates because they are under control of the same investment advisor.

 

Strategic Growth  Share Activity       Year Ended December 31, 2017 
                       Net Change in         
   Balance           Balance       Unrealized   Dividends   Amount of Gain 
   December 31,           December 31,       Appreciation   Credited to   (Loss) Realized on 
Fund  2016   Purchases   Sales   2017   Fair Value   (Depreciation)   Income   Sale of Shares* 
Aggressive Growth   116,973    85,260    57,102    145,131   $1,211,846   $207,368   $   $(29,235)
International   298,137    244,877    115,701    427,313    4,303,047    706,290    89,641    28,839 
Large/Mid Cap Growth   229,065    75,928    53,595    251,398    2,189,673    263,356    54,281    (5,475)
Small Cap Value   62,468    35,673    30,375    67,766    1,318,051    (18,192)   18,908    151,173 
Large/Mid Cap Value   103,884    47,338    25,328    125,894    2,414,642    207,089    21,504    124,306 
Fixed Income   291,472    44,370    229,865    105,977    1,075,667    33,243    15,898    (33,496)
High Yield Bond   154,995    40,255    45,021    150,229    1,403,137    57,530    51,341    (18,301)
Israel Common Values   66,498    19,174    13,513    72,159    1,117,020    205,122    14,574    22,686 
Defensive Strategies   464,556    3,494    241,613    226,437    2,647,044    109,496    3,460    (24,379)
Emerging Markets   96,469    113,118    50,165    159,422    1,578,276    230,806    10,308    20,220 
Growth & Income   326,150    7,239    149,198    184,191    2,066,628    35,284    1,476    108,475 

 

Conservative Growth  Share Activity   Year Ended December 31, 2017 
                       Net Change in         
   Balance           Balance       Unrealized   Dividends   Amount of Gain 
   December 31,           December 31,       Appreciation   Credited to   (Loss) Realized on 
Fund  2016   Purchases   Sales   2017   Fair Value   (Depreciation)   Income   Sale of Shares* 
Aggressive Growth   82,077    44,350    31,538    94,889   $792,327   $129,468   $   $108 
International   230,091    81,008    104,511    206,588    2,080,339    358,648    43,338    47,107 
Large/Mid Cap Growth   164,999    77,489    73,204    169,284    1,474,464    171,345    36,551    12,428 
Small Cap Value   61,357    10,720    21,377    50,700    986,117    (13,482)   14,146    117,488 
Large/Mid Cap Value   85,578    27,769    26,062    87,285    1,674,120    137,109    14,909    97,877 
Fixed Income   572,548    54,653    160,960    466,241    4,732,343    114,770    78,651    (98,543)
High Yield Bond   107,827    83,403    56,348    134,882    1,259,796    48,570    46,602    (13,104)
Israel Common Values   65,318    15,076    35,066    45,328    701,678    91,480    9,155    77,761 
Defensive Strategies   373,322    6,620    193,574    186,368    2,178,638    60,819    2,848    12,494 
Emerging Markets   87,465    42,534    37,976    92,023    911,032    133,451    5,950    42,336 
Growth & Income   320,343    19,290    174,246    165,387    1,855,640    6,789    1,438    130,271 

 

*Includes capital gain distributions from affiliated funds.

 

Note 9 | Subsequent Events

 

Subsequent events after the date of the Statements of Assets and Liabilities have been evaluated through the date the financial statements were issued. Management has concluded that there is no impact requiring adjustment or disclosure in the financial statements.

17

 

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 

To the Shareholders and Board of Trustees of

The Timothy Plan

 

Opinion on the Financial Statements

 

We have audited the accompanying statements of assets and liabilities, including the schedules of investments, of Timothy Plan Conservative Growth Portfolio Variable Series and Timothy Plan Strategic Growth Portfolio Variable Series (the “Funds”), each a series of The Timothy Plan, as of December 31, 2017, and the related statements of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, including the related notes, and the financial highlights for each of the five years in the period then ended (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of Timothy Plan Conservative Growth Portfolio Series and Timothy Plan Strategic Growth Portfolio Variable Series, two of the series constituting The Timothy Plan as of December 31, 2017, the results of their operations for the year then ended, the changes in their net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with accounting principles generally accepted in the United States of America.

 

Basis for Opinion

 

These financial statements are the responsibility of the Funds’ management. Our responsibility is to express an opinion on the Funds’ financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Funds in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

 

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.

 

Our audits include performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements and confirmation of securities owned as of December 31, 2017, by correspondence with the custodian. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion. We have served as the Funds’ auditor since 2005.

 

COHEN & COMPANY, LTD.

Cleveland, Ohio

February 14, 2018

18

 

Officers and Trustees of the Trust (Unaudited)

 

The Trustees and principal executive officers of the Trust and their principal occupations for the past five years are listed as follows:

 

INTERESTED TRUSTEES

 

Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Arthur D. Ally*

1055 Maitland Center Commons

Maitland, FL

 

Chairman and  President

 

  Indefinite; Trustee and President since 1994   13
  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1942

 

President and controlling shareholder of Covenant Funds, Inc. (“CFI”), a holding company. President and general partner of Timothy Partners, Ltd. (“TPL”), the investment Advisor and principal underwriter to each Fund. CFI is also the managing general partner of TPL.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Joseph E. Boatwright**

1055 Maitland Center Commons

Maitland, FL

 

Trustee, Secretary

 

 

Indefinite; Trustee and Secretary since 1995

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1930

 

 

Retired Minister. Currently serves as a consultant to the Greater Orlando Baptist Association. Served as Senior Pastor to Aloma Baptist Church from 1970-1996.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Mathew D. Staver**

1055 Maitland Center Commons

Maitland, FL

 

Born: 1956

 

Trustee

 

 

Indefinite; Trustee since 2000

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Attorney specializing in free speech, appellate practice and religious liberty constitutional law. Founder of Liberty Counsel, a religious civil liberties education and legal defense organization. Host of two radio programs devoted to religious freedom issues. Editor of a monthly newsletter devoted to religious liberty topics. Mr. Staver has argued before the United States Supreme Court and has published numerous legal articles.

 

  None

 

*Mr. Ally is an “interested” Trustee, as that term is defined in the 1940 Act, because of his positions with and financial interests in CFI and TPL.

 

**Messrs. Boatwright and Staver are “interested” Trustees, as that term is defined in the 1940 Act, because each has a limited partnership interest in TPL.

