BOKFA INVESTON WRAP FEE PROGRAM BROCHURE

InvestOn™ Wrap Fee Program Brochure Form ADV Part 2A, Appendix 1 March 31, 2026 BOK Financial Advisors P.O. Box 2300 Tulsa, OK 74172 Phone: (877) 781-6889 advisors.bokfinancial.com This Part 2A, Appendix 1 Wrap Fee Program Brochure (“Brochure”) is effective March 31, 2026, and provides information about the qualifications and business practices of BOK Financial Advisors (“BOKFA”) relating to InvestOn™ (the “Program”), an online investment advisory program. If you have any questions about the contents of this Brochure, please contact the BOKFA Compliance Department at 1-877-781- 6889. Please note that the information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. BOKFA is an investment adviser registered with the SEC. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. Additional information about BOKFA is available on the SEC’s website at www.adviserinfo.sec.gov. IRS Circular 230 Disclosure: BOKFA, its affiliates, agents, and employees are not in the business of providing tax, regulatory, accounting, or legal advice. This Brochure and any tax-related statements provided by BOKFA are not intended or written to be used, and cannot be used or relied upon, by any such taxpayer for the purpose of avoiding tax penalties. Any such taxpayer should seek advice based on the taxpayer’s particular circumstances from an independent tax advisor. Securities, insurance, and advisory services offered through BOK Financial Securities, Inc., member FINRA/SIPC and a subsidiary of BOK Financial Corporation. Services may be offered under our trade name, BOK Financial Advisors. NOT FDIC INSURED | NO BANK GUARANTEE | MAY LOSE VALUE  Item 2. Material Changes This section discusses specific material changes that have been made to our Wrap Fee Program Brochure dated January 10, 2025, and provides you with a summary of such changes. There have been no changes to our InvestOn Wrap Fee Program Brochure since January 10, 2025. We will provide you with a new Part 2A, Appendix 1 Wrap Fee Program Brochure as necessary based on SEC Rules or at your request, at any time, without charge. Our Wrap Fee Program Brochure may be requested by contacting your BOKFA Advisor or by calling 1-877-781- 6889. BOKFA InvestOn™ Brochure | 2  Item 3. Table of Contents Item 2. Material Changes ............................................................................................................................ 2 Item 3. Table of Contents ............................................................................................................................ 3 Item 4. Services, Fees and Compensation ................................................................................................. 4 About BOKFS/BOKFA ............................................................................................................................. 4 Description of Services ............................................................................................................................ 4 Electronic Accessibility Requirement ...................................................................................................... 5 Investment Advice ................................................................................................................................... 5 Gather Information .............................................................................................................................. 5 Asset Allocation Model and Investment Strategy ................................................................................ 6 Withdrawals of Assets ............................................................................................................................. 7 Investment of Cash ................................................................................................................................. 7 Custody ................................................................................................................................................... 7 Account Statements ................................................................................................................................ 7 Trade Confirmations ................................................................................................................................ 7 Trading Practices .................................................................................................................................... 7 Voting Client Securities ........................................................................................................................... 8 Class Actions ........................................................................................................................................... 8 Fees and Compensation ......................................................................................................................... 8 Program Fees ...................................................................................................................................... 8 Termination of Client Agreements ........................................................................................................... 9 Other Fee Information ............................................................................................................................. 9 Wrap Fee Pricing Compared to Alternative Options ........................................................................... 9 Performance-Based Fees and Side-by-Side Management ................................................................ 9 Additional Expenses You May Pay Including Brokerage and Other Transaction Costs ..................... 9 Mutual Fund Fees ............................................................................................................................... 9 Cavanal Hill Fund Fees ..................................................................................................................... 10 IRA Account Fees ............................................................................................................................. 10 Administrative Fees ........................................................................................................................... 11 Item 5. Account Requirements and Types of Clients ................................................................................ 11 Electronic Relationship .......................................................................................................................... 