View Document Text
Part 2A Appendix 1 of Form ADV:
Wrap Fee Program Brochure
of
Arvest Wealth Management
March 27, 2026
This wrap fee program brochure (“Brochure”) provides information about the qualifications and business
practices of Arvest Investments, Inc. d/b/a Arvest Wealth Management (the “Firm”), an investment
adviser registered with the SEC (#801 – 63738). Please note that registration with the SEC does not imply
a certain level of skill or training. If you have questions about the contents of this Brochure, please contact
us at (888) 916-2121 or AWMSolutionsCenter@arvest.com. The information in this Brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state securities
authority.
Additional information about Arvest Wealth Management also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Arvest Wealth Management is the trade name used by Arvest Investments, Inc., an SEC registered
investment adviser and broker-dealer, member FINRA/SIPC, and a wholly owned subsidiary of Arvest
Bank.
Physical Address: 913 West Monroe, Lowell, AR 72745
Mailing Address: P.O. Box 1515, Lowell, AR 72745
Web Address: https://www.arvest.com/personal/invest
Item 2 Material Changes
The following are material changes to our Arvest Wealth Management, Inc. (AWM) Wrap Fee Program
Brochure (Form ADV Part 2A) since the most recent revision dated September 16, 2025.
In addition to various product provider arrangements, our firm receives payments from certain product
providers through preferred provider relationships. These companies are selected based on several
factors, including product breadth, financial stability, and service support. In exchange for being
designated as a preferred provider, these companies pay us additional revenue-sharing fees. The
existence of these preferred arrangements creates a conflict of interest, as there is a financial incentive
for our firm to make available a preferred provider over a non-preferred one. However, our financial
professionals are required to act in a fiduciary capacity and must provide recommendations based on your
specific needs in your best interest, regardless of the provider’s preferred status. These revenue-sharing
payments are paid from the provider's own assets and are not charged to the Firm’s clients.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to AWMSolutionsCenter@arvest.com , or by calling (888) 916-2121.
Consistent with the current rules, we will ensure that you receive a summary of any material changes to
this and subsequent Brochures within 120 days of the close of our business’ fiscal year, which is December
31. Furthermore, we will provide you with other interim disclosures about material changes, as necessary.
You can access additional information about our firm and our management personnel on the SEC’s
website, www.adviserinfo.sec.gov, and on FINRA’s website, https://brokercheck.finra.org/.
Page 2 of 32
March 2026
Item 3 Table of Contents
Contents
Item 2
Material Changes .................................................................................................... 2
Item 3
Table of Contents ................................................................................................... 3
Item 4
Services, Fees and Compensation............................................................................ 5
Item 5
General Information Regarding the Wrap Fee Programs......................................................................... 6
Arvest Wealth Management SMA Strategies ........................................................................................... 9
Arvest Wealth Management Unified Managed Account (UMA) .............................................................. 9
BNYA AdvisorFlex Portfolios ..................................................................................................................... 9
BNYA Target Risk Portfolios .................................................................................................................... 10
Mutual Funds & ETF Strategists ............................................................................................................. 10
BlackRock Investment Management, LLC Target Allocation Portfolios .............................................. 10
Calvert – Responsible Allocation Models ........................................................................................... 11
Capital Research and Management Company ................................................................................... 11
First Trust ETF Model Portfolios .......................................................................................................... 11
Goldman Sachs Asset Management LP – ETF Asset Allocation Models ............................................. 11
Russell Investment Core Model Strategies and Tax-Managed Core Model Strategies ....................... 12
Vanguard Advisers, Inc. ETF Strategic Model Portfolios-CRSP ........................................................... 12
IMG Strategies ........................................................................................................................................ 12
Managed Core Equity Portfolio .......................................................................................................... 13
Managed Strategic Equity Portfolio .................................................................................................... 13
Dividend Income and Growth (DIG) Portfolio .................................................................................... 13
IMG Blended Strategies Portfolios ..................................................................................................... 13
Portfolios within the Arvest Wealth Management Unified Management Account (UMA) ................ 13
Trade Rotation Policies for IMG Equity, Balanced, Blended, and ETF Model Portfolios ........................ 14
IMG ETF Models ..................................................................................................................................... 14
IMG Tactical Blends ETF Models ......................................................................................................... 15
IMG Fixed Income Strategies .................................................................................................................. 15
IMG Managed Credit Fixed Income Portfolio and IMG Managed Short-Term Credit Fixed Income
Portfolio .............................................................................................................................................. 15
IMG Core Fixed Income Portfolio ....................................................................................................... 16
IMG Managed Municipal Bond Portfolio ............................................................................................ 17
Advisor Directed – Discretionary ............................................................................................................ 17
Advisor Directed – Non-Discretionary .................................................................................................... 18
Modification of Client Advisory Fee Schedules/Fees Negotiable ........................................................... 18
Billing ...................................................................................................................................................... 18
Program Changes .................................................................................................................................... 19
Termination of the Advisory Relationship .............................................................................................. 19
ERISA Accounts ....................................................................................................................................... 20
Other Fees and Additional Compensation ............................................................................................. 20
Cash Sweep Program .............................................................................................................................. 21
Margin Accounts ..................................................................................................................................... 21
Transactions Executed Away from Pershing .......................................................................................... 22
Account Requirements and Types of Clients .......................................................... 22
Account Requirements ........................................................................................................................... 22
Types of Clients ....................................................................................................................................... 22
Page 3 of 32
March 2026
Item 6
Portfolio Manager Selection and Evaluation .......................................................... 23
Item 7
Selection and Review of Portfolio Managers ......................................................................................... 23
Advisory Business ................................................................................................................................... 23
Performance-Based Fees and Side-by-Side Management ..................................................................... 23
Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 23
Voting Client Securities ........................................................................................................................... 29
Client Information Provided to Portfolio Managers ............................................... 29
Item 8
Information Provided to Affiliated Portfolio Managers ......................................................................... 29
Information Provided to Non-affiliated Portfolio Managers .................................................................. 30
Client Contact with Portfolio Managers ................................................................. 30
Item 9
Additional Information ......................................................................................... 30
Disciplinary Information ......................................................................................................................... 30
Financial Industry Activities and Affiliations........................................................................................... 30
Custody ................................................................................................................................................... 31
Code of Ethics ......................................................................................................................................... 31
Review of Accounts ................................................................................................................................ 32
Account Statements and Reports ........................................................................................................... 32
Client Referrals ....................................................................................................................................... 32
Financial Information ............................................................................................................................. 32
Business Continuity Plan ........................................................................................................................ 32
Page 4 of 32
March 2026
Item 4 Services, Fees and Compensation
Arvest Investments, Inc., doing business as Arvest Wealth Management (the “Firm”), is a corporation
organized under the laws of the State of Arkansas. The Firm is 100% owned by Arvest Bank, Fayetteville,
Arkansas. Arvest Bank is a wholly owned subsidiary of Arvest Bank Group, Inc., a corporation of which Jim
C. Walton and Samuel Robson Walton each own or control over 25% but less than 50% of the equity.
The Arvest mission statement: People helping people find financial solutions for life.
The Firm is an investment advisor registered with the Securities and Exchange Commission (SEC), with its
principal place of business located in Arkansas, with advisors located in Arvest Bank branches in Arkansas,
Oklahoma, Missouri, and Kansas. The Firm began conducting investment advisory business in 2004.
As of December 31, 2025, the Firm had regulatory advisory assets under management of
$3,439,741,668.35 of which we managed $997,487,385.05 on a discretionary basis.
The Firm provides investment advisory services through the Firm-sponsored wrap fee programs, as
further described in this Part 2A Appendix 1 of Form ADV wrap fee program brochure (the “Arvest Wealth
Management Wrap Fee Program Brochure”), and retirement plan consulting services, advice, and
financial planning services, as described in our Part 2A of Form ADV (Firm Brochure). The Firm Brochure
is provided separately to those applicable current and prospective clients.
The Firm sponsors and offers the following wrap fee programs, as described in this Brochure:
● Arvest Wealth Management SMA Equity and Balanced Strategies
● Arvest Wealth Management SMA Fixed Income Strategies
● Arvest Wealth Management Unified Managed Account
● BNY Mellon Advisors, Inc. (BNYA) AdvisorFlex Portfolios
● BNY Mellon Advisors, Inc. (BNYA) Target Risk Portfolios
● Mutual Funds & ETF Strategists
IMG Equity, Balanced, & Blended Strategies
●
IMG ETF Models
●
●
IMG Fixed Income Strategies
● Advisor Directed – Discretionary
● Advisor Directed – Non-Discretionary
Through personal discussions with the client in which the client’s goals and objectives are established, the
Firm’s investment advisor representatives, referred to as Client Advisors in this document, determine
which programs and underlying portfolios are suitable to the client’s circumstances. Clients generally can
request that reasonable restrictions be imposed on the types of investments to be held in their accounts.
These restrictions may include prohibitions with respect to the purchase or sale of particular securities or
types of securities. If, in its sole discretion, the Firm or the Portfolio Manager, believes that the restrictions
are unreasonable or inappropriate for the account, the Firm will notify the Client that, unless the
restrictions are removed, it may terminate the account. Clients will not be able to provide restrictions that
prohibit or restrict the investment advisor of a mutual fund or Exchange Traded Fund (ETF) with respect
to the purchase and sale of specific securities or types of securities within the mutual fund or ETF. Clients
retain individual ownership of all securities held in their wrap fee program accounts and can request to
receive trade confirmations and to vote proxies or, in certain cases where a portfolio manager accepts
proxy voting authority, to delegate proxy voting authority to the portfolio managers, as described in their
Firm advisory agreement and in this Brochure.
Page 5 of 32
March 2026
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client’s stated investment objectives, tolerance
for risk, liquidity needs and suitability.
To ensure that our initial determination of an appropriate program and/or portfolios remains suitable and
that the account continues to be managed in a manner consistent with the client’s financial circumstances
and goals, we will:
1. Send quarterly written reminders on client account statements requesting any updated information
regarding changes in the client’s investment objectives or risk tolerances,
2. At least annually, contact each participating client to determine whether there have been any changes
in the client’s financial situation or investment objectives, and whether the client wishes to impose
investment restrictions or modify existing restrictions,
3. Be reasonably available to consult with the client, and
4. Maintain client suitability information in each client’s file.
General Information Regarding the Wrap Fee Programs
A wrap fee program is an investment advisory program in which you pay one bundled annual fee (the
“Client Advisory Fee”) to compensate the Firm and Portfolio Managers (including the Firm, when your
Firm investment advisor representative (“Client Advisor”) or other Firm Portfolio Management and
Research investment advisor representatives are acting as portfolio managers) for their services and to
pay the brokerage transaction execution and custody and clearing costs associated with transactions in
the your wrap fee program advisory account. Except as disclosed under “Item 9 – Additional Information
– Custody,” with respect to client funds and securities of which we are deemed to have custody because
they were pledged to our parent company, Arvest Bank, as collateral for loans, the Firm does not have
custody of client funds and securities. All client funds and securities are held by a qualified custodian such
that the Firm does not have physical custody of any funds and securities. The Firm’s wrap fee program
accounts are held at Pershing LLC (“Pershing”), with the Firm acting as introducing broker pursuant to the
Firm’s fully disclosed clearing services agreement with Pershing. Pershing serves as custodian for the
accounts and provide execution and clearance of transactions. By entering into the Firm wrap fee
program advisory agreement and participating in a wrap fee program, client authorizes and directs the
Firm and the Portfolio Managers to trade through Pershing.