19

 

Officers and Trustees of the Trust (Unaudited)(Continued)

 

INDEPENDENT TRUSTEES

 

Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Kenneth Blackwell

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2011

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1948

 

Currently serving as an independent consultant or Fellow with the Family Research Council and the American Civil Rights Union, and is a Visiting Professor at Liberty University, Lynchburg, VA. Former Secretary of State for the State of Ohio.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Richard W. Copeland

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

  Indefinite; Trustee since 2005  

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1947

 

Retired founder of Copeland & Covert, Attorneys at Law; B.A. from Mississippi College, JD from University of Florida and LLM Taxation from University of Miami. Associate Professor Stetson University for past 40 years.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Deborah Honeycutt

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2010

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1947

 

Dr. Honeycutt is a licensed physician currently serving as Medical Director of Clayton State University Health Services in Morrow, GA, CEO of Minority Health Services in Atlanta, and as a volunteer at Good Shepherd Clinic. Dr. Honeycutt received her B.A. and M.D. at the University of Illinois.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Bill Johnson

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2005

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1946

 

President (and Founder) of American Decency Association, Freemont, MI since 1999. Previously served as Michigan State Director for American Family Association (1987-1999). Previously a public school teacher for 18 years. B.S. from Michigan State University and a Masters of Religious Education from Grand Rapids Baptist Seminary.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

John C. Mulder

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2005

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

Born: 1950  

President of WaterStone (formerly the Christian Community Foundation and National Foundation) since 2001. Prior: 22 years of executive experience for a group of banks and a trust company. B.A. in Economics from Wheaton College and MBA from University of Chicago.

 

  None

20

 

Officers and Trustees of the Trust (Unaudited)(Continued)

 

Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Charles E. Nelson

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2000

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1934

 

Certified Public Accountant, semi-retired. Former non-profit industry accounting officer. Former financial executive with commercial bank. Former partner national accounting firm. 

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Scott Preissler, Ph.D.

1055 Maitland Center Commons

Maitland, FL

 

Trustee

 

 

Indefinite; Trustee since 2004

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Born: 1960

 

Director of Steward Leadership and Professor in Residence at Shorter University. Former Chairman of Stewardship Studies at Southwestern Baptist Theological Seminary, Ft. Worth, TX. Also serves as Founder and Chairman of the International Center for Biblical Stewardship.

 

  None
         
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Alan M. Ross

1055 Maitland Center Commons

Maitland, FL

 

Born: 1951

 

Trustee, Vice Chairman

 

 

Indefinite; Trustee since 2004

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

Founder and CEO of Corporate Development Institute which he founded in 2000. Previously he served as President and CEO of Fellowship of Companies for Christ and has authored three books: Beyond World Class, Unconditional Excellence, Breaking Through to Prosperity.

 

  None
       
Name, Age and Address  

Position(s)

Held With Trust

 

Term of Office

and Length of Time Served

 

Number of Portfolios

in Fund Complex

Overseen by Trustee

Patrice Tsague

1055 Maitland Center Commons

Maitland, FL

 

Born: 1973

 

Trustee

 

 

Indefinite; Trustee since 2011

 

 

13

 

  Principal Occupation During Past 5 Years  

Other Directorships

Held by Trustee

 

President and Chief Servant Officer of the Nehemiah Project International Ministries Inc. since 1999.

  None

 

The Fund’s Statement of Additional Information includes additional information about the Trustees and is available free of charge, upon request, by calling toll-free at 1-800-846-7526.

21

 

Privacy Notice

 

     

FACTS

  WHAT DOES THE TIMOTHY PLAN DO WITH YOUR PERSONAL INFORMATION?
     
WHY?   Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some, but not all information sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this Notice carefully to understand what we do.
     
WHAT?   The types of information we collect and share depend on the product or service you have with us. This information can include:
     
    ●    Social Security Number
     
    ●    Assets
     
    ●    Retirement Assets
     
    ●    Transaction History
     
    ●    Checking Account History
     
    ●    Purchase History
     
    ●    Account Balances
     
    ●    Account Transactions
     
    ●    Wire Transfer Instructions
     
    When you are no longer our customer, we continue to share your information as described in this Notice.
     
HOW?   All financial companies need to share your personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons The Timothy Plan chooses to share; and whether you can limit this sharing.
         
Reasons we can share your personal information.     Does The Timothy Plan share?       Can you limit this sharing?  

For our everyday business purposes-

Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus.

  Yes   No

For our marketing purposes-

to offer our products and services to you.

  No   We don’t share
For joint marketing with other financial companies   No   We don’t share

For our affiliates’ everyday business purposes-

information about your transactions and experiences.

  Yes   No

For our affiliates’ everyday business purposes-

information about your creditworthiness

  No   We don’t share
For non-affiliates to market to you   No   We don’t share
         
Questions?   Call 800-662-0201

22

 

  Page 2            

 

Who we are    
Who is providing this Notice?  

Timothy Plan Family of Mutual Funds

Timothy Partners, Ltd.

 

What we do

 

   

How does The Timothy Plan protect your

personal information?

 

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

 

Our service providers are held accountable for adhering to strict policies and procedures to prevent any misuse or your nonpublic personal information.

How does The Timothy Plan collect your          

personal information?

  We collect your personal information, for example, when you

  ●      Open an account

  ●      Provide account information

    ●      Give us your contact information

    ●      Make deposits or withdrawals from your account

    ●      Make a wire transfer

    ●      Tell us where to send the money

    ●      Tell us who receives the money

    ●      Show your government-issued ID

    ●      Show your drivers’ license

    We also collect your personal information from other companies.
Why can’t I limit all sharing?   Federal law gives you the right to limit only:
     
    ●      Sharing for affiliates’ everyday business purposes-information about your creditworthiness.
     
    ●      Affiliates from using your information to market to you.
     
    ●      Sharing for non-affiliates to market to you
     
    State laws and individual companies may give you additional rights to limit sharing.

 

Definitions    
Affiliates  

Companies related by common ownership or control. They can be financial and non-financial companies.

 

Timothy Partners, Ltd. is an affiliate of The Timothy Plan

Non-affiliates  

Companies not related by common ownership or control. They can be financial and non-financial companies.

 

      The Timothy Plan does not share with non-affiliates so they can market to you.

Joint marketing  

A formal agreement between non-affiliated financial companies that together market financial products to you.

 

      The Timothy Plan does not jointly market.

23

 

Customer Identification Program

 

The Board of Trustees of the Trust has approved procedures designed to prevent and detect attempts to launder money as required under the USA PATRIOT Act. The day-to-day responsibility for monitoring and reporting any such activities has been delegated to the transfer agent, subject to the oversight and supervision of the Board.

 

Disclosures

 

HOW TO OBTAIN PROXY VOTING INFORMATION

 

Information regarding how the Funds voted proxies relating to Fund securities during the period ended June 30 as well as a description of the policies and procedures that the Funds use to determine how to vote proxies is available without charge, upon request, by calling 1-800-846-7526 or by referring to the Security and Exchange Commission’s (“SEC”) website at http://www.sec.gov.