11 Types of Clients ..................................................................................................................................... 12 Program Minimums ............................................................................................................................... 12 Item 6. Portfolio Manager Selection and Evaluation ................................................................................. 12 Advisory Business ................................................................................................................................. 12 Methods of Analysis .............................................................................................................................. 12 Affiliated Managers ................................................................................................................................ 12 Risk of Loss ........................................................................................................................................... 13 Item 7. Client Information Provided to Portfolio Managers ....................................................................... 14 Item 8. Client Contact with Portfolio Managers ......................................................................................... 15 Item 9. Additional Information ................................................................................................................... 15 Disciplinary Information ......................................................................................................................... 15 Other Financial Industry Activities and Affiliations ................................................................................ 17 Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ....................... 18 Soft Dollar Benefits ................................................................................................................................ 19 Best Execution ...................................................................................................................................... 19 Review of Accounts ............................................................................................................................... 19 Client Reporting ..................................................................................................................................... 19 Client Referrals and Other Compensation ............................................................................................ 19 Financial Information ............................................................................................................................. 21 Business Resumption ............................................................................................................................ 21 Privacy Notice ....................................................................................................................................... 21 BOKFA InvestOn™ Brochure | 3  Item 4. Services, Fees and Compensation About BOKFS/BOKFA BOK Financial Securities, Inc. (“BOKFS”), d/b/a BOKFA Advisors (“BOKFA”) is an investment adviser registered with the Securities and Exchange Commission (“SEC”), as well as a registered broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”), and the Municipal Securities Rulemaking Board (“MSRB”). BOKFA has been registered as an investment adviser with the SEC since January 1997. SEC registration does not imply a certain level of skill or training. BOK Financial Advisors is a wholly-owned subsidiary of BOK Financial Corporation (“BOK Financial”), an Oklahoma corporation that is publicly traded and listed on the NASDAQ exchange (ticker symbol: BOKF). BOKFA has locations associated with BOKF, NA under the banking names of: BOK Financial, Bank of Albuquerque, Bank of Oklahoma, and Bank of Texas. BOK Financial Securities is also licensed as an insurance agency in some states under the names BOK Financial Securities, Inc., BOSC Agency, Inc., and BOSC Insurance Services. See Item 9. Additional Information - Other Financial Industry Activities and Affiliations for more information. In this document, BOK Financial Securities, Inc. is referred to as “BOKFS” when describing its activities as a broker-dealer. BOK Financial Advisors is the name used in association with advisory activities (including sponsoring the wrap fee programs) and may be referred to as “BOKFA,”, “the Firm”, “we,” “us,” or “our” throughout this document. “You” or “your” refers to our current or prospective clients. Description of Services Wrap Fee Programs The Firm provides investment advisory services through Firm-sponsored wrap fee programs, as further described in this Brochure. A wrap fee program is an investment advisory program in which you pay one bundled annual fee to compensate the Firm and Portfolio Manager for their services. The fee also covers brokerage services including execution, clearing, and custody costs associated with the transactions in your wrap fee program account. 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 provides execution and clearing of transactions. By entering into the Firm wrap fee program advisory agreement and participating in a wrap fee program, you are authorizing and directing the Firm and the Portfolio Managers to trade through Pershing. InvestOn Program This Brochure describes the InvestOn™ program (the “Program”), an online investment advisory program sponsored by BOKFA. The Program is a discretionary, fee-based investment management solution offered by BOKFA through our suite of Managed Account Programs. The Program allocates account assets to mutual funds selected by BOKF, NA’s Strategic Investment Advisors (“SIA”) group and trades are executed by BOKFA at its discretion. The Firm sponsors and offers the following Managed Account Programs: Separately Managed Account (“SMA”) Program Portfolio Manager (“PM”) Directed Program • Mutual Fund/Exchange Traded Fund (“ETF”) Program – Wealth Portfolios Program • Mutual Fund/ETF Program – Advisor Select Flex Program • Mutual Fund/ETF Program – CPS Program (closed to new investors) • Outside Investment Strategies Program • Unified Managed Account (“UMA”) Program • • • Advisor Directed Program – Discretionary (closed to new investors) • Advisor Directed Program – Non-Discretionary • Digital Advice Program – InvestOn™ BOKFA InvestOn™ Brochure | 4  Clients are not limited to