Pershing provides the Firm access to its technology platform, which includes: The Proposal System,
Proposal Output and Portfolio Analytics, initiation, and monitoring of new managed accounts, and the
Firm and Portfolio Manager level asset and account reporting. In addition, Pershing provides access to the
following operational services: support functions related to new account processing such as account
funding notifications, processing of trade confirmation delivery instructions and proxy notices, house-
holding for performance reporting and billing purposes, process account maintenance requests, billing
and payment services, daily reconciliation of accounts and production of quarterly and on-demand
performance reporting.
Through our agreement with BNY Mellon Advisors, Inc. (“BNYA”), an affiliate of Pershing and a SEC
registered investment adviser, BNYA provides access to individual account managers and investment
advisory and discretionary services to the Firm with respect to the programs. The Firm’s clients have
access to BNYA’s investment advisory platform through their participation in the programs, including, as
applicable, access to model providers and portfolio and asset managers reviewed and selected by BNYA
to participate in BNYA’s investment advisory platform and, ultimately, reviewed and selected by the Firm
to participate in the programs. BNYA is an independent third-party money manager that also acts as a
Page 6 of 32
March 2026
portfolio and/or overlay manager with respect to certain of the Firm-sponsored wrap fee programs (the
“BNYA Advised Programs”), as described below.
The applicable Client Advisory Fee depends in part on the program you have selected and is described
later in this Item 4. The Client Advisory Fee, including the annualized percentage agreed upon by you and
your client advisor, is also based upon the market value of all assets under management in an advisory
program account, including all balances in cash, money market funds, bank deposit programs, and
securities positions, but excluding margin debit balance (if applicable). There may, however, be additional
charges such as wire transfer fees or commissions for trades not executed through our clearing firm. The
Client Advisory Fee does not cover trades executed through broker-dealers other than Pershing. Please
refer to “Transactions Executed Away from Pershing” below regarding the reasoning and added costs and
fees you may incur when your Portfolio Manager elects to execute trades away from Pershing. Additional
information on the Client Advisory Fee is located later in Item 4 (pages 18 - 22) and in the Firm’s Wrap Fee
Program Advisory Agreement.
The Firm’s wrap fee program services may cost you more or less than purchasing similar services
separately, assuming the services could be purchased directly from the various providers thereof. Each
wrap fee program is available only for a Client Advisory Fee that is based upon a percentage of assets
under management. In evaluating a wrap fee program, clients should consider several factors. A client
may be able to obtain some or all the services available through a particular wrap fee program on an
“unbundled” basis through the Firm or through other firms and, depending on the circumstances, the
aggregate of any separately paid fees may be lower (or higher) than the single, all-inclusive fee charged
in the wrap fee program. Payment of an asset-based fee may produce accounting, bookkeeping or income
tax results that differ from those resulting from the separate payment of (i) securities commissions and
other execution costs on a trade-by-trade basis and (ii) advisory fees. Any securities or other assets used
to establish a wrap fee program account may be sold, and the client will be responsible for payment of
any taxes due. The Firm recommends that each client consult with his or her tax advisor or accountant
regarding the tax treatment of wrap fee program accounts.
Client advisory fees and net revenues vary across our programs. Additionally, advisor compensation is
based partly on production. This creates a conflict of interest because the firm may earn higher revenue
from certain programs.
Consequently, both the firm and its advisors have an incentive to recommend more expensive programs
even when lower-priced alternatives are available. Because advisor salaries and bonuses are tied to the
revenue generated by their accounts, we may be motivated to prioritize higher-cost options. The Firm’s
wrap fee program alternative investment portfolio solutions are limited. This presents a conflict of interest
by causing certain advisory clients to invest in higher-cost illiquid alternative investments through
brokerage accounts that may charge more in upfront commissions than would be paid in fees through
fee-based advisory accounts.
The Firm’s policies require all Client Advisors to only recommend those programs and services that are in
the best interest of each client. Furthermore, Client Advisors’ salaries, with exceptions for those with less
tenure at our Firm (consult your Client Advisor’s ADV 2B), are calculated and set semi-annually. For each
performance-based salary calculation, 6 months of prior production are used to determine application of
the Client Advisor’s performance to a payout grid used to set an Advisor’s salary level.
The table on the next page provides a comparison of the wrap fee programs sponsored by the Firm. Please
refer to the specific wrap fee program heading below for further information regarding the management
and costs of the program you are considering. Additional information regarding BNYA and each of the
other third-party portfolio managers and model providers referenced in the table can be found in their
Form ADV Part 2A. Additionally, periodic information regarding a portfolio manager or model provider
and its strategy will be available to the Firm’s Client Advisors to provide to clients upon request.
Page 7 of 32
March 2026
Page 8 of 32
March 2026
Arvest Wealth Management SMA Strategies
The Arvest Wealth Management SMA Strategies program provides the client with an opportunity to
access equity and fixed income strategies of select third-party portfolio managers on which the Firm,
utilizing research provided by BNYA and the portfolio managers’ disclosure documents, among other
items, conducts initial and ongoing research and due diligence. To be selected as a third-party portfolio
manager under this program, certain information must be readily available to support the Firm’s initial
and ongoing due diligence of the portfolio manager, and there must be sufficient economic efficiencies
including the amount of fees charged by the portfolio manager or the level of interest in the portfolio
manager on the part of the Firm clients. The portfolio managers have discretionary authority to invest,
reinvest, sell, or retain account assets under management by them.
SMA accounts are offered as Manager Traded and Model Delivery accounts. Model Delivery accounts are
traded by BNYA. Although there is not a difference in end fees to the Firm’s clients, the internal costs in
the Model Delivery SMA are lower to the firm resulting in more revenue to the Firm.
The annual Client Advisory Fee schedule for Arvest Wealth Management SMA Fixed Income Strategies is
on the chart on page 8.
Arvest Wealth Management Unified Managed Account (UMA)
UMA is a multi-discipline managed account product housed in a single account. with traditional and non-
traditional asset classes made available. The Firm is the sponsor, and BNYA serves as the overlay manager.
The Firm and BNYA work together to determine the default asset allocation percentages and allowable
bands for each model. BNYA and the Firm select the investments to be used for each style allocation, also
known as each sleeve, of the core models. Additionally, BNYA investment committee and the Firm
approves each investment vehicle available in the UMA. A sleeve can contain a third-party portfolio
manager’s equity model, an exchange traded fund, a mutual fund, or a combination of all three.
Additionally, a mutual fund model or ETF model provided by a third-party strategist (model creator) may
be used within the UMA. Equity third-party money managers, as well as mutual fund or ETF model
programs, transmit trade instructions to Pershing, on behalf of the Firm, for Pershing to execute on a
discretionary basis. Trading in Fixed Income portfolios is handled differently as third-party money
managers execute trading their individual portfolios within the UMA.
The Arvest Wealth Management UMA is flexible in that once the client has selected program available
investments, the portfolio manager is granted limited discretionary trading authority to include the
authority to allocate assets across the selected Models, Sleeve Managers, ETFs, mutual funds and other
securities; and to implement in its discretion Model changes received from Model Providers; and to
rebalance the account in accordance with target allocations and program trading parameters established
by our Firm. BNYA will allocate assets across the investment option(s) selected by the client for their UMA
account, in a manner consistent with our Firm’s instruction. The client retains final authority for the asset
allocation decisions and the selection of individual investment options to fill the selected asset allocation.
The annual Client Advisory Fee schedule for Arvest Wealth Management UMA is on the chart on page 8.
BNYA AdvisorFlex Portfolios
The Firm is the sponsor and BNYA acts as the portfolio manager for AdvisorFlex Portfolios, which is a
managed account program that includes three objectives-based strategies (Appreciation, Income and
Preservation), with multiple BNYA proprietary models within each strategy, as further described in BNYA’s
disclosure documents (BNYA ADV Part 2A). Client, with the assistance of Client’s Firm Client Advisor, is
responsible for selecting the appropriate model for the Client. For each investment selection within a
model, BNYA identifies several options from which Client may choose.
Page 9 of 32
March 2026
BNYA will implement certain updates and changes to the models and may replace one investment vehicle
with another and/or change the asset allocation of the model.
If a model does not perform according to expectations, BNYA may adjust the model.
The annual Client Advisory Fee schedule for BNYA AdvisorFlex Portfolios is on the chart on page 8.
BNYA Target Risk Portfolios
Target Risk Portfolios offers ten (10) diversified, discretionary investment models, including four (4) tax
aware models, that generally include allocations to traditional asset classes. Target Risk 20/80 is the most
conservative model, with the majority of the model allocated to fixed income and the balance to equities;
Target Risk US Equity 100/0 is the most aggressive model with an allocation focused on equities. For the
tax aware models, Target Risk Tax Aware 80/20 is the most aggressive model. The Firm is the sponsor of
the Firm Wrap Fee Program, and BNYA serves as the portfolio manager. As portfolio manager, BNYA
determines the asset allocation strategy and selects investment vehicles for each investment style
component of ten portfolios based on proprietary models. These models may consist of open- and closed-
end mutual funds, exchange traded funds and other securities, as determined by BNYA, in its sole
discretion. Tax aware models include municipal bond funds in the fixed income asset classes.
If a model does not perform according to expectations, BNYA may adjust the model.
Please consult BNYA disclosure documents (ADV Part 2A) for additional information regarding this
program. The annual Client Advisory Fee schedule for BNYA Target Risk Portfolios is on the chart on page
8.
Mutual Funds & ETF Strategists
The Mutual Funds & ETF Strategists Program is a model delivery program where the Firm, as program
sponsor, selects certain third-party investment advisors (referred to herein as the strategists or model
providers), made available under BNYA’s advisory platform, who provide model portfolios to BNYA for use
in the program. Individual portfolios or models are selected by the client, with the assistance and advice
of the Client Advisor. BNYA acts as the overlay portfolio manager to the program and manages client
accounts in its discretion based on the selected models, implementing model changes and rebalancing
client accounts pursuant to target allocations and program trading parameters. Model providers act as
nondiscretionary investment sub-advisers presenting model portfolios to BNYA for use in the program.