 

HOW TO OBTAIN 1ST AND 3RD FISCAL QUARTER PORTFOLIO HOLDINGS

 

Each Fund files its complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-Q. Form N-Q is available on the SEC’s website at http://www.sec.gov and may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC (1-800-SEC-0330). The information on Form N-Q is available without charge, upon request, by calling 1-800-846-7526.

24

 

BOARD OF TRUSTEES  
Arthur D. Ally  
Kenneth Blackwell  
Joseph E. Boatwright  
Rick Copeland  
Deborah Honeycutt  
Bill Johnson  
John C. Mulder  
Charles E. Nelson  
Scott Preissler  
Alan Ross  
Mathew D. Staver  
Patrice Tsague  
   
OFFICERS  
Arthur D. Ally, President  
Joseph E. Boatwright, Secretary  
   
INVESTMENT ADVISOR  
Timothy Partners, Ltd.  
1055 Maitland Center Commons  
Maitland, FL 32751  
   
DISTRIBUTOR  
Timothy Partners, Ltd.  
1055 Maitland Center Commons  
Maitland, FL 32751  
   
TRANSFER AGENT  
Gemini Fund Services, LLC  
17605 Wright St., Suite 2  
Omaha, NE 68130  
   
INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM  
Cohen & Company, Ltd.  
1350 Euclid Ave., Suite 800  
Cleveland, OH 44115  
   
LEGAL COUNSEL  
David Jones & Assoc., P.C.  
18630 Crosstimber  
San Antonio, TX 78258 (TIMOTHY PLAN LOGO)

 

For additional information or a prospectus, please call: 1-800-846-7526
Visit the Timothy Plan web site on the internet at: www.timothyplan.com

 

This report is submitted for the general information of the shareholders of the Funds. It is not authorized for distribution to prospective investors in the Funds unless preceded or accompanied by an effective Prospectus which includes details regarding the Funds’ objectives, policies, expenses and other information. Distributed by Timothy Partners, Ltd.

 

HEADQUARTERS
The Timothy Plan
1055 Maitland Center Commons
Maitland, Florida 32751
(800) 846-7526
www.timothyplan.com
invest@timothyplan.com

 

SHAREHOLDER SERVICES
Gemini Fund Services, LLC
17605 Wright St., Suite 2
Omaha, NE 68130
(800) 662-0201

 

 

Item 2. Code of Ethics.

 

(a)           As of the end of the period covered by this report, the registrant has adopted a code of ethics that applies to the registrant's principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the registrant or a third party.

 

(b)           For purposes of this item, “code of ethics” means written standards that are reasonably designed to deter wrongdoing and to promote:

 

  (1) Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
  (2) Full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the Commission and in other public communications made by the registrant;

(3)           Compliance with applicable governmental laws, rules, and regulations;

  (4) The prompt internal reporting of violations of the code to an appropriate person or persons identified in the code; and

(5)           Accountability for adherence to the code.

 

(c)           Amendments:  During the period covered by the report, there have not been any amendments to the provisions of the code of ethics.

 

(d)           Waivers:  During the period covered by the report, the registrant has not granted any express or implicit waivers from the provisions of the code of ethics.

 

(e)           Posting:  We do not intend to post the Code of Ethics for the Officers or any amendments or waivers on a website.

 

(f)           Availability:  The Code of Ethics for the Officers can be obtained, free of charge by calling the toll free number for the appropriate Fund.

 

Item 3. Audit Committee Financial Expert.

 

(a)           The registrant has an Audit committee currently composed of three independent Trustees, Mr. Rick Copeland, Mr. John Mulder and Mr. Charles Nelson.  The registrant’s board of trustees has determined that Mr. Charles Nelson is qualified to serve as an Audit Committee Financial Expert, and has designated him as such.

 

Item 4. Principal Accountant Fees and Services.

 

(a)

Audit Fees

 

The Timothy Plan

FY 2017

FY 2016

FY 2015

FY 2014

FY 2013

$ 26,000

$ 25,000

$ 25,000

$ 25,000

$ 24,000

FY 2012 $ 24,000

 

 

(b)

Audit-Related Fees

 

The Timothy Plan          Registrant        Adviser

FY 2017

FY 2016

FY 2015

FY 2014

FY 2013

 

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

FY 2012 $ 0 $ 0

 

 

Nature of the fees:

 

 (c)

Tax Fees

 

 

The Timothy Plan

FY 2017

FY 2016

FY 2015

FY 2014

FY 2013

$ 0

$ 0

$ 0

$ 0

$ 0

FY 2012 $ 0

 

 

Nature of the fees: preparation of the 1120 RIC

 

 (d)

All Other Fees

Registrant                            

The Timothy Plan

FY 2017

FY 2016

FY 2015

FY 2014

FY 2013

$ 0

$ 0

$ 0

$ 0

$ 0

FY 2012

$ 0

 

(e) (1) Audit Committee’s Pre-Approval Policies

 

The Audit Committee Charter requires the Audit Committee to be responsible for the selection, retention or termination of auditors and, in connection therewith, to (i) evaluate the proposed fees and other compensation, if any, to be paid to the auditors, (ii) evaluate the independence of the auditors, (iii) pre-approve all audit services and, when appropriate, any non-audit services provided by the independent auditors to the Trust, (iv) pre-approve, when appropriate, any non-audit services provided by the independent auditors to the Trust's investment adviser, or any entity controlling, controlled by, or under common control with the investment adviser and that provides ongoing services to the Trust if the engagement relates directly to the operations and financial reporting of the Trust, and (v) receive the auditors’ specific representations as to their independence;

 

  (2) Percentages of Services Approved by the Audit Committee

 

 

 

Registrant

 

Audit-Related Fees:   0%
Tax Fees:   0%
All Other Fees:   0%

(f)           During audit of registrant's financial statements for the most recent fiscal year, less than 50 percent of the hours expended on the principal accountant's engagement were attributed to work performed by persons other than the principal accountant's full-time, permanent employees.

 

(g)           The aggregate non-audit fees billed by the registrant's accountant for services rendered to the registrant, and rendered to the registrant's investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant:

 

  Registrant Adviser

 

FY 2017

FY 2016

FY 2015

FY 2014

FY 2013

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

$ 0

FY 2012 $ 0 $ 0

 

(h)           Not applicable.  The auditor performed no services for the registrant’s investment adviser or any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant.

 

Item 5. Audit Committee of Listed Companies.  Not applicable.

 

Item 6.  Schedule of Investments.   Not applicable – schedule filed with Item 1.

 

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Funds.  Not applicable.

 

Item 8.  Portfolio Managers of Closed-End Management Investment Companies.  Not applicable.