just one Managed Account Program. Clients can obtain the wrap fee program brochures detailing the other Managed Account Programs through the SEC’s Investment Adviser Public Disclosure page (https://adviserinfo.sec.gov) or by contacting the Firm. The Program is designed to help you pursue your investment goals by providing you with investment advice, guidance, and access to advisory services and investment solutions. Before investing through the Program, please read the information in this Brochure and contact the Firm at 877-781-6889 if you have any questions. Clients use a web or mobile application to determine whether the Program is appropriate for them. If so, clients must enter into an investment advisory agreement with us (the “Client Agreement”). The Client Agreement will cover the Program account that you choose to enroll in. In the Client Agreement, we agree to act as your investment adviser and agent to provide the services described in this Brochure and you grant us the investment discretion and trading authority necessary to do so. Electronic Accessibility Requirement The Program provides you with the services described in this Brochure electronically through the use of the Program’s website (https://advisors.bokfinancial.com/ways-to-work-with-us/investon) or mobile application. Through an online experience clients complete their Risk Profile Questionnaire then consider and, if acceptable, select a recommended portfolio and investment strategy. Clients should carefully consider whether their participation in the Program is appropriate for their investment needs and goals prior to enrollment. You can change your investment strategy by going online and completing a new Risk Profile Questionnaire. You should periodically review your existing Risk Profile Questionnaire and update it when your goals, financial circumstances, risk tolerance, or other aspects of your financial situation change. You must log in to the Program website or mobile application to access important documents, ensure information is accurate and up to date, and to complete periodic reviews. You will be required to sign a New Account Form, the Client Agreement, and other agreements and acknowledge disclosures, as necessary, electronically. These agreements and other disclosures and notices will be delivered to you in electronic format only by posting the information on the Program website or mobile application where you access your account, through email, or via other electronic means. This is a requirement both now and in the future. You are required to provide us with an accurate and up to date email address to enroll in the Program. You are required to immediately notify us of any changes to your email address by updating your information via the Program website or mobile application or by calling us at 877-781-6889. Failure to provide accurate contact information and a valid email address could result in termination of your enrollment in the Program. Additionally, if at any time you are enrolled in the Program you are unable or unwilling to sign electronically or accept electronic delivery of all Program documents and communications, your participation in the Program may be terminated. Investment Advice If you determine the Program is appropriate for you, then you will establish an account through the Program website or mobile application. To establish the account, we will 1) gather information about you and 2) recommend an asset allocation model and investment strategy, which you will accept by entering into the Client Agreement. Gather Information We will gather from you important financial and personal information used as the basis for our investment recommendations. Periodically you will be asked to confirm this information. It is your responsibility to ensure the information you provide to us is complete and accurate and to notify us if any information provided is inaccurate or becomes inaccurate. If there are joint owners on the account, then the information provided should reflect all owners’ views and circumstances. In performing our services, we are not required to independently verify any information you provide to us, and we are authorized to rely on the information you provide. BOKFA will use the information provided by you to recommend a target asset allocation and investment strategy. BOKFA InvestOn™ Brochure | 5  Recommendations are intended for the specific investment goal identified for that account. Additional accounts will need to be set up for additional investment goals. Asset Allocation Model and Investment Strategy The Program is a model-based asset allocation program that systematically rebalances client accounts to maintain target asset allocations and remove the emotion from investing. Your recommended asset allocation model will be based on the information you have provided us, including, but not limited to, your account risk tolerance and account time horizon. The investment selection aspect of the Program is professionally managed by BOKF, NA’s Strategic Investment Advisors group. SIA provides the research and analytics that build the foundation for investment services within BOK Financial. Asset allocation research, manager selection and oversight, and market analysis conducted by the group is utilized to deliver sophisticated investment solutions for clients of BOKFA and our affiliates. SIA establishes, monitors, and updates target asset allocation models as deemed necessary. In general, the asset allocation models, which have associated asset class ranges, available through the Program are: • • • Income-Conservative: The Income Conservative portfolio emphasizes income and protection. This portfolio should be considered if you seek high current income with preservation of capital and liquidity and are unwilling to accept significant fluctuations in value. Income: The Income portfolio emphasizes income and protection while retaining an equity component to help outpace inflation. This portfolio should be considered if you need additional current income from your investments and a potential hedge against inflation. Income with Growth: The Income with Growth portfolio seeks to provide income with a moderate level of long-term capital growth. This portfolio should be considered if you are seeking above- average income returns and are willing to accept fluctuations in value. • Balanced: The Balanced portfolio seeks to provide high total return over the long-term through capital appreciation and current income. This portfolio should be considered if you