The annual Client Advisory Fee schedule for the model portfolios in Arvest Wealth Management’s Mutual
Funds & ETF Strategists Program is on the chart on page 8.
BlackRock Investment Management, LLC Target Allocation Portfolios
BlackRock Investment Management, LLC provides models to BNYA on a non-discretionary basis for use in
the program They offer 11 investment portfolios in each, Target Allocation, Target Allocation Tax Aware
and Target Allocation ESG, that generally include allocations of a blend of mutual fund and ETFs. BlackRock
Target Allocation ESG Models are core portfolios that extensively focus on companies that exhibit
environmental, social, and governance (ESG) characteristics. Target Allocation 0/100 is the most
conservative portfolio, with the majority of the portfolio allocated to fixed income and the balance to
equities; Target Allocation 100/0 is the most aggressive portfolio with an allocation focused on equities.
These portfolios seek to provide a range of risk and return levels by diversifying across various asset classes
and a wide variety of factors that can impact investments, such as asset interest rates, credit spreads and
foreign exchange.
Additionally, for investors with longer term investment time frames there are 5 Long Horizon allocation
models available.
Page 10 of 32
March 2026
Calvert – Responsible Allocation Models
The Calvert-Responsible Allocation Models are mutual fund allocation advisory model portfolios. The
Calvert Research and Management (CRM) Asset Allocation Team is responsible for management and
oversight of the models. This includes implementing strategic asset allocation decisions, evaluating the
effectiveness of their decisions, and monitoring the underlying fund options.
The Calvert-Responsible Allocation Models seek to achieve their investment objectives by investing
primarily in a portfolio of underlying Calvert fixed-income and equity funds that meet the models’
investment guidelines. Each of the underlying Calvert mutual funds utilizes both financial and responsible
investment analysis.
The models currently available under the program are Calvert Responsible Conservative Model, Calvert
Responsible Moderate Model, Calvert Responsible Growth Model
Capital Research and Management Company
The Capital Research and Management Company manages twelve (12) models. These models provide
client access to investment strategists who construct distinct portfolio solutions to help meet their
demands. These models are typically comprised of actively managed mutual funds and/or exchange-
traded funds (ETFs).
Portfolio Solutions Committee and Capital Solutions Group regularly monitor the portfolios for risks and
ensure alignment with their long-term portfolio objectives, while underlying fund managers utilize
company—and security-specific research to make real-time decisions and find opportunities.
The models currently available under the program are: American Funds Conservative Growth & Income
MP, American Funds Conservative Income & Growth MP, American Funds Conservative Income MP,
American Funds Global Growth MP, American Funds Growth & Income MP, American Funds Growth MP,
American Funds Moderate Growth & Income MP, American Funds Moderate Growth MP, American Funds
Preservation MP, American Funds Retire Income MP Conservative, American Funds Retire Income MP
Enhance, and American Funds Retire Income MP Moderate.
First Trust ETF Model Portfolios
The First Trust ETF Model Portfolios are created by the First Trust Advisors Model Investment Committee
and consist of ETFs. These models are aimed at total return while diversifying the risk exposure of various
asset classes over the long term.
The models currently available under the program are: First Trust Conservative, First Trust Conservative
Growth, First Trust Balanced Growth, First Trust Moderate Growth, First Trust Aggressive Growth.
Goldman Sachs Asset Management LP – ETF Asset Allocation Models
The eight (8) models are created by Goldman Sachs Asset Management (GSAM) multi-asset class
investment team, which analyzes the economic cycle and incorporates asset class views in seeking to
position the portfolios for the current economic environment. The team uses quantitative and qualitative
techniques like macro valuations, stress tests and scenario analysis in identifying and reacting to cyclical
changes in economies.
The GSAM Asset Allocation ETF Models are available in several asset allocation combinations ranging from
20% bond exposure to 90% stock exposure with models representing 10% incremental changes in
between.
Page 11 of 32
March 2026
Russell Investment Core Model Strategies and Tax-Managed Core Model Strategies
Russell Investment Management, LLC provides models on a non-discretionary basis to BNYA for use in the
program. These model strategies are designed to optimize asset allocation strategies based on various
investment principles.
This Russell model portfolio strategy currently provides core, and tax-managed, and active-passive
models. These models offer clients an opportunity to select from varied asset allocations and investment
styles to address a variety of investment objectives. The core model strategies’ corresponding tax-
managed versions are designed to maximize after-tax return for a client’s taxable dollars. These tax-
managed models may be appropriate for clients desiring a more tax sensitive approach for their non-
qualified accounts.
Vanguard Advisers, Inc. ETF Strategic Model Portfolios-CRSP
Vanguard Advisers, Inc. (“VAI”) provides ETF models on a non-discretionary basis to BNYA for use in the
program. These strategic model portfolios are created and maintained by VAI’s Investment Strategy Group
and reflect VAI’s belief in a top-down approach stressing asset allocation, broad diversification, and low
costs. Their model portfolio construction includes exposure to U.S and international equities as well as
domestic and international fixed income securities. The VAI model portfolios also strive to maintain
internal expense ratios that are lower than industry averages.
The ETF Strategic Model Portfolios are available in several asset allocation combinations ranging from
100% bond exposure to 100% stock exposure with models representing 20% incremental changes in
between.
IMG Strategies
IMG portfolios include several managed strategies that are managed by investment advisory portfolio
managers from AWM’s Portfolio Management and Research (PMR).
Our Equity investment philosophy is built around four key characteristics:
• Quality – PMR considers quality securities to be those of established entities with proven track
records.
• Value – PMR considers securities where it believes the security is attractively priced relative to
•
our analysis of future prospects.
Long Term Approach – PMR is not a short-term market timer. The goal is to construct portfolios
that will perform favorably over the long haul.
• Diversification – Portfolios will be well diversified by both issuer and industry. PMR believes that
this is a crucial element of risk management.
We are value-oriented and focused on consistent, long-term performance. In order to accomplish these
objectives, we combine traditional analysis with systematic research to create a fundamental factor rating
for stocks based on their single factor score in the areas of:
• Value (stocks undervalued by the market)
• Quality (well-managed financially healthy companies)
•
Low-Volatility (stable and predictable companies)
• Momentum (strong recent performance, correlates with themes)
The process leverages many points of fundamental data, supplemented by sentiment and price
information, to construct proprietary metrics, which are evaluated to provide comprehensive
understanding of company and factor trends.
Page 12 of 32
March 2026
Rather than attempting to “time” short term market swings, we seek to identify high-quality stocks that
possess long term value. Our ultimate goal is to provide actively managed portfolios of stocks with
identifiable investment opportunities at risk levels below the overall market.
The annual Client Advisory Fee schedule for the IMG Equity and Balanced Portfolios is on the chart on
page 8.
Managed Core Equity Portfolio
The IMG Managed Core Equity Portfolio invests most of its assets in equity securities of companies that
are Large-Cap (market capitalization > $10 billion), with an emphasis on domestic U.S. corporations.
Managed Strategic Equity Portfolio
The IMG Managed Strategic Equity Portfolio invests in equity securities of companies across multiple
market capitalizations and geographic locales.
Dividend Income and Growth (DIG) Portfolio
The IMG DIG Portfolio is constructed of a broadly diversified selection of dividend-paying equity securities
across multiple market capitalizations and sectors in the US, though some American Depository Receipts
(ADRs) may be included. The Portfolio will invest in approximately 25 – 35 securities that will typically
have both an attractive current yield and the likelihood to consistently raise dividends.
In the above Portfolios, certain equity sub-classes (i.e., International, Emerging Markets, Mid-Cap, Small-
Cap) may be utilized from time to time using mutual funds and/or ETFs. In addition, from time to time, a
portion of the portfolio may be held in money market funds.
IMG Blended Strategies Portfolios
IMG Blended Strategies Portfolios are managed by investment advisory portfolio managers from the
Firm's PMR. The portfolios consist of allocations to an IMG Dividend Income and Growth (DIG), Core
Equity, or Strategic Equity Managed Portfolio combined with securities that are allocated to one of ten
IMG Strategic ETF (Exchange Traded Funds) Models. Also, managed fixed income portfolios (e.g., IMG
Managed Credit Fixed Income, Managed Short-Term Credit Fixed Income, Core Fixed Income, and
Managed Municipal Bond) may be blended with securities of one of the IMG Strategic ETF portfolios.
Finally, securities of a managed equity portfolio may be blended with securities of a managed fixed income
portfolio.
The combinations of managed portfolios and ETF models are selected by the client in various percentages
made available by the Firm. The minimum account values for these blended strategies portfolios vary
between $50,000 to $2,000,000. Please consult with your Client Advisor regarding the minimum
investment and account values of the portfolio prior to investing.
Portfolios within the Arvest Wealth Management Unified Management Account (UMA)
Certain IMG ETF Model Portfolios, IMG Equity Portfolios and IMG Balanced Portfolios are also available
for investment within our Firm’s UMA. Clients and potential clients investing in these portfolios should
be aware of differences in the way securities transactions are completed for the UMA portfolios versus
our IMG Separately Managed Account (SMA) portfolios.
UMA portfolios’ security transactions are completed through a model delivery process, where the
applicable managers from our Firm’s PMR relay portfolio model composition to BNYA, who provides
limited discretionary portfolio manager overlay services in executing the corresponding portfolio model
trades.
The differences in processes for UMA and SMAs’ trade executions means that trades necessary to incept
advisory portfolios or to execute desired investment changes may take place at different times.
Page 13 of 32
March 2026
Additionally, BNYA, as described in their disclosure documents, has a Trade Rotation Policy which allocates
the distribution of model updates across multiple programs and model providers. This means in some
cases BNYA may not execute model delivered trades until after our Firm has executed trades in the SMA,
or other non-UMA portfolios we manage on a discretionary basis.