 

Item 9.  Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.  Not applicable.

 

Item 10.  Submission of Matters to a Vote of Security Holders

The registrant has not adopted procedures by which shareholders may recommend nominees to the registrant’s board of trustees.

 

Item 11.  Controls and Procedures.

 

(a)           Based on an evaluation of the registrant’s disclosure controls and procedures as of November 19, 2010, the disclosure controls and procedures are reasonably designed to ensure that the information required in filings on Forms N-CSR is recorded, processed, summarized, and reported on a timely basis.

 

(b)           There were no significant changes in the registrant’s internal control over financial reporting that occurred during the registrant’s second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.

 

Item 12.  Exhibits.

 

(a)(1)

Code is filed herewith

 

(a)(2)

Certifications  by the  registrant's  principal  executive  officer and principal financial officer, pursuant to Section 302 of the Sarbanes- Oxley Act of 2002 and required by Rule  30a-2 under the Investment Company Act of 1940 are filed herewith.

 

(a)(3)

Not Applicable

 

(b)

Certification pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 is filed herewith.

 

 

 


 

 

SIGNATURES

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

(Registrant)   The Timothy Plan                                           

 

By /s/ Arthur D. Ally  
  Arthur D. Ally, President/Principle Executive Officer & Treasurer/Principle Financial Officer
   
Date 2/27/18  

 

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

 

 

By /s/ Arthur D. Ally  
  Arthur D. Ally, President/Principle Executive Officer & Treasurer/Principle Financial Officer
   
Date 2/27/18  

 

 

EX-99.CERT 2 cert1.htm Blu Giant, LLC

EX-99.CERT 2 cert99.htm SECTION 302 CERTIFICATIONS

 

SECTION 302 CERTIFICATIONS

 

I, Arthur D. Ally, certify that:

 

1. I have reviewed this report on Form N-CSR of the Timothy Plan;

 

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

 

3. Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;

 

4. The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:

 

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

 

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

 

(c) Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and

 

(d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

 

5. The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):

 

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and

 

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

 

 

Date 2/27/18   /s/ Arthur D. Ally
      Arthur D. Ally, President/Principle Executive Officer & Treasurer/Principle Financial Officer
 
 

 

EX-99.906 CERT 3 cert2.htm Blu Giant, LLC

EX-99.906 CERT 3 cert906.htm SECTION 906 CERTIFICATION

 

SECTION 906 CERTIFICATION

 

Arthur D. Ally, President/Principle Executive Officer & Treasurer/Principle Financial Officer of the Timothy Plan (the "Registrant"), certifies to the best of his knowledge that:

 

1. The Registrant's periodic report on Form N-CSR for the period ended December 31, 2017 (the "Form N-CSR") fully complies with the requirements of Sections 15(d) of the Securities Exchange Act of 1934, as amended; and

 

2. The information contained in the Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Registrant.

 

President/Principle Executive Officer & Treasurer/Principle Financial Officer

Timothy Plan                                                       

 

/s/ Arthur D. Ally

Arthur D. Ally

 

Date 2/27/18
   

 

A signed original of this written statement required by Section 906 of the Sarbanes-Oxley Act of 2002 has been provided to the Timothy Plan and will be retained by the Timothy Plan and furnished to the Securities and Exchange Commission (the "Commission") or its staff upon request.

 

This certification is being furnished to the Commission solely pursuant to 18 U.S.C. ss. 1350 and is not being filed as part of the Form N-CSR filed with the Commission.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EX-99.CODE ETH 4 coe.htm Blu Giant, LLC

CODE OF ETHICS

OF

THE TIMOTHY PLAN

 

 

I.       Introduction

 

This Code of Ethics has been adopted by The Timothy Plan (the "Trust”) in compliance with Rule 17j-1 (the "Rule") under the Investment Trust Act of 1940, as amended (the "Act") to establish standards and procedures for the detection and prevention of activities by which persons having knowledge of the investments and investment intentions of the Trust may abuse their fiduciary duties to the Trust, and to deal with other types of conflict-of-interest situations to which the Rule is addressed.

 

The Rule makes it "unlawful" for certain persons who have affiliations with the Trust to engage in conduct which is deceitful, fraudulent or manipulative, or which involves false or misleading statements, in connection with the purchase or sale of securities by the Trust. This Code of Ethics is intended to establish policies and procedures designed to insure that persons subject to this Code of Ethics and the Rule do not use any information concerning the investments or investment intentions of the Trust, or his or her ability to influence such investment related information, for personal gain or in a manner detrimental to the interests of the Trust.

 

II.       Principles

 

This Code of Ethics acknowledges the general principles that persons affiliated with the Trust:

 

(A)owe a fiduciary obligation to the Trust;
(B)have the duty at all times to place the interests of Trust shareholders first;
(C)must conduct all of their personal securities transactions in such a manner as to avoid any actual or potential conflict of interest or abuse of such person’s position of trust and responsibility; and
(D)should not take inappropriate advantage of their positions in relation to the Trust.

 

III.       Definitions (as used herein)

 

"Access Person" means:

A
(1)any Trustee, officer, general partner or Advisory Person of the Trust or any Adviser to the Trust.

 

(A)If an Adviser to the Trust is primarily engaged in a business or businesses other than advising Funds or other advisory clients, the term Access Person means any Trustee, officer, general partner or Advisory Person of the Adviser who, with respect to any Fund, makes any recommendation, participates in the determination of which recommendation will be made, or whose principal function or duties relate to the determination of which recommendation will be made, or who, in connection with his or her duties, obtains any information concerning recommendations on Covered Securities being made by the Adviser to any Fund.

 

(B)An Adviser is “primarily engaged in a business or businesses other than advising Funds or other advisory clients” if, for each of its most recent three fiscal years or for the period of time since its organization, whichever is less, the Adviser derived, on an unconsolidated basis, more than 50% of its income (or loss), before taxes and extraordinary items, from the other business or businesses.

 

 
 
(2)Any Trustee, officer or general partner of a principal underwriter who, in the ordinary course of business, makes, participates in or obtains information regarding, the purchase or sale of Covered Securities by the Trust for which the principal underwriter acts, or whose functions or duties in the ordinary course of business relate to the making of any recommendation to the Trust, regarding the purchase or sale of Covered Securities.

 

“Advisory Person” means:

 

(1)Any employee of the Trust or an Adviser to the Trust (or of any Trust in a control relationship to the Trust or an investment adviser to the Trust) who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of Covered Securities by the Trust, or whose functions relate to the making of any recommendations with respect to such purchases or sales; and

 

(2)Any natural person in a control relationship to the Trust or an Adviser to the Trust who obtains information concerning recommendations made to the Trust with regard to the purchase or sale of Covered Securities by the Trust.