seek both a reasonable level of income and long-term growth of capital and are willing to accept a moderate level of risk and return. • Growth with Income: The Growth with Income portfolio seeks long-term capital appreciation and growth of income. This portfolio should be considered if you seek long-term growth of capital with moderate volatility and have the ability to withstand moderate fluctuations to achieve potentially higher returns. • Growth: The Growth portfolio seeks long-term capital appreciation with minimal need for income. This portfolio should be considered if you have moderately high expectations for a return on your investments and can tolerate market downturns and volatility for the possibility of achieving greater long-term gains. • Growth Aggressive: The Growth Aggressive portfolio seeks a high level of capital appreciation, without regard to current income. This portfolio should be considered if you seek to maximize long- term growth of capital and can tolerate high degrees of fluctuation for the possibility of higher returns. In the Program, after establishing the appropriate target asset allocation based on your Risk Profile Questionnaire, we will monitor your account and rebalance at any time in our sole discretion. Asset movements such as contributions or withdrawals, payment of dividends, receipt of interest, or payment of Program fees may prompt BOKFA to review your account to determine if rebalancing is necessary. In addition, BOKFA monitors your account for drift from the target asset allocation and may rebalance all or some of your account assets to the target allocation. Client accounts will be reallocated, or rebalanced if allocation percentages remain the same, as necessary in accordance with the then current asset allocation recommendations for a particular model. Resulting allocation changes are directed by BOKFA on a discretionary basis, without prior notice to the client. The Program will invest in a large number of mutual funds with some holding only a small percentage of the assets you BOKFA InvestOn™ Brochure | 6  allocate to this Program. When selecting a fund for a model, we select only funds subject to the selection process described in this Brochure. See Item 6. Portfolio Manager Selection and Evaluation for more information. Because the Program is a model-based program, BOKFA’s ability to tailor the Program is limited; however, clients may impose reasonable restrictions on investing in certain securities or types of securities to the extent the model can accommodate these requirements. Clients with specific investment restrictions or requirements must first inquire of BOKFA, in writing, in order to determine if the request(s) can be accommodated. Withdrawals of Assets Liquidation of certain securities may be required in connection with withdrawal requests. In such instances, assets will generally not be available for withdrawal until the settlement date(s) of the transactions. If requested funds are not withdrawn from the account within a reasonable amount of time, the funds may be reinvested without notification to you by us. Payment of account withdrawals may be issued in the form of a check. BOKFA reserves the right to terminate the account if it falls below the Program required minimum balance due to a withdrawal(s). In addition, taxable gains and losses may be realized as a result of a withdrawal request. Investment of Cash The Program Fee will be assessed on cash balances in your account. Each asset allocation model may have different cash allocations based on the strategy or current market conditions. In certain market conditions, such as volatile or uncertain market conditions, for defensive purposes, and for other cash management purposes, cash allocations may comprise a substantial portion of your account. Custody Pershing LLC (“Pershing”) is a wholly owned subsidiary of The Bank of New York Mellon Corporation (BNY) and a member of FINRA, the New York Stock Exchange (NYSE), and SIPC. Program accounts are custodied at Pershing. Pershing also provides clearing, recordkeeping, and reporting services for these accounts. Pershing is a qualified custodian as defined under Rule 206(4)-2 of the Investment Advisers Act of 1940 (Advisers Act). These services are included in the Program Fee and you do not pay extra for them. BOKFA is deemed to have custody of the cash and securities in the Program accounts because advisory fees may be deducted directly from the accounts. BOKFA is also deemed to have custody where it has standing third party asset movement instructions. Account Statements You will receive statements electronically directly from Pershing regarding the activity in your account(s) on at least a quarterly basis. You may request delivery of paper statements for a small charge (see Administrative Fee section below). Trade Confirmations You will receive trade-by-trade confirmations electronically for transactions in your account. You have the option of trade confirmation suppression during the establishment of your account. Should you elect to suppress trade confirmations you direct Pershing not to deliver separate trade confirmations for the account. You understand and acknowledge that: 1) you will not pay a different fee based on this direction; 2) this direction is not a condition to entering into or continuing to participate in the Program; 3) you may rescind this direction at any time. In lieu of separate trade confirmations, information from the confirmation will be reported via the account statement. A client that has suppressed trade confirmation can obtain, upon request to BOKFA or Pershing and at no additional charge, information about or a hard copy of any account confirmation. Trading Practices The Program may participate in “block” or “aggregated” trading allowing us to combine multiple orders for shares of the same securities purchased for advisory accounts we manage. We will combine orders for accounts held at the same BOKFA InvestOn™ Brochure | 7  custodian and in the same Program only. When block trading, we will distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. When we combine orders, each participating account pays an average price per share for all transactions. It does not reduce your transaction costs or fees. If a block order is only partially executed (filled), we allocate the order to all participating accounts on a pro rata basis. No account or type of account will be given preferential treatment in the allocation of aggregated orders. BOKFA is not obligated to utilize