Trade Rotation Policies for IMG Equity, Balanced, Blended, and ETF Model Portfolios
Our Firm’s PMR utilizes trade-rotation policies which are intended to allocate transactions equitably over
time across our client base, subject to extenuating circumstances and to trading directions imposed by
clients. The effectiveness of these policies can depend on market factors such as the liquidity of the
securities being traded and the size of the transactions. In order to process trades for different client types
and platforms, our firm maintains two trading groups: one executes trades for Arvest Bank Trust trading
relationships, and another executes trades for Arvest Wealth Management Advisory trading relationships
(generally wrap-fee accounts where Arvest portfolio managers have discretion). This could cause certain
accounts to pay more or receive less for a security than other accounts. When necessary, the two groups
use reasonable efforts to coordinate so that clients receive fair and best execution, which may include
rotating initial trading between the two groups, or creating a “step out trade,” where an Arvest Bank Trust
order will be aggregated with an Arvest Wealth Management Advisory order for execution. In addition,
we offer advisory services through UMA model delivery platforms, where allocation decisions made by
our Portfolio Managers are communicated via the overlay manager's technology provider. Clients utilizing
a UMA model delivery platform will have transactions effected at the overlay manager's discretion. In
order to ensure fair practice across discretionary trading platforms or UMA model delivery platforms, our
firm generally initiates random trade rotation across applicable platforms. Where a platform falls in the
rotation could favorably or adversely affect a client’s executions relative to other clients; however, the
random nature of trade rotation is intended in the long run to provide fair placement and execution to all
discretionary trading platforms and UMA model delivery platforms. Circumstances may cause a particular
platform to be unable to receive trade instructions or model holdings; in such cases, we cause trades to
be executed for the next platforms in rotation until the issue is resolved; and as a result, those unable to
receive trade instructions or model holdings will receive different, and perhaps less favorable, prices for
their transactions then they would have received had the platform received those instructions or model
holdings in the original trade rotation. We may utilize rotations or allocation methods other than those
described above if we believe such rotation or method is appropriate under the circumstances and that
such alternative rotation or method is generally fair and equitable. We reserve the right to vary from these
policies to comply with additional requirements that may be placed on us by our platforms,
intermediaries, and clients, including but not limited to timing of trades and broker selection.
Notwithstanding these policies, one group of clients may have transactions effected before or after
another group of clients. We reserve the right to change these policies at our discretion.
IMG ETF Models
IMG Strategic ETF and IMG Real Assets Portfolio Models are managed by investment advisory portfolio
managers from the Firm’s PMR.
IMG Strategic ETF Models provide diversified portfolio solutions to meet defined risk tolerance objectives.
Each model is designed around a targeted strategic asset allocation. The following asset classes can be
included in the models: cash and cash alternatives, fixed income, alternative income, commodities,
currency, domestic and international equity securities. The strategic asset allocation targets provide the
long-term strategic guidelines. However, the models may be adjusted over time based on new research,
analysis, or market developments.
IMG Real Assets Portfolio seeks to achieve attractive long-term total returns, while maximizing real
returns during inflationary environments. The strategy invests in a diversified portfolio of funds in Real
Assets, including real estate companies, commodities, natural resource companies, global infrastructure
companies, precious metals, and other permitted investments which could include mutual funds. The
Page 14 of 32
March 2026
strategy seeks to generate alpha from both top-down tactical asset allocation and bottom-up sector and
security selection.
IMG Tactical Blends ETF Models
IMG Tactical Blends ETF Models are managed by investment advisory portfolio managers from the Firm's
PMR. The model consists of allocations to a Strategic ETF Portfolio and to an absolute return strategy
through a tactically managed ETF(s) or mutual fund(s). IMG utilizes a proprietary-research and scoring
process to select the tactically managed mutual fund(s) and/or ETF(s). Clients may choose from various
percentages of the ETF Model and tactical component made available by the Firm.
This strategy is focused on mitigating large losses during the pronounced declines in the equity market
and participating in as much of the gains as possible when the markets are rising. The tactical
ETF(s)/fund(s) use various proprietary indicators to determine if funds should be invested in risk assets or,
when defensively positioned, cash equivalents and/or fixed income.
The tactical blends models may underperform during choppy markets that lack leadership or when
leadership changes in the market. Additionally, the strategy may not participate fully in rising market
environments.
The following asset classes may be included in the tactical portion of the model: cash and cash
alternatives, fixed income, commodities, real assets, domestic and international equity securities, and
derivatives.
The annual Client Advisory Fee schedule for the IMG ETF Models is as follows on the chart on page 8
IMG Fixed Income Strategies
Our goal with all our IMG Fixed Strategies, which are managed fixed income portfolios, is to maximize the
cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall
investment-grade credit quality.
PMR Fixed Income investment advisory portfolio managers will make all reasonable efforts to invest client
funds as soon as practicable, and generally no more than sixty days from receipt of client funds into the
account. Full investment of accounts in the Managed Municipal Bond Portfolio is generally delayed,
usually up to six months (if account is allocated to only bonds issued from state of residence, investment
time could be delayed up to twelve months), due to the desirability of purchasing bonds at new issuance
and the irregular schedule of acceptable new issues.
The annual Client Advisory Fee schedule for the IMG Fixed Income Portfolio Models is on the chart on
page 8:
IMG Managed Credit Fixed Income Portfolio and IMG Managed Short-Term Credit Fixed Income Portfolio
The IMG Managed Credit Fixed Income Portfolio is a 100% fixed income portfolio, consisting primarily of
a mix of investment-grade corporate, taxable municipal and securitized bonds and is managed by portfolio
managers from the Firm’s PMR. A high yield ETF or mutual fund may be utilized from time to time in order
to enhance returns. The portfolio goal is to maximize the cash yield (primarily) and total return
(secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. The
following guidelines and constraints apply to each portfolio:
• All individual corporate bonds must be rated at least Baa3 or BBB- by one of the three major credit
ratings agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase.
• All individual municipal bonds must be rated at least Baa1 or BBB+ by one of the major rating
•
agencies (S&P, Moody’s, and Fitch) at the time of purchase.
In the event an issuer’s rating (for a corporate or municipal security) falls below investment-grade
by all three rating agencies, the security must be liquidated or reported to the IMG Investment
Page 15 of 32
March 2026
Committee at the next scheduled meeting. Note that the Committee may approve the issuer for
retention or authorize a timeline or price target for liquidation.
• Securitized bonds must be rated Aaa or AAA by one of the three major credit ratings agencies at
the time of purchase. Additionally, commercial mortgage-backed, asset backed and collateralized
loan obligation mutual funds or ETFs may be used, provided the funds/ETFs have been approved
for use in other IMG products.
• 12.5% maximum concentration of the portfolio’s value in the securities of any single corporate
issuer (at market value).
• Up to 10% of the portfolio’s value may be invested in a high-yield mutual fund(s) or ETF(s).
• Target portfolio duration of 7 years or less for the Credit Fixed Income Portfolio Target maximum
portfolio duration of 4 years or less for the Short-Term Credit Fixed Income Portfolio.
• Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide
leverage.
IMG Core Fixed Income Portfolio
The IMG Core Fixed Income Portfolio, formerly known as the IMG Managed Diversified Bond Portfolio, is
a 100% fixed income portfolio, consisting primarily of a mix of short-term, intermediate-term and long-
term bonds and will be broadly diversified among various fixed income sectors, including (but not limited
to): U.S. treasury securities, U.S. agency securities, residential mortgage-backed securities and
collateralized mortgage obligations, investment-grade corporate bonds, taxable municipal securities,
commercial mortgage-backed securities, and asset-backed securities. A high-yield ETF or mutual fund may
also be utilized from time to time in order to enhance returns. Portfolios will be managed by Portfolio
Managers from the Firm’s PMR. The portfolio goal is to maximize the cash yield (primarily) and total return
(secondarily) of each account, consistent with maintaining an overall investment-grade credit quality.
The Firm undertook an action to better streamline the process of auditing, identifying, and stratifying
managed strategies. As a result, the PMR elected to change the name of IMG Managed Diversified Bond
to IMG Core Fixed Income to better align with this initiative. No material changes to the management of
this portfolio were initiated. Only the name was changed, which will ensure that strategies are referred
to by consistent nomenclature internally across the platforms where the Firm’s PMR manages clients’ and
the Firm’s funds. Additionally, the streamline process changes will support assets under management
(AUM) calculations being conducted in a consistent manner. The primary benchmark for portfolios
managed in this strategy will be the Bloomberg U.S. Aggregate Bond Index. The following guidelines and
constraints apply to each portfolio:
• All corporate bonds must be rated at least Baa3 or BBB- by one of the three major credit ratings
agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase.
• All individual municipal bonds must be rated at least Baa1 or BBB+ by one of the major rating
agencies (S&P, Moody’s, and Fitch) at the time of purchase.
• No more than 30% of the portfolio’s value may be invested in bonds rated below A3 or A- (by all
•
three rating agencies) at the time of purchase.
In the event an issuer’s rating (for a corporate or municipal security) falls below investment-grade
by all three rating agencies, the security must be liquidated or reported to the IMG Investment
Committee at the next scheduled meeting. Note that the Committee may approve the issuer for
retention or authorize a timeline or price target for liquidation.
• Securitized bonds must be rated Aaa or AAA by one of the three major credit ratings agencies at
the time of purchase. Additionally, commercial mortgage-backed, asset backed and collateralized
loan obligations mutual funds or ETFs may be used, provided the funds/ETFs have been approved
for use in other IMG products.
• 10% maximum concentration of the portfolio’s value in the securities of any single corporate
issuer (at market value).
Page 16 of 32
March 2026
• Up to 10% of the portfolio’s value may be invested in a high-yield mutual fund(s) or ETF(s).
• Portfolio duration range of 2 to 9 years.
• Minimum average portfolio rating of A1 or A+.
• Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide
leverage.
IMG Managed Municipal Bond Portfolio
The IMG Managed Municipal Bond Portfolio is a 100% fixed income portfolio and will be invested
predominantly in securities which produce income that is exempt from federal income taxes (except
under extraordinary circumstances). In circumstances when the after-tax yield for treasury or agency debt
is determined by the manager to be advantageous versus a tax exempt yield, the manager may purchase
treasury or agency securities in lieu of tax exempt municipal bonds. The portfolio managers may also place
a heavier emphasis on bonds issued within the client’s state of residence. Portfolios will be managed by
portfolio managers from the Firm’s PMR. The portfolio goal is to maximize the after-tax cash yield
(primarily) and total return (secondarily) of each account, consistent with maintaining an overall
investment-grade credit quality. The following guidelines and constraints apply to each portfolio:
• All municipal bonds must be rated at least Baa2 or BBB by one of the three major credit ratings
•
agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase.
In the event an issuer’s rating falls below investment-grade, or is withdrawn, by all three rating
agencies, the security must be liquidated or reported to the IMG Investment Committee at the
next scheduled meeting. The Committee may approve the issuer for retention or authorize a
timeline or price target for liquidation.
• 17.5% maximum concentration of the portfolio’s value in the securities of any single issuer (at
market value) and a 10% maximum value concentration to be allocated to a specific portfolio
holding.
• Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide
leverage.
Clients are encouraged to consult a tax advisor to determine if municipal bonds are an appropriate
investment prior to investing in this strategy.
Advisor Directed – Discretionary
The Advisor Directed-Discretionary Program is a wrap fee program designed to provide discretionary
investment advice through your Client Advisor acting as a portfolio manager for a fee, based on the value
of your assets in the program. Acting under the Firm advisory agreement and once your account is
established at Pershing, your Client Advisor will manage your account on a discretionary basis. BNYA has
no discretion over assets managed in the Advisor Directed-Discretionary Program and is not providing
investment advisory services to you.