 

"Affiliated Person" means:

 

(1)Any officer, Trustee, copartner or employee of the Trust, Adviser and/or Underwriter;

 

(2)any person directly or indirectly owning, controlling or holding with power to vote, 5% or more of the outstanding voting securities of the Trust, Adviser and/or Underwriter;

 

(3)any person 5% or more of whose outstanding voting securities are directly or indirectly owned, controlled or held with power to vote, by the Trust, Adviser and/or Underwriter; and

 

(4)any person directly or indirectly controlling, controlled by, or under common control with the Trust, Adviser and/or Underwriter.

 

"Beneficial Interest" means:

 

any interest by which an Access Person or any member of his or her immediate family (relative by blood or marriage living in the same household), can directly or indirectly derive a monetary benefit from the purchase, sale (or other acquisition or disposition) or ownership of a security, except such interests as Clearing Officers shall determine to be too remote for the purpose of this Code of Ethics. (A transaction in which an Access Person acquires or disposes of a security in which he or she has or thereby acquires a direct or indirect Beneficial Interest will be referred to in this Code of Ethics as a "personal securities" transaction or as a transaction for the person's "own account").

 

At the written request of a person subject to this Code of Ethics, the Clearing Officers, in their sole discretion or with the advice of counsel, may from time to time issue written interpretations as to whether an Access Person has a “Beneficial Interest” in a security or a transaction, and whether a transaction is or would be considered to be a “personal securities” transaction or a transaction “for the person’s own” account for purposes of the reporting requirements under this Code. Any such written interpretations shall be included in Appendix A attached to and incorporated by reference into this Code of Ethics, and may be relied upon solely by the person(s) seeking such interpretations.

 

“Clearing Officers” means any two officers of the Trust who are not:

 

(1)parties to the transaction;
(2)related by blood or marriage to a party to the transaction; and
(3)interested in or affiliated persons of the issuer of the securities at issue.
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Control” means:

 

the power to exercise a controlling influence over the management or policies of a Trust (unless such power is solely the result of an official position with such Trust). Any person who owns beneficially, directly or through one or more controlled companies, more than 25% of the voting securities of a Trust shall be presumed to control such Trust.

 

“Covered Security” means:

 

all stock, debt obligations and other instruments comprising the investments of the Trust, including any warrant or option to acquire or sell a security, and financial futures contracts, except that it does not include:

 

(1)Direct obligations of the Government of the United States;

 

(2)Banker’s acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements, and

 

(3)Shares issued by open-end Funds.

 

References to a "Security" in this Code of Ethics shall include any warrant for, option in, or security immediately convertible into that "Security."

 

“Fund” means an investment company registered under the Act, and includes the Trust.

 

A "security held or to be acquired" by the Trust means:

 

any Covered Security which, within the most recent 15 calendar days: (i) is or has been held by the Trust; or (ii) is being or has been considered by an Adviser for purchase by the Trust.

 

A security is "being considered for purchase or sale";

 

from the time an order is given by or on behalf of the Trust to the order room of the Adviser until all orders with respect to that security are completed or withdrawn.

 

III.       General Prohibitions

 

The specific provisions and reporting requirements of the Rule and this Code of Ethics are concerned primarily with those investment activities of Access Persons who are associated with the Trust and who thus may benefit from or interfere with the purchase or sale of portfolio securities by the Trust. However, the Rule and this Code of Ethics shall also apply to all Affiliated Persons of the Trust, the Adviser(s), Sub-Adviser(s) and the Underwriter ("Covered Persons"), unless specifically stated otherwise.

 

The Rule makes it "unlawful" for Covered Persons to engage in conduct which is deceitful, fraudulent, or manipulative, or which involves false or misleading statements, in connection with the purchase or sale of securities by the Trust. Accordingly, under the Rule and this Code of Ethics, no Covered Person shall use any information concerning the investments or investment intentions of the Trust, or his or her ability to influence such investment intentions, for personal gain or in a manner detrimental to the interests of the Trust.

 

In addition, no Covered Person shall, directly or indirectly in connection with the purchase or sale of a "security held or to be acquired" by the Trust:

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(i)employ any device, scheme or artifice to defraud the Trust; or

 

(ii)make to the Trust or an Adviser any untrue statement of material fact or omit to state to any of the foregoing a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading; or

 

(iii)engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon the Trust; or

 

(iv)engage in any manipulative practice with respect to the Trust.

 

V.        Prohibited Transactions

 

A.Blackout Periods

 

Subject to any additional limiting requirements that may be set forth below, an Advisory Person may not effect a personal securities transaction in a “security held or to be acquired” by the Trust unless such person:

 

(1)executes such transaction at a price equal to or less advantageous than the price obtained for such security by the Trust; and
(2)reports to the Trust the information described in Paragraph VI of this Code of Ethics.

 

Any profits realized on personal securities transactions in violation of this Section V shall be disgorged.

 

B. Initial Public Offerings

 

An Advisory Person may not acquire any security in an initial public offering, unless such Advisory Person (1) obtains advance written clearance of such transaction by two Clearing Officers and (2) reports to the Trust the information described in Paragraph VI of this Code of Ethics.

 

C. Private Placements

 

(1)An Advisory Person may not acquire any security in a private placement, unless such Advisory Person (1) obtains advance written clearance of such transaction by two Clearing Officers and (2) reports to the Trust the information described in Paragraph VI of this Code of Ethics.

 

When considering whether to grant approval to the Advisory Person to engage in these transactions, the Clearing Officers shall consider, among other factors, whether the investment opportunity should be reserved for the Trust, and whether the opportunity is being offered to the Advisory Person by virtue of his or her position with the Trust. If the Clearing Officers find that the investment opportunity should be reserved to the Trust or that the opportunity is being offered to the Advisory Person by virtue of his or her position with the Trust, the Clearing Officers shall refuse permission for the Advisory Person to enter into the transaction.

 

(2)An Advisory Person who has been authorized to acquire securities in a private placement or an initial public offering shall be required to disclose that investment to the Trust and the appropriate Adviser whenever such Advisory Person participates, either directly or indirectly, in subsequent consideration of an investment in the issuer by any portfolio in the Trust complex.

 

(3)In the event that an Advisory Person has been given approval to acquire securities in a private placement or an initial public offering, any decision of the Trust to purchase securities of the issuer of such private placement or initial public offering shall be subject to prior review by the Trust’s independent Trustees who have no personal interest in the issuer.
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D. Ban On Short - Term Trading Profits

 

An Advisory Person may not profit from the purchase and sale, or sale and purchase, of the same (or equivalent) securities within 60 calendar days, unless such transactions fully comply with the restrictions of Section V(A) of this Code of Ethics. Any profits realized on non-complying short-term trades shall be disgorged.