When you begin the program, your Client Advisor uses your investment profile to create a congruent
asset allocation with select portfolio securities. In some cases, your Client Advisor may select an existing
Client Advisor-developed portfolio strategy that is also used for other clients with similar investment
profiles as yours. Currently the list of approved investments for the Advisor Directed-Discretionary
Program includes mutual funds, exchanged traded funds (“ETFs”), options (limited to covered calls and
purchases), fee-based unit investment trusts (“UITs”), equities, bonds, and other securities. Additionally,
alternative, or complex investments may be included. Examples of these alternative or complex
investments include alternative mutual funds, buffered UITs, and leveraged ETFs. Descriptions of these
alternative investments and risks associated with them may be found in Item 6 under “Investment
Strategies” and “Risk of Loss” within this Wrap Fee Program Disclosure.
our Client Advisor has full discretion over the selection and number of investments to be purchased or
sold in the account, without obtaining your prior consent or approval. Once a portfolio is constructed,
your Client Advisor monitors the account and rebalances the portfolio as changes in market conditions
and client circumstances warrant.
Page 17 of 32
March 2026
The annual Client Advisory Fee schedule for Advisor Directed – Discretionary is on the chart on page 8.
Advisor Directed – Non-Discretionary
The Advisor Directed-Non-Discretionary Program is a wrap fee program it is also an “advisor as portfolio
manager” program, designed to provide investment advice through your Client Advisor for a fee based on
the value of your assets in the program. Acting under the Firm advisory agreement, and once your Client
Advisor establishes an account is established at Pershing, for the purpose of creating a portfolio to be
managed by your Client Advisor will manage your account on a non-discretionary basis, meaning that you
remain ultimately responsible for selecting the investments for, and approving transactions in, the
account. BNYA has no discretion over assets managed in the Advisor Directed-Non Discretionary Program
and is not providing investment advisory services to you.
Because the account is not discretionary, your Client Advisor will provide you with investment advice, but
you will retain full judgment over the selection and amount of investments to be purchased or sold in the
account. Once a portfolio is constructed, your Client Advisor monitors the account and will provide you
with advice and recommendations regarding rebalancing the portfolio as changes in market conditions
and client circumstances warrant, but Client Advisor will not have the authority to enter into any
transactions without obtaining your prior consent or approval.
The annual Client Advisory Fee schedule for Advisor Directed – Non-Discretionary is on the chart on page
8.
Modification of Client Advisory Fee Schedules/Fees Negotiable
The Firm reserves the right, in its sole discretion, to negotiate or modify the Client Advisory Fee schedules
for any client due to a variety of factors, including but not limited to the level of reporting and
administrative operations required to service an account, the investment strategy or style, the number of
portfolios or accounts involved, assets to be placed under management and/or the number and types of
services provided to the client. Because the Firm’s fees are negotiable, the actual fee paid by any client or
group of clients may be different from the fees reflected in Firm’s Client Advisory Fee schedules. The
specific Client Advisory Fee schedule for a client will be identified in the Firm advisory agreement with
each client.
Billing
The Client Advisory Fee is charged quarterly in advance and is calculated using the market value of all
assets under management in an advisory program account, including all balances in cash, money market
funds, bank deposit programs, and securities positions, but excluding margin debit balance (if applicable).
The Client Advisory Fee is calculated as of the last business day of the previous quarter by our custodian
or BNYA and is due on the first business day of each calendar quarter. This last business day of the previous
quarter valuation includes the values of any assets sold but not yet settled but does not include the values
of any assets purchased but not yet settled. The initial Client Advisory Fee is based upon the market value
of all assets under management in the account at inception is due in full on the date the account is
accepted by the Firm and the custodian. For the period from inception date through the last business day
of the then current full calendar quarter, the initial Client Advisory Fee is pro-rated accordingly. Our
clearing firm debits your account for the fees charged by the Firm, BNYA, Pershing, and portfolio managers
and model providers, as applicable, and remits the fees to the respective parties accordingly.
Additions and Withdrawals: Clients, with Firm Wrap Fee Program accounts, may make additions to the
account at any time. Additions may be in cash and securities, subject to the requirements of the program
and portfolios selected and the ability of the Firm or the portfolio manager to decline to accept particular
securities. A client may withdraw assets from the account upon request. Written request or written
confirmation from the client may be required for certain withdrawals, including, when following the
withdrawal of assets from the account would be below the program’s minimum account value
Page 18 of 32
March 2026
requirements, in connection with certain account terminations, or in certain other circumstances as the
Firm may determine in its sole discretion. The Client acknowledges that any withdrawals from the account
will be subject to, and the client shall allow time for, the usual and customary securities trading and
settlement procedures, and processes relating to the transfer of funds electronically or via physical check
(generally 2 - 5 business days not counting actual mailing time for a check). A request to add or withdraw
from the account should not be considered a “market order” because the corresponding security trades
may take multiple days to execute.
Adjustments to the Client Advisory Fees related to additions and withdrawals are made quarterly (for the
prior quarter) when net flows reach a cumulative threshold of $5,000. The adjustments will be prorated
based upon the dates of the additions and/or withdrawals.
Please refer to your Firm advisory agreement for specific information concerning your Client Advisory Fee
and for additional information regarding our billing practices.
Program Changes
Clients may change their existing program within the Firm’s Wrap Fee Program either through executing
a new advisory agreement, or in certain instances, through completion and submission of the “Change A
Manager And/Or Style” form without executing a new advisory agreement.
The Firm, in processing a program change for any account, will refund any prepaid, unearned fees on the
program being terminated. In calculating a client’s reimbursement of fees, we will prorate the
reimbursement according to the number of days remaining in the billing period. Additionally, the Firm will
treat the billing on the new advisory program in similar fashion to how we would treat a new advisory
account inception i.e. The initial Client Advisory Fee for the new program is based upon the market value
of all assets under management in the account at new program’s inception and is due in full on the date
the account is accepted by the Firm and the custodian - for the period from the new program’s inception
date through the last business day of the then current full calendar quarter, the initial Client Advisory Fee
for the new program is prorated accordingly.
Termination of the Advisory Relationship
Client may terminate his or her Firm advisory agreement, without penalty, within five business days of
signing, and receive a full refund of all Client Advisor Fees paid by the client. Following the initial five
business day period, the Firm advisory agreement may be terminated by either party upon request to the
other party. Upon termination of the Firm advisory agreement, the Firm or the custodian will make a pro-
rata refund to the client of the Client Advisory Fee paid to the Firm pursuant to this Agreement for the
period after the effective date of termination through the end of the current Client Advisory Fee billing
period. Termination will not, affect obligations of the client arising from transactions initiated, prior to
such termination. The client may incur additional charges or fees in connection with transfers of securities
or cash following termination of advisory status. Upon termination of any account, any prepaid, unearned
fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will prorate the
reimbursement according to the number of days remaining in the billing period.
Additionally, the Firm may terminate the advisory status of a client’s account that falls below the minimum
balance requirements of the advisory portfolio they are invested in. Our Firm’s Investment Advisor
Representatives (IARs) will attempt to contact clients with below minimum investment balances to discuss
alternatives such as adding funds to the portfolio, repositioning to advisory portfolios with lower
minimum balance requirements (as applicable), movement of security positions in kind to brokerage
account status, or liquidating account security positions. The Firm may terminate an account’s advisory
status when its associates attempted but were unable to contact these impacted clients. The securities
will be maintained “in kind” in these instances until further direction is received from the client.
Page 19 of 32
March 2026
Similar to additions and withdrawals requests, the client shall allow time for the trading and settlement
procedures, and processes relating to the transfer of funds electronically or via physical check (generally
2 - 5 business days not counting actual mailing time for a check). A request to add or withdraw from the
account should not be considered a “market order” because the corresponding security trades may take
multiple days to execute.
ERISA Accounts
The Firm is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual
retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”). As
such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that
include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in
prohibited transactions, the Firm may only charge reasonable fees for investment advice. Additionally,
our firm and/or our related persons do not receive any commissions or 12b-1 fees in an advisory ERISA
account. Should the Firm or our related persons receive a commission or 12b-1 fee payment in a Firm
advisory ERISA account, these fees will be rebated back to the client’s account.
Other Fees and Additional Compensation
There may be other costs assessed which are not included in the Client Advisory Fee, such as fees, expenses
and charges levied by mutual funds, ETFs, American Depositary Receipts (ADRs) and money market funds.
In addition, there are other fees charged by the custodian, as applicable, that are not included in your Client
Advisory Fee, such as costs associated with the purchase and sale of certain mutual funds and other similar
securities held in your account, exchange or auction fees, transfer taxes, costs for transactions executed
other than at the custodian, any fees imposed by the SEC, electronic fund and wire transfer fees, security
reorganizations, voluntary and mandatory corporate actions, fees for client-initiated transfers, costs
associated with investment of your funds in cash sweep funds, annual custodial fees for Simplified
Employee Pension (SEP), Simple IRAs, other retirement accounts (excluding only Traditional and Roth IRAs)
and termination fees for all IRA and retirement accounts and other charges mandated by law. Account and
service fees such as the annual IRA custodial fees for SEP and Simple IRAs and IRA account termination fees
are charged in amounts that exceed the costs incurred by the Firm. This reflects a voluntary markup that
the Firm receives on these fees and charges. Please refer to the Firm’s current “Schedule of Miscellaneous
Account & Service Fees” available at our disclosures web page www.arvest.com/documents-and-
resources/awm-disclosures or reach out to your Client Advisor should you have any questions relating to
these charges.
The Firm diligently attempts to ensure that, when exercising discretionary authority, portfolio managers
invest client advisory wrap fee program account assets in a mutual fund’s most cost efficient share class
available. To avoid having client returns reduced by distribution (and/or shareholder services) 12b-1 fees
and lower overall investment costs for our clients, should 12b-1 fees be received by the Firm with respect
to a client advisory wrap fee program account, these fees will be rebated to the client or their account.
A client could invest in a mutual fund directly, without our services. In that case, the client would not
receive the services provided by our firm which are designed, among other things, to assist the client in
determining which mutual fund or funds are most appropriate to each client’s financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services
being provided.
Various vendors, product providers, distributors and others have provided and may, in the future provide,
compensation by paying some expenses related to the following activities: training and education to
include the Firm’s training and recognition events. Also, certain vendors have, and may in the future,
provide marketing support (example seminars), invite us to participate in conferences, or on-line training
that may further Investment Advisor Representatives' and employees' skills and knowledge. Also, some
Page 20 of 32
March 2026
have and occasionally provide us with gifts, meals and entertainment of reasonable value consistent with
industry rules and regulations.
In addition to various product provider arrangements, our firm receives payments from certain product
providers through preferred provider relationships. These companies are selected based on several
factors, including product breadth, financial stability, and service support. In exchange for being
designated as a preferred provider, these companies pay us additional revenue-sharing fees. The
existence of these preferred arrangements creates a conflict of interest, as there is a financial incentive
for our firm to make available a preferred provider over a non-preferred one. However, our financial
professionals are required to act in a fiduciary capacity and must provide recommendations based on your
specific needs in your best interest, regardless of the provider’s preferred status. These revenue-sharing
payments are paid from the provider's own assets and are not charged to the Firm’s clients.
Under the Firm’s clearing agreement with Pershing, Pershing has made available to the Firm certain
incentives, such as credits to cover implementation, technology, and strategic plan support costs and an
annual cash incentive based upon the net annual growth in assets we introduce to our clearing firm,
exclusive of market value changes. These incentives, if received, will not be credited against, and will not
reduce, the Client Advisory Fees or other amounts a client owes to the Firm. Although these incentives, if
received, may be considered compensation to the Firm, they will not be applied towards our Client
Advisors’ production in connection with the determination of their production-based salaries.
Additionally, under the Firm’s clearing agreement with Pershing, the Firm is subject to a significant
termination fee if the clearing agreement is terminated prior to the eight-year agreement term. Although
this termination clause does not represent current revenue to our firm, it does create a financial incentive
for the Firm to maintain our clearing agreement with Pershing, even if it is not in the best interest of
advisory clients to do so.
Cash Sweep Program
The Firm offers an automatic cash sweep program where uninvested cash balances in eligible client
accounts held with Pershing will be invested in the default option which currently is a money market fund
(subject to certain limitations and restrictions, including with respect to minimum sweep balances and
advisory account type) More information on these options is described in our Cash Sweep Disclosure
document, available at www.arvest.com/documents-and-resources/awm-disclosures. The Firm’s
agreement with Pershing provides that Pershing will compensate the Firm based on the balances of client
accounts held in such sweep accounts. The amount of compensation varies between the various cash
sweep alternatives. The salaries and bonus opportunities of Client Advisors are based in part on
production, i.e., the amount of net Client Advisory fee revenues and other revenues, generated to the
Firm by their advisory client accounts. Consequently, the possibility of this compensation creates an
incentive for the Firm, or its Client Advisors, to make decisions for the account which would have the
effect of increasing this compensation. Such compensation or payments are not credited against, and will
not reduce, the Client Advisory Fees or other amounts a client owes to the Firm. The Firm does not receive
any fees or compensation from the sweep vehicle(s) designated for IRA and ERISA accounts. Please refer
to our Cash Sweep Disclosure document for additional information about our Cash Sweep program,
including information regarding the share of cash sweep revenues we receive on each of the available
cash sweep vehicles, or reach out to your Client Advisor should you have any questions.
BNYA Advised Program accounts will have their cash sweeps determined by BNY Mellon Advisors, Inc.
Information in this regard may be found in BNYA’s disclosure documents, which are provided to clients in
those programs. The Firm and its Client Advisors do not receive any cash sweep compensation with
respect to those BNYA Advised Programs.
Margin Accounts
Under the Firm’s clearing agreement with Pershing, if a client obtains a margin loan from Pershing, the
Firm will receive a share of the margin interest generated on debit balances in the client’s margin account.
Page 21 of 32
March 2026
The Firm establishes the interest rate schedule that determines the interest charges to your account. The
amounts charged include a markup of the rates that Pershing charges the Firm for margin financing. As
the Firm earns additional compensation when you have a margin balance, this creates an incentive for
our firm to establish the interest rate schedule at a level that is financially advantageous for our firm.
Additionally, the Firm’s receipt of interest revenue creates a financial incentive for our firm to propose
strategies using margin that may not be in a client’s best interest.
The Firm’s Client Advisors are not compensated on margin interest revenue generated to the Firm by their
assigned client accounts.
Transactions Executed Away from Pershing
Implementation and execution of transactions in the wrap fee programs are conducted by the Firm as an
introducing firm on a fully disclosed basis through its clearing firm, Pershing, LLC. However, portfolio
managers associated with the wrap fee programs have the option of executing transactions away from
Pershing if they believe it is in the client’s best interests to do so. This is frequently referred to as “trading
away” or “step out trading.” The portfolio manager – not the Firm – decides as to when it trades with
Pershing or away from Pershing. A portfolio manager’s ability to trade away is not limited, as the portfolio
manager’s fiduciary duty to clients, as well as its expertise in trading its portfolio securities, makes the
portfolio manager responsible for determining the suitability of trading away from Pershing.
The wrap fees disclosed previously in this document do not cover transaction charges or other charges,
including commissions, markups, and markdowns resulting from transactions effected through or with a
broker dealer other than Pershing, which is the custodian. In addition, some portfolio managers executing
trades in U.S. Treasury securities will incur a system cost from the portal through which the trades are
processed. As a result, these trades could be more costly than trades that execute with Pershing and could
negatively affect the performance of the account. Further, the additional trading costs will not be
reflected on clients’ trade confirmations or account statements. Typically, the executing broker will
embed the added costs into the transaction price, making it difficult to determine the exact added cost
for transactions executed away from Pershing.
The Firm does not receive additional fees when portfolio managers execute transactions away from
Pershing.
Considering the additional charges that apply to step out transactions, the portfolio manager could
determine that placing clients’ transactions with Pershing is in clients’ best interest. Alternatively, the
portfolio manager may execute transactions with a broker-dealer firm other than Pershing if the portfolio
manager believes that doing so is consistent with its obligation to obtain best execution.
Item 5 Account Requirements and Types of Clients
Account Requirements
Please refer to Item 4 for specific information regarding the minimum account size required for each of
our programs.
Types of Clients
The Firm provides the advisory services described in this Brochure to individuals, pension or profit-sharing
plans, trusts, charitable organizations, corporations, and other business entities.
Page 22 of 32
March 2026
Item 6 Portfolio Manager Selection and Evaluation
Selection and Review of Portfolio Managers
The Client Advisors generally select which portfolio managers to recommend to clients. The Firm selects
portfolio managers for its wrap fee programs based upon the nature of the products offered and services
provided. The Firm may also add or remove portfolio managers from the programs based upon the
requests of the Client Advisors, or for any reason, in its sole discretion. The Firm uses information provided
by BNYA and portfolio managers, as well as publicly available information, in reviewing and selecting third-
party portfolio managers and model managers suitable for the Firm’s wrap fee programs. BNYA provides
information and research to the Firm with respect to managers that are researched by BNYA. BNYA uses
proprietary processes for screening and evaluating managers made available under its advisory platform
that focuses on quantitative factors such as historical performance and volatility, as well as the manager's
reputation and approach to investing.
The Firm does not audit, verify, or guarantee the accuracy, completeness, or methods of calculation of
any historic or future performance or other information provided by BNYA or any third-party portfolio
manager. There can be no assurance that the performance information from BNYA and portfolio manager,
or other source is or will be calculated on any uniform or consistent basis or has been or will be calculated
according to or based on any industry or other standards.
The Firm’s selection and review process with respect to the Firm related persons serving as portfolio
managers under our wrap fee programs differs from the selection and review process described above
with respect to third party portfolio managers. The minimum requirements for the Client Advisors and
other investment advisor representatives to serve as a Firm portfolio manager include college degree or
satisfactory past relevant business and portfolio management experience, in addition to the required
industry examinations and registrations, if any. The Firm conducts a detailed annual review of its IMG
portfolio management team’s processes and activities as part of the Firm’s compliance review of its
supervisory and operational departments. All associates have annual written performance reviews.
Advisory Business
The Firm acts as discretionary portfolio manager for clients in the Arvest Wealth Management Advisor
Directed Discretionary Program and IMG portfolios. Please refer to Item 4 for a description of (a) our
portfolio management services with respect to these programs, (b) how we tailor our advisory services to
our clients’ needs and (c) clients’ ability to impose reasonable restrictions on investing in certain securities
or types of securities, and (d) the portion of the Client Advisory Fees that we receive for our services as
portfolio manager with respect to these programs.
Performance-Based Fees and Side-by-Side Management
Fees based on a share of capital gains or capital appreciation of assets of a client are commonly referred
to as “performance-based fees.” Neither the Firm nor any of its supervised persons accept performance-
based fees.
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We may use the following methods of analysis in formulating our investment advice and/or managing
client assets in the programs for which we act as portfolio managers (the IMG Portfolios, the Adviser
Directed- Discretionary Program, and the Adviser Directed-Non-Discretionary Program):
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
Page 23 of 32
March 2026
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk,
as the price of a security can move up or down along with the overall market regardless of the economic
and financial factors considered in evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis to the present to recognize
recurring patterns of investor behavior and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
in that a poorly managed or financially unsound company may underperform regardless of market
movement.
Quantitative Analysis. We use mathematical models to obtain more accurate measurements of a
company’s quantifiable data, such as the value of a share price or earnings per share and predict changes
to that data.
A risk in using quantitative analysis is that the models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement
and predict changes to share price based on that data. A risk using qualitative analysis is that our
subjective judgment may prove incorrect.
Investment Strategies
As portfolio managers, we use the following strategies in managing client accounts, provided that such
strategies are appropriate to the needs of the client and consistent with the client’s investment objectives,
risk tolerance, and time horizons, among other considerations:
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk
tolerance.
Long-term purchases. We purchase securities with the idea of holding them in the client’s account for a
year or longer. Typically, we employ this strategy when:
● We believe the securities to be currently undervalued, and/or
● We want exposure to a particular asset class over time, regardless of the current projection for this
class.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them
within a relatively brief time (typically a year or less). Although we do not participate in market timing, we
do this to take advantage of conditions that we believe will soon result in a price swing in the securities
we purchase.
Use of Options. We may use options as an investment strategy. An option is a contract that gives the buyer
the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or
before a certain date. A seller, or writer, of an option contract receives a premium (credit) from the buyer
and has obligations at the option’s exercise. An option, just like a stock or bond, is a security. An option is
also a derivative because it derives its value from an underlying asset.
Page 24 of 32
March 2026
The two types of options are “calls” and “puts”:
● A “call” gives us the right to buy an asset at a certain price within a specific period of time. We will
buy a “call” if we have determined that the stock may increase before the option expires. Additionally,
we could sell a call to receive a premium, keeping in mind our obligations to the buyer if the options
are exercised.
● A “put” gives us, the holder, the right to sell an asset at a certain price within a specific period of time.
We will buy a “put” if we have determined that the price of the stock may fall before the option
expires. Additionally, we could sell a put to receive a premium, keeping in mind our obligations to the
buyer if the options are exercised.
We will use options to speculate on the possibility of a sharp price swing. We will also use options to
“hedge” a purchase of the underlying security; in other words, we will use an option purchase to limit the
potential upside and downside of a security we have purchased for your portfolio.