 

F. Gifts

 

Advisory Persons may not accept any gift or other thing of more than de minimis value from any person or entity that does business with or on behalf of the Trust.

 

G. Service as a Trustee to Other Public Companies

 

Advisory Persons may not serve on the board of directors of any publicly traded company, without prior authorization of a majority of the Trust’s Board of Trustees, which authorization shall be specifically based upon a determination that the board service would be consistent with the interests of the Trust and its shareholders. If and when such board service is authorized, the Advisory Person serving as a director will be isolated from other Advisory Persons who make investment decisions involving that company through "Chinese Wall" or other procedures.

 

VI. Advance Clearance Requirement

 

A. Procedures

 

(1) From Whom Obtained

Persons who desire to enter into personal securities transactions in transactions requiring prior approval under paragraph V above, must obtain the written approval of any two Clearing Officers prior to entering into such transactions.

 

(2) Time of Clearance

Transaction clearances must be obtained not more than three (3) days prior to the transaction. If the trade is not made within three (3) days of the date of clearance, a new clearance must be obtained.

 

(3) Form

Persons seeking authorization to enter into transactions requiring prior clearance shall complete and sign a form approved for that purpose by the Trust, which form shall set forth the details of the proposed transaction. An example of such form is annexed hereto as Schedule A (“Clearance Forms”). Upon obtaining authorization to enter into the subject transaction, the Clearing Officers authorizing the transaction shall affix their signatures to the Clearance Form to indicate such approval.

 

(4) Filing

Copies of all completed Clearance Forms, with all required signatures, shall be retained by the Administrator of this Code of Ethics in accordance with the record keeping requirements set forth in Section XII of this Code of Ethics.

 

B. Factors Considered in Clearance of Personal Transactions

 

Clearing Officers may refuse to grant clearance of a personal transaction in their sole discretion without being required to specify any reason for the refusal. Generally, Clearing Officers will consider the following factors in determining whether or not to authorize a proposed transaction:

5 
 

 

(1)Whether the amount or nature of the transaction, or person entering into the transaction, is likely to affect the price or market for the Security;

 

(2)Whether the individual making the proposed purchase or sale is likely to benefit from purchases or sales in the same or similar security being made or being considered by the Trust; and

 

(3)Whether the security proposed to be purchased or sold is one that would qualify for purchase or sale by the Trust.

 

VII. Exempt Transactions

 

Neither the prohibitions nor the reporting requirements of this Code of Ethics apply to:

 

(A)Purchases, sales or other acquisitions or dispositions of Securities for an account over which the person has no direct influence or control and does not exercise indirect influence or control;

 

(B)Purchases, sales or other acquisitions or dispositions of securities which are not eligible for purchase or sale by any portfolio of the Trust;

 

(C)Involuntary purchases or sales;

 

(D)Purchases which are part of an automatic dividend reinvestment plan; and

 

(E)Purchases or other acquisitions or dispositions resulting from the exercise of rights acquired from an issuer as part of a pro rata distribution to all holders of a class of securities of such issuer and the sale of such rights;

 

VIII.       Reporting of Securities Transactions

 

A. Reporting Requirements of Access Persons

 

(1)Reports Required: Unless specifically excepted by other provisions of this Code of Ethics, every Access Person of the Trust, Adviser, Sub-Adviser(s) and Underwriter must provide to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, the following reports:

 

(a)Initial Holdings Reports- Not later than ten (10) days after a person becomes an Access Person, such person shall complete, sign and deliver to the Trust, and the Adviser(s) or Underwriter, as applicable, an Initial Holdings Report, a form of which is attached to this Code of Ethics as Schedule B; except that

 

(i)Any person who qualified as an Access Person prior to March 1, 2000 shall be exempt from filing an Initial Holdings Report.

 

(b)Quarterly Transaction Reports- Not later than ten (10) days after the end of each calendar quarter, each Access Person shall make a written report (“Quarterly Transaction Report”), a form of which is attached to this Code of Ethics as Schedule C, to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, which;

 

(1)With respect to any transaction during the previous calendar quarter in a Covered Security in which the Access Person had any direct or indirect Beneficial Ownership, contains the following information:
6 
 

 

(i)The date of the transaction, the title, the interest rate and maturity date (if applicable), the number of shares and the principal amount of each Covered Security involved:

 

(ii)The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

 

(iii)The price of the Covered Security at which the transaction was effected;

 

(iv)The name of the broker, dealer or bank with or through which the transaction was effected; and

 

(v)The date that the report is submitted by the Access Person.

 

(2)With respect to any account established by the Access Person in which any securities were held during the previous quarter for the direct or indirect benefit or the Access Person, contains the following information:

 

(ii)The name of the broker, dealer or bank with whom the Access Person established the account;

 

(iii)The date the account was established; and

 

(iv)The date that the report is submitted by the Access Person.

 

(c)Annual Holding Reports- Not later than thirty (30) days after the end of the Trust’s fiscal year end, each Access Person shall make a written report, a form of which is attached to this Code of Ethics as Schedule D (“Annual Holdings Report”), to the Administrator of this Code of Ethics and the Adviser(s) or Underwriter, as applicable, which:

 

(1)Sets forth the title, number of shares and principal amount of each Covered Security in which the Access Person had any direct or indirect beneficial ownership;
(2)Sets forth the name of any broker, dealer or bank with whom the Access Person maintains an account in which any securities are held for the direct or indirect benefit of the Access Person;
(3)Contains the date that the report is submitted by the Access Person; and
(4)States that the information contained in the Annual Holdings Report is current as of a date not greater than thirty (30) days prior to the date the report was submitted.

 

B.       Exemptions from Reporting

 

(1)A person need not make an Initial Holdings Report with respect to transactions effected for, and Covered Securities held in, any account over which the person has no direct or indirect influence or control.

 

(2)A Trustee of the Trust who is not an "interested person" of the Trust, as such term is defined in Section 2(a)(19) of the Act, and who would otherwise be required to make a report solely by reason of being a Trustee of the Trust, need not make:

 

(a)An Initial Holdings Report or an Annual Holdings Report; and

 

(b)A Quarterly Transaction Report, unless the Trustee knew, or in the ordinary course of fulfilling his or her official duties as a Trustee should have known, that during the fifteen (15) day period immediately before or after the Trustee’s transaction in a Covered Security, the Trust purchased or
7 
 

sold the Covered Security, or the Trust or an Adviser considered purchasing or selling the Covered Security.

 

(3)An Access Person of the Trust’s Underwriter need not make a report to the Underwriter, if such person makes a report to the Trust and:

 

(a)The Underwriter is not an affiliated person of the Trust or any Adviser to the Trust; and

 

(b)The Underwriter has no officer, Trustee or general partner who serves as an officer, Trustee or general partner of the Trust or an Adviser to the Trust.