We use “covered calls,” in which we sell an option on security you own. In this strategy, you receive a
fee for making the option available, and the person purchasing the option has the right to buy the
security from you at an agreed-upon price.
We use a “spreading strategy,” in which we purchase two or more option contracts (for example, a “call”
option that you buy and a “call” option that you sell) for the same underlying security. This effectively
puts you on both sides of the market, but with the ability to vary price, time, and other factors.
Use of Complex or Alternatives. We, and other portfolio managers in our wrap fee program, may also
employ complex or alternative investments. Examples of these alternative investments are alternative
mutual funds, buffered UITs, and leveraged ETFs. Alternative mutual funds include a wide range of
investment objectives to meet various needs. Unlike traditional mutual funds, alternative mutual funds
often seek to accomplish their investment objectives by investing in non-traditional investments such as
global real estate, start-up companies, or commodities. Additionally, these alternative funds generally use
more complex investment and trading strategies than traditional mutual funds, such as selling stocks
short, or using derivatives or leverage. A Buffered UIT uses an investment strategy designed to provide
upside performance potential, subject to a cap, with some downside protection. The portfolios invest in
options based on the price performance of shares of a reference asset, often an ETF. The performance
may be impacted by a variety of factors to include among others, redemption activity, dilution of your
investment, unusual market events, market movements, and changes in the liquidity of options.
Leveraged ETFs are exchange-traded funds that use financial derivatives and debt as leverage to amplify
the returns of an underlying index. Generally leveraged ETFs are more expensive than traditional ETFs and
the potential for greater (amplified) performance also brings the potential for greater losses.
Risk of Loss
Investments in securities have inherent risks and clients should be prepared to bear the risk that they
could lose some or all the money they invest. Material risk factors related to the investment strategies
we, or other portfolio managers within our wrap fee program include but are not limited to, the following:
Asset Allocation Risk - A risk of asset allocation is that the client may not participate in sharp increases in
a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income,
and cash will drift over time due to stock and market movements and, if not corrected, will no longer be
appropriate for the client’s goals.
Risks for all forms of analysis - Our analysis methods rely on the assumption that the companies whose
securities we purchase and sell, the rating agencies that review these securities, and other publicly
available sources of information about these securities, are providing accurate and unbiased data. While
Page 25 of 32
March 2026
we are aware that data may be incorrect, there is always a risk that our analysis may be compromised by
inaccurate or misleading information.
Long-term purchase strategy risk - A risk in a long-term purchase strategy is that by holding the security
for this length of time, we may not take advantage of short-term gains that could be profitable to a client.
Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the
decision to sell.
Risks Associated with Investing in Commodities. An investment in commodity-linked derivative
instruments may be subject to greater volatility than investments in traditional securities, particularly if
the instruments involve leverage. The value of commodity-linked derivative instruments may be affected
by changes in overall market movements, commodity index volatility, changes in interest rates, or factors
affecting a particular industry or commodity, such as drought, floods, weather, livestock disease,
embargoes, tariffs, international economic, political, and regulatory developments. The use of derivatives
presents risks different from, and possibly greater than, the risks associated with investing directly in
traditional securities. Among the risks presented are market risk, credit risk, counterparty risk, leverage
risk and liquidity risk. The use of derivatives can lead to losses because of adverse movements in the price
or value of the underlying asset, index, or rate which may be magnified by certain features of the
derivatives.
Risks Associated with Investing in Mutual Funds – Mutual Funds are subject to market risk, including the
possible loss of principal. The value of the portfolio will fluctuate with the value of the underlying
securities. Mutual Funds may have underlying investment strategy risks similar to investing in
commodities, bonds, real estate, international markets or currencies, emerging growth companies, or
specific sectors. Investors should consider Mutual Funds investment objective, risks, charges, and
expenses carefully before investing. In addition to your annual management fee, you will have the fund’s
internal management fees (these fees are detailed in the fund’s prospectus). Mutual funds are required
to distribute capital gains to shareholders, typically at year-end. Even if the fund’s overall value has
decreased during the year, you may still owe taxes on capital gains distributions if the manager sold
underlying holdings for a profit.
Risks Associated with Investing in an Exchange-Traded Fund (ETF) - ETFs are subject to market risk,
including the possible loss of principal. The value of the portfolio will fluctuate with the value of the
underlying securities. ETFs may trade for less than their net asset value. ETFs may have underlying
investment strategy risks similar to investing in commodities, bonds, real estate, international markets or
currencies, emerging growth companies, or specific sectors. Investors should consider an ETF’s investment
objective, risks, charges, and expenses carefully before investing.
Convertible Securities Risk - Convertible securities are subject to the usual risks associated with debt
securities, such as interest rate risk and credit risk. Convertible securities also react to changes in the value
of the common stock into which they convert and are thus subject to market risk.
Counterparty Risk - The risk that a counterparty to a financial instrument entered into by the Portfolio
Manager or held by a special purpose or structured vehicle becomes bankrupt or otherwise fails to
perform its obligations due to financial difficulties, including making payments to the Portfolio.
● Counterparty risk involved in ETFs with full replication and ETFs with representative sampling
strategies – An ETF using a full replication strategy generally aims to invest into all constituent assets
in the same weightings as its benchmark. ETFs adopting a representative sampling strategy will invest
in some, but not all the relevant constituent assets. ETFs investing through synthetic instruments
issued by third parties carry more counterparty risk than ETFs investing directly in the underlying
assets.
Page 26 of 32
March 2026
● Synthetic replication strategies – ETFs using a synthetic replication strategy use swaps or other
derivative instruments to gain exposure to a benchmark. Currently, synthetic replication ETFs can be
further categorized into two forms:
● Swap-based ETFs – Total return swaps allow ETF managers to replicate the benchmark performance
of ETFs without purchasing the underlying assets. Swap-based ETFs are exposed to counterparty risk
of the swap dealers and may suffer losses if such dealers default or fail to honor their contractual
commitments.
● Derivative embedded ETFs – ETF managers may use other derivative instruments to synthetically
replicate the economic benefit of the relevant benchmark. The derivative instruments may be issued
by one or multiple issuers. Derivative embedded ETFs are subject to the counterparty risk of the
derivative instruments’ issuers and may suffer losses if such issuers default or fail to honor their
contractual commitments.
Cybersecurity Risk – Investment Advisers, in addition to the clients they serve, are exposed to, and rely
on, a broad array of interconnected systems and networks, both internally and through service providers
such as custodians, brokers, dealers, and technology providers. All these parties use digital engagement
tools and other technology to varying degrees in their communications and engagements. As a result,
they face cybersecurity risks and may experience cybersecurity incidents. Cybersecurity risks include, but
are not limited to compromised company, employee, or client data, corruption or loss of data, and
disruption or inability to provide services.
Default Risk – The risk that the issuer of a fixed-income security or the counterparty to a contract may or
will default or otherwise become unable or unwilling to honor a financial obligation, such as making
interest or principal payments.
Foreign Currency Risk – Securities issued by foreign companies are frequently denominated in foreign
currencies. The change in value of a foreign currency against the U.S. dollar will result in a change in the
U.S. dollar value of securities denominated in that foreign currency.
Foreign Investment Risk – The Portfolio may invest in securities of foreign issuers. Investments in securities
of foreign securities are subject to risks associated with foreign markets, such as adverse political, social,
and economic developments, accounting standards or governmental supervision that is not consistent
with that to which U.S. companies are subject, limited information about foreign companies, and less
liquidity in foreign markets. These risks may be more pronounced for investments in developing countries.
Government Agency Risk – Direct obligations of the U.S. Government such as Treasury bills, notes and
bonds are supported by its full faith and credit. Indirect obligations issued by Federal agencies and
government-sponsored entities generally are not backed by the full faith and credit of the U.S. Treasury.
Accordingly, while U.S. Government agencies and instrumentalities may be chartered or sponsored by
Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Treasury.
Inflation risk – Prices of a Portfolio’s investments will likely move in response to changes in inflation and
interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing
power of an investor’s future interest payments and principal. Inflation also generally leads to higher
interest rates, which in turn may cause the value of many types of fixed income investments to decline.
Interest Rate Risk – Fixed income securities increase or decrease in value based on changes in interest
rates. If rates increase, the value of fixed income securities generally declines. On the other hand, if rates
fall, the value of the fixed income securities generally increases.
Legislative Risk – There can be no assurance as to what actions might be taken by any federal, state, or
municipal legal authority that may adversely affect investments held by the Portfolio. These actions may
include (but are not limited to) changes on environmental issues, regulation, social issues, and taxation.
Page 27 of 32
March 2026
Liquidity Risk – Due to a lack of demand in the marketplace or other factors, a Portfolio may not be able
to sell some or all the investments promptly or may only be able to sell investments at less than desired
prices.
Management Risk – The Portfolio is actively-managed. The Portfolio’s value may decrease if the Firm
pursues unsuccessful investments or fails to correctly identify risks affecting the broad economy or
specific issuers comprising the Portfolio.
Market Risk – The market value of securities may fall or fail to rise. Market risk may affect a single issuer,
sector of the economy, industry, or the market as a whole. The market value of securities may fluctuate,
sometimes rapidly and unpredictably.
Municipal Obligation Risk – Municipal security prices can be significantly affected by political changes as
well as uncertainties in the municipal market related to taxation, legislative changes, or the rights of
municipal security holders. Because many municipal securities are issued to finance similar projects,
especially those relating to education, healthcare, transportation and utilities, conditions in those market
sectors can affect municipal bond prices.
Prepayment Risk – Issuers may choose to pay off debt earlier than the stated maturity date on a bond.
When this happens, the bond fund may not be able to reinvest the proceeds in an investment with as high
a return or yield.
Real Estate Industry and Real Estate Investment Trust (REIT) Risk - These risks can include fluctuations in
the value of the underlying properties, defaults by borrowers or tenants, market saturation, decreases in
market rates for rents, and other economic, political, or regulatory occurrences affecting the real estate
industry, including REITs. REITs depend upon specialized management skills, may have limited financial
resources, may have less trading volume, and may be subject to more abrupt or erratic price movements
than the overall securities markets. REITs are also subject to the risk of failing to qualify for tax-free pass-
through of income.
Risks in Commercial Real Estate Market – A Portfolio’s investments in commercial real estate are subject
to risks affecting real estate investments generally (including market conditions, competition, property
obsolescence, changes in interest rates and casualty to real estate).
Risk of Impaired Credit Quality – If debt obligations held by a Portfolio are downgraded by ratings agencies,
go into default, or if management action, legislation or other government action reduces the issuers’
ability to pay principal and interest when due, the obligations’ value may decline and a Portfolio’s value
may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including
particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain
than for an issuer of a higher rated obligation, lower-rated and unrated obligations are generally more
vulnerable than higher-rated obligations to default, ratings downgrades, and liquidity risk. Political,
economic, and other factors also may adversely affect governmental issues.