 

(4)An Access Person of an Adviser need not make a report to the Adviser, if such person makes a report to the Trust and all of the information contained in such report would duplicate information required to be recorded under §§ 275.204-2(a)(12) or 275.204(a)(13) of the Investment Advisers Act of 1940, as amended.

 

(5)An Access Person need not make a Quarterly Transaction Report if the Report would duplicate information contained in broker trade confirmations or account statements received by the Trust with respect to the Access Person for the applicable quarterly reporting period, but only if such broker trade confirmations or account statements contain ALL of the information required to be reported in the Quarterly Transaction Reports.

 

C. Responsibility to Report

 

The responsibility for taking the initiative to report is imposed on each individual required to make a report. Any effort by the Trust to facilitate the reporting process does not change or alter that responsibility.

 

D. Where to File Report

 

All reports must be filed with the Administrator of this Code of Ethics.

 

IX. Confidentiality of Trust Transactions

 

Until disclosed in a public report to shareholders or to the SEC in the normal course of the Trust’s business, all information concerning Securities "being considered for purchase or sale" by the Trust shall be kept confidential by all Access Persons and disclosed by them only on a "need to know" basis. It shall be the responsibility of the Administrator of this Code of Ethics to report any inadequacy found by him or her to the Board of Trustees of the Trust or any committee appointed by the Board to deal with such information.

 

X. Sanctions

 

Any violation of this Code of Ethics shall be subject to the imposition of such sanctions by the Trust as may be deemed appropriate under the circumstances to achieve the purposes of the Rule and this Code of Ethics which may include suspension or termination of employment, a letter of censure and/or restitution of an amount equal to the difference between the price paid or received by the Trust and the more advantageous price paid or received by the offending person. Sanctions for violation of this Code of Ethics by a Trustee of the Trust will be determined by a majority vote of its independent Trustees.

 

XI. Administration and Construction

 

(A)The administration of this Code of Ethics shall be the responsibility of the President of the Trust who shall serve as the "Administrator" of this Code of Ethics.

 

(B)The duties of such Administrator shall include:
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(1) Continuous maintenance of a current list of the names of all Access Persons with an appropriate description of their title or employment;

 

(2) Providing each Covered Person a copy of this Code of Ethics and informing them of their duties and obligations thereunder, and assuring that Covered Persons who are not Access Persons are familiar with applicable requirements of this Code of Ethics;

 

(3) Supervising the implementation of this Code of Ethics by the Adviser(s) and Underwriter and the enforcement of the terms hereof by the Adviser(s) and Underwriter;

 

(4) Maintaining or supervising the maintenance of all records and reports required by this Code of Ethics;

 

(5) Preparing listings of all transactions effected by any Access Person within fifteen (15) days of the date on which the same security was held, purchased or sold by the Trust;

 

(6) Determining whether any particular securities transaction should be exempted pursuant to the provisions of this Code of Ethics;

 

(7) Issuing either personally, or with the assistance of counsel as may be appropriate, an interpretation of this Code of Ethics which may appear consistent with the objectives of the Rule of this Code of Ethics;

 

(8) Conducting of such inspections or investigations, including scrutiny of the listings referred to in the preceding subparagraph, as shall reasonably be required to detect and report, with his or her recommendations, any apparent violations of this Code of Ethics to the Board of Trustees of the Trust or any Committee appointed by them to deal with such information;

 

(9) Submitting a quarterly report to the Trustees of the Trust containing a description of any violation and the sanction imposed; transactions which suggest a possibility of a violation, and any exemptions or waivers found appropriate by the Administrator; and any other significant information concerning the appropriateness of this Code of Ethics.

 

XII. Required Records

 

The Administrator shall maintain or cause to be maintained in an easily accessible place, the following records:

 

(A) A copy of this and any other Code of Ethics adopted pursuant to the Rule which has been in effect during the past five (5) years;

 

(B) A record of any violation of such Codes of Ethics and of any action taken as a result of such violation;

 

(C) A copy of each report made by the Administrator within two (2) years from the end of the fiscal year of the Trust in which such report and interpretation is made or issued and for an additional three (3) years in a place which need not be easily accessible;

 

(D) A list of all persons who are, or within the past five (5) years have been, required to make reports pursuant to the Rule and this Code of Ethics; and

 

(E) A copy of all Initial Holdings Reports, Quarterly Transactions Reports, and Annual Holdings Reports submitted within the last five (5) years, the first two (2) years in an easily accessible place.

 

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XIII. Amendments and Modifications

 

This Code of Ethics may not be amended or modified except in a written form which is specifically approved by majority vote of the Independent Trustees of the Trust.

 

 

This Code of Ethics was adopted by the Trust’s Board of Trustees, including a majority of the Trust’s “Independent Trustees”, at a meeting held on November 3, 2000.

 

Witness my Signature:

 

 

 

___________________________

Joseph Boatwright

Secretary to the Trust

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SCHEDULE A

 

CONFIDENTIAL TRANSACTION CLEARANCE

REQUEST FORM

 

Pursuant to the requirements of Section V of the Code of Ethics of The Timothy Plan (the “Trust”), I, ______________________, being an Access Person of the Trust, as that term is defined in the Code, hereby request that the Trust approve the following transaction in Covered Securities:

 

Name of Security: _________________________________________________________

 

Number of shares/Principal amount:____________________________________________

 

Nature of transaction: ___________________________________

(i.e., purchase, sale or other type of acquisition or disposition);

 

Name of broker/dealer or bank executing transaction: ________________________________

 

Yes No  
     
___ ___ The security described above represents an investment in an initial public offering.
     
___ ___ The security described above represents an investment in a private placement.

 

By my signature below, I swear and affirm that I have not engaged in any transactions in the above-described securities in violation of the Trust’s Code of Ethics, that I will invest in the above-described securities only after obtaining clearance to do so from authorized officers of the Trust, will report all such transactions in accordance with the requirements of the Trust’s Code of Ethics, and if I receive clearance to engage in the above-described security, I will execute the transaction not later than three (3) days after receiving clearance or will obtain a new clearance prior to executing the transaction.

 

 

__________________________________                 __________________________________

Signature of Applicant Printed Name of Applicant

 

 

_____ After due consideration, the proposed transaction described above is APPROVED.

 

_____ After due consideration, the proposed transaction is DENIED.

 

_____(Check only if approving a transaction that represents an investment in an initial public offering or in a private placement). We, the undersigned, in the exercise of our obligations to the Trust under the Trust’s Code of Ethics, have found that the above-described transaction is not a transaction that should be reserved to the Trust, and we further find that the transaction is not being offered to the Applicant as a result of his/her position with the Trust, Adviser or Underwriter.