Commodities and Commodity Derivatives Investing Risk – An investment in commodity-linked derivative
instruments may be subject to greater volatility than investments in traditional securities, particularly if
the instruments involve leverage. The value of commodity-linked derivative instruments may be affected
by changes in overall market movements, commodity index volatility, changes in interest rates, or factors
affecting a particular industry or commodity, such as drought, floods, weather, livestock disease,
embargoes, tariffs, and international economic, political, and regulatory developments. The use of
derivatives presents risks different from, and possibly greater than, the risks associated with investing
directly in traditional securities. Among the risks presented are market risk, credit risk, counterparty risk,
leverage risk and liquidity risk. The use of derivatives can lead to losses because of adverse movements in
the price or value of the underlying asset, index, or rate which may be magnified by certain features of
the derivatives.
Page 28 of 32
March 2026
Small-Cap and Mid-Cap Risk – Securities of small or mid-capitalization companies that may not have the
size, resources, and other assets of large-capitalization companies. As a result, the securities of small- or
mid-cap companies held by the Portfolio may be subject to greater market risks and fluctuations in value
than large-cap companies or may not correspond to changes in the stock market in general.
Risks associated with Complex or Alternative Investments – These types of investments are often more
speculative, illiquid, expensive, and subject to higher degree of risk than traditional securities. The
potential benefits of using derivative and illiquid investments and/or complex trading strategies could
have a negative impact on a client’s ability to achieve their investment objectives.
Voting Client Securities
The Firm does not have and will not accept authority to vote client securities, with respect to any of the
programs described in this Brochure, except for the IMG Programs, as described below.
IMG Programs
The Firm acts as discretionary portfolio manager through its PMR for clients in the IMG portfolios. The
conditions that govern the PMR’s authority to vote proxies on behalf of clients are contained in our
advisory agreement. If Clients investing in the IMG portfolios elected to delegate to IMG program portfolio
manager the authority to vote proxies on their behalf, pursuant to the advisory agreement, PMR
investment advisory portfolio managers will vote proxies on behalf of its clients. If clients elected to vote
proxies on their own behalf, they will receive proxy related information directly from their custodian.
We will vote proxies in the best interests of clients and in accordance with our established policies and
procedures. It is our policy to vote client shares primarily in conformity with Glass-Lewis & Co. or
Broadridge recommendations. Glass-Lewis & Co. and Broadridge are neutral third parties that issue
recommendations based on their own internal guidelines. Using Glass-Lewis & Co. or Broadridge
recommendations assist in limiting conflict of interest issues between the Firm and our clients.
PMR utilizes a third-party electronic voting platform, ProxyEdge (a division of Broadridge Financial
Solutions, Inc.) to vote client shares. The Firm or ProxyEdge retains a record of all proxy voting information
for the requisite amount of time, including a copy of each proxy statement received, a record of each vote
cast, and a copy of any document created that was material to deciding on how to vote proxies.
Item 7 Client
Information Provided
to Portfolio
Managers
You must complete an account profile with the assistance of your Client Advisor. The account profile
outlines your investment objectives, financial circumstances, risk tolerance and any restrictions you may
wish to impose on your investment activities. You agree to inform us in writing of any material change in
your financial circumstances that might affect the way your assets should be invested. Your Client Advisor
will be reasonably available to you for consultation on these matters and will act on any changes in your
account profile deemed to be material or appropriate as soon as practical after we become aware of the
change.
Information Provided to Affiliated Portfolio Managers
The Firm employees who serve as portfolio managers have access to all client information obtained by
the Firm and Client Advisors with respect to the particular client accounts they manage.
Page 29 of 32
March 2026
Information Provided to Non-affiliated Portfolio Managers
Non-affiliated portfolio managers have access to potentially all client information with respect to clients
whose accounts they manage through a “distributor workstation” that is used to monitor and manage
client activity. Such information includes client identifying information such as name, address, and tax ID;
account profile information such as investment objective and risk tolerance; and administrative
information such as disbursement requests, statements, confirmations, and other documents prepared
by the custodian, Pershing. In addition, individual portfolio managers sometimes request additional
information such as copies of client account agreements, other account related agreements, such as IRA
adoption forms and beneficiary designations, and IRS form W-9. To the extent the Firm believes such
requests are reasonably related and necessary to the services being provided by the third-party portfolio
managers, the Firm generally honors those requests.
Item 8 Client Contact with Portfolio Managers
The primary contact for clients with respect to all Firm-sponsored wrap fee advisory programs is the
client’s Client Advisor. There are no restrictions on a client’s access to his or her Client Advisor. Non-
affiliated portfolio managers typically service clients of multiple firms, and direct client access to those
portfolio managers is, therefore, not routine. In most cases, the Firm clients rely on the firm to monitor
the performance and appropriateness of non-affiliated portfolio managers and to manage the
relationship. Nevertheless, the Firm is not aware of any prohibition against the client communicating
directly with non-affiliated Portfolio Managers in appropriate. In certain instances, your Client Advisor
may coordinate a response with the Portfolio Manager (if applicable) or arrange for you to consult directly
with the Portfolio Manager.
Item 9 Additional Information
Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client’s or prospective
client’s evaluation of our advisory business or the integrity of our management.
The Firm, as a broker-dealer, is a member of FINRA. FINRA alleged that the Firm violated rules 4 and 5 of
Regulation S-P, NASD Rule 3010(a)(2) and (b)(1), and FINRA Rules 3110(a)(2), (b)(1) and 2010 by, between
January 2009 and December 2016, failing to provide required initial and annual privacy notices to certain
brokerage customers and failing to establish and maintain a supervisory system reasonably designed to
ensure that it was meeting its privacy notice obligations. In May 2018, without admitting or denying
FINRA’s findings, the Firm consented to the entry of findings and to the following sanctions, including a
censure, a fine in the amount of $150,000, and an undertaking to revise as necessary its policies,
procedures, and internal controls, which the Firm has already complied with.
You can access additional information about our firm and our management personnel on the SEC’s
website adviserinfo.sec.gov, and on FINRA’s website, https://brokercheck.finra.org.
Financial Industry Activities and Affiliations
The Firm is also a general securities broker/dealer, member FINRA/SIPC, registered with the SEC and various
state regulatory agencies.
The Firm is wholly owned by Arvest Bank, an Arkansas state-chartered bank. The Firm is also affiliated
with Arvest Insurance, Inc., an Arkansas insurance agency, and wholly owned subsidiary of Arvest Bank,
offering life and health insurance products. All are wholly owned by Arvest Bank.
Page 30 of 32
March 2026
The Firm’s Client Advisors are licensed as general securities brokers, insurance agents, and registered
investment advisors. The Firm’s Client Advisors may recommend that clients purchase insurance products
through Arvest Insurance, Inc., or banking, loan, and trust services through Arvest Bank for which clients
may incur separate costs, including fees, interest, and other changes in addition to the Client Advisory Fee
described herein; however, clients are under no obligation to purchase products or services through an
affiliated financial services company.
Custody
The Firm does not maintain physical custody of client assets (which are maintained by Pershing, a third-
party qualified custodian, as discussed in Item 4 above); however, we are deemed to have custody of
certain clients’ wrap fee account assets pledged by such clients as collateral to secure their obligations to
repay loans obtained from the Firm’s parent company, Arvest Bank. Additionally, the Firm would be
deemed to have custody in certain instances where Arvest Bank, a Client Advisor, or another Firm-related
person serves as trustee, or has similar powers conferred by a trust document, general power of attorney,
or guardianship related to a Firm advisory account, which could result in conflicts of interest given the
dual roles involving the Firm and its related persons. A Client Advisor can only serve in the above roles for
members of their immediate family or with approval from AWM Compliance.
All Firm clients receive account statements directly from Pershing at least quarterly. We urge our clients
to carefully review these statements.
Code of Ethics
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we
require of our employees, including compliance with applicable federal securities laws.
The Firm and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have
an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general
principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access
persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of
securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides
for oversight, enforcement, and recordkeeping provisions.
Our Code of Ethics is designed to ensure that the personal securities transactions, activities, and interests
of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their own
accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal account(s) securities
identical to or different from those recommended to our clients. In addition, any related person may have
an interest or position in a certain security which may also be recommended to a client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior
to a transaction(s) being implemented for an advisory account, when the associate has received an
order(s) or has knowledge of pending trades for clients, thereby; preventing such employee(s) from
benefiting from transactions placed on behalf of advisory accounts.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to AWMSolutionsCenter@arvest.com , or by calling (888) 916-2121.
Page 31 of 32
March 2026
Review of Accounts
We contact clients at least annually to determine whether there have been any changes in the client’s
financial situation, investment objectives or investment restrictions that would require changes to the
client’s Program Account. To ensure that the Program and the selected Model, Investment Strategy
and/or Portfolio Manager remain suitable for the client, clients are instructed to promptly notify their
Client Advisor of any material changes to their investment objectives and/or financial situation. Clients
are solely responsible for notifying the Firm in the event that any information that Firm maintains about
them is inaccurate or becomes inaccurate.
While the underlying securities within an account are monitored by the account’s portfolio managers,
accounts are reviewed at least annually by the Client Advisor assigned to the account. Accounts are
reviewed in the context of each client’s stated investment objectives and guidelines. More frequent
reviews may be triggered by material changes to client’s individual circumstances, market conditions,
political or economic environment.
Account Statements and Reports
Our clearing firm/custodian provides statements at least quarterly and confirmations of transactions that
include periodic reports summarizing account performance, balances, and holdings.
Client Referrals
The Firm does not pay referral fees to independent persons or firms for introducing clients to us. We may
pay Arvest Bank associates a nominal one-time cash award of no more than $25, for a qualified referral
to a licensed Client Advisor, which is not dependent upon a sale being made.
It is the Firm’s policy not to accept or allow our related persons to accept any form of compensation,
including cash, sales awards, or other prizes from a non-client in conjunction with the advisory services
we provide to our clients.
Financial Information
Under no circumstances does the Firm require or solicit payment of fees more than $1,200 per client more
than six months in advance of services rendered. Therefore, we are not required to include a balance
sheet for our most recently completed fiscal year.
The Firm is not aware of any financial condition that is reasonably likely to impair its ability to meet its
contractual commitments to its clients nor has the Firm been the subject of a bankruptcy petition.
Business Continuity Plan
The Firm is committed to safeguarding the interests of our clients and customers in the event of an
emergency or significant business disruption. Our Business Continuity Plan, which enables us to respond
to events that significantly disrupt our business, may be obtained from our Client Advisors,
and can also be found at our disclosures website: https://www.arvest.com/documents-and-
resources/awm-disclosures.
Page 32 of 32
March 2026