 

__________________________________           __________________________________
Signature of Clearing Officer Date   Signature of Clearing Officer Date

 

__________________________________           ___________________________________
Printed Name Printed Name

 

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SCHEDULE B

CONFIDENTIAL INITIAL

HOLDINGS REPORT

THE TIMOTHY PLAN

 

The following lists all holdings in Covered Securities in which I had any direct or indirect beneficial ownership as of ________________________. (If no transactions took place write "None".) Sign and return to the Secretary of the Trust not later than the 10th day after you qualify as an Access Person. Use reverse side if additional space is needed.

 

HOLDINGS IN COVERED SECURITIES

 

 

Transaction Date

Description of Security Number of Shares/ Units

 

Per Unit Price

Total Amount Broker executing Transaction
           
           
           
           
           
           
           
           
           
           
           
           
           
           

 

The following lists all accounts established by me as of _______________________ in which I had any direct or indirect beneficial ownership in any Securities. (If no accounts were established, write "None".) Sign and return to the Secretary of the Trust not later than the 10th day after you qualify as an Access Person. Use reverse side if additional space is needed.

 

Name of Broker, Dealer or Bank Date Account Established
   
   
   

 

 

 

  Name: _________________________
Date: _________________________ Signature: _________________________
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SCHEDULE C

QUARTERLY SECURITIES TRANSACTIONS

CONFIDENTIAL REPORT

THE TIMOTHY PLAN

 

The following lists all transactions in Covered Securities in which I had any direct or indirect beneficial ownership during the last calendar quarter. (If no transactions took place write "None".) Sign and return to the Secretary of the Trust not later than the 10th day of the month following the end of the calendar quarter. Use reverse side if additional space is needed.

 

PURCHASES/SALES AND OTHER DISPOSITIONS

 

 

 

Transaction Date

 

 

Description of Security

Purchase (P), Sale(S), or Other Disposition (Describe)

 

Number of Shares/ Units

 

 

 

Per Unit Price

 

 

Total Amount

 

 

Broker executing Transaction

             
             
             
             
             
             
             
             
             
             
             
             
             
             

 

The following lists all accounts established by me during the last calendar quarter in which I had any direct or indirect beneficial ownership in any Securities. (If no accounts were established, write "None".) Sign and return to the Secretary of the Trust not later than the 10th day of the month following the end of the calendar quarter. Use reverse side if additional space is needed.

 

Name of Broker, Dealer or Bank Date Account Established
   
   
   

 

 

 

 

 

  Name: _________________________
Date: _________________________ Signature: _________________________
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SCHEDULE B

CONFIDENTIAL ANNUAL

SECURITIES HOLDINGS REPORT

THE TIMOTHY PLAN

 

The following lists all holdings in Covered Securities in which I had any direct or indirect beneficial ownership as of ________________________. (If no transactions took place write "None".) Sign and return to the Secretary of the Trust not later than the 30th day after the Trust’s fiscal year end. Use reverse side if additional space is needed.

 

HOLDINGS IN COVERED SECURITIES

 

 

Transaction Date

Description of Security Number of Shares/ Units

 

Per Unit Price

Total Amount Broker executing Transaction
           
           
           
           
           
           
           
           
           
           
           
           
           
           

 

The following lists all accounts established by me as of _______________________ in which I had any direct or indirect beneficial ownership in any Securities. (If no accounts were established, write "None".) Sign and return to the Secretary of the Trust not later than the 30th day after the Trust’s fiscal year end. Use reverse side if additional space is needed.

 

Name of Broker, Dealer or Bank Date Account Established
   
   
   

 

I swear and affirm that the foregoing information is true and correct to the best of my information and belief, and that the information included in this report is current as of a date not later than thirty (30) days prior to the filing of this report.

 

 

  Name: _________________________
Date: _________________________ Signature: _________________________
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VERIFICATION OF ACCESS PERSONS

 

THE TIMOTHY PLAN

 

Required Report for

Code of Ethics of The Timothy Plan

As Adopted November 3, 2000

 

Listed below are the names and current mailing addresses of all persons, as of October 31, 2000, who are considered to be “Access Persons” of The Timothy Plan, as such term is defined in the Code of Ethics of The Timothy Plan (the “Trust”), as adopted on November 3, 2000 (the “Code”).

 

Name of Access Person Mailing Address

 

1. __________________ ___________________________________

2. __________________ ___________________________________

3. __________________ ___________________________________

4. __________________ ___________________________________

5. __________________ ___________________________________

6. __________________ ___________________________________

7. __________________ ___________________________________

8. __________________ ___________________________________

9. __________________ ___________________________________

 

 

15 
 

ACKNOWLEDGEMENT OF RECEIPT

OF CODE OF ETHICS

OF

THE TIMOTHY PLAN

 

Required Report for

Code of Ethics of The Timothy Plan

As Adopted November 3, 2000

 

 

I, ___________________________, certify by my signature below as follows:

 

 

1.I have received, read, understand and agree to comply with the Code of Ethics of The Timothy Plan (the “Trust”), as adopted on November 3, 2000 (the “Code”); and

 

2.I acknowledge that I am an “Access Person” of the Trust, as such term is defined in the Code and that Access Persons of the Trust are generally required make periodic reports of their securities transactions and securities holdings; and

 

3.I am subject to the reporting requirements of the Code; and

 

4.On the first day following the end of each calendar quarter (January 1st, April 1st, July 1st, October 1st ) I will receive a Quarterly Securities Transaction Report from the Trust. I will complete and return the Report to Michael J. Senior not later than the tenth day of the month in which the Report is sent; and

 

5.I will inform the Trust of any change in my mailing address within ten (10) days of such change.

 

 

_________________________ _________________________
Date: Signature
   
  _________________________
  Printed Name
   

 

16 
 

AUTHORIZATION

OF

RESPONSIBLE INDIVIDUAL

 

THE TIMOTHY PLAN

 

Pursuant to the requirements of the Code of Ethics of The Timothy Plan, as adopted on November 3, 2000 (the “Code”), Mr. Arthur D. Ally has been appointed, by vote of the Board of Trustees of the Trust to be the person responsible for the review of all transaction and holdings reports required to be filed under the Code.

 

Mr. Ally will file a quarterly report with the Board of Trustees indicating and/or including:

 

1.Any reports required to be filed under the Code for the reporting period;
2.The names of each person required to file a report under the Code;
3.The names of any reporting person who failed to timely file a required report;
4.Copies of all submitted reports; and
5.A description of any violations or apparent violations of the Code for the reporting period.

 

 

_________________________ _____________________________
Date By: Joseph Boatwright
  For the Trust
   
_________________________ _____________________________
Date By: Arthur D. Ally
   
17 
 
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