block or aggregated trading and may not do so in all circumstances. Voting Client Securities For clients with accounts in the Program, unless otherwise agreed to by you and BOKFA, you delegate through your advisory agreement the sole discretion to vote client security proxies to BOKFA at the commencement of your advisory relationship. You generally will not be able to direct BOKFA on how to vote in a particular proxy voting situation. It is the policy of BOKFA, that absent compelling reasons why a proxy should not be voted, all proxies relating to client securities should be voted. As a matter of policy and as a fiduciary to our clients, proxies are voted in the best interests of the client accounts. The determination of the interest of a client account in a proposal presented by proxy is the effect that the proposal could have on the current or future value of the investment, if any. In most cases, the default vote is to vote in line with management’s request. Cavanal Hill Investment Management monitors and votes proxies related to BOKFA for the Program unless you have retained this authority. Cavanal Hill Investment Management does this on behalf of BOKFA and maintains all appropriate documentation required by the SEC. You may obtain a more complete description of our proxy voting policies and procedures upon request. You may also obtain information from us about how proxies were voted on your behalf. Class Actions On occasion, securities held or previously held in a client’s account are the subject of class action lawsuit. BOKFA has no obligation to determine if securities held or previously held by the client are subject to a pending or resolved class action lawsuit. In addition, BOKFA has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, BOKFA has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Fees and Compensation Program Fees Program fees will be charged on a “wrap fee” basis, which means you pay an annual asset-based fee that covers investment advisory services and transaction costs (see Wrap Fee Pricing Compared to Alternative Options). Your Program Fee covers transaction, brokerage, clearing, recordkeeping, custody, and sponsor fees. The Advisory Fee is not apportioned to any individuals; it is retained by BOKFA. For the services provided in the Program, you will pay to us an annual asset-based fee at the rate of 0.70%. The fee is payable monthly in arrears for the Program. At the sole discretion of BOKFA, fees may be negotiated based upon any number of factors. New accounts are assessed an initial Program fee on a pro-rata basis from the date the account is activated through the end of the billing period. An account is considered activated when it is funded at the required minimum level of assets for the Program. After the initial Program fee, the monthly Program fee will be calculated and charged to your account based on the average daily balance in your account during the previous month. The fair market value of assets is determined in good faith by Pershing (i.e., the closing price of each security on the principal exchange on which it is traded or, if not listed, by consulting other exchange or valuation services). Program fees deducted from your Account will be shown on your Pershing statements. BOKFA InvestOn™ Brochure | 8  The average daily balance is defined as: The average amount that exists in an account over a period of time. The number is calculated by adding the daily balances over a period of time and dividing by the total number of days in that period. The average daily balance is often seen as a more accurate reflection of the total funds in your account when calculating the total fees for a billing period. Termination of Client Agreements You may end your managed account relationship with us without penalty at any time. BOKFA does not impose termination fees. If you end this relationship or close any of your accounts, any fees you paid in advance that are unearned by us will be promptly refunded to you. Fees will be calculated on a pro-rata basis for the calculation of refunds or additional fees that may be due BOKFA, if the account is closed within the billing period. You will be responsible for termination fees imposed by Pershing, if applicable. (See IRA Account Fees) We reserve the right to terminate, at our sole discretion, any client account that we feel has engaged in excessive, extreme, or unsuitable trading. We may also terminate any account that we feel no longer meets our compliance requirements. Should the account be terminated due to the death of the account holder, fees will stop being charged as of the date of death. Fees paid in advance beyond this date will be refunded. Transactions may occur in discretionary accounts until BOKFA is notified of the account holder’s death. Other Fee Information In the Program, you may make deposits and withdrawals at any time, subject to maintenance of the account minimum. No adjustment will be made for appreciation or depreciation in the market value of an account during the billing period. You may see percentages shown as “basis points” in some documents you receive. To explain, 1% is equal to 100 basis points (bps), so for example 0.70% is equal to 70 bps and 1.75% is equal to 175 bps. It is possible a similar investment management style may be offered at a lower price in another BOKFA program or in other programs provided by different investment advisers. Wrap Fee Pricing Compared to Alternative Options A “wrap fee program” is one where you pay one combined fee for your advisory and management services as well as trading, execution, and custody fees. The fees are “wrapped” into one total fee. You may pay more or less than you would pay if you purchased these services separately. Clients may be able to obtain some or all the services available through the Program on a stand-alone basis from other firms. Factors that impact the cost of the Program in relation to the cost of the same services purchased separately include, but are not limited to, the type and size of the account, the size or number of trades for an account, the types of investments held in the account, and the number and range of ancillary advisory or other services provided to an account. Performance-Based Fees and Side-by-Side Management BOKFA does not charge performance-based fees or conduct side-by-side management for any accounts in the Program. Additional Expenses You May Pay Including Brokerage and Other Transaction Costs Mutual Fund Fees Mutual fund shareholders will pay a pro-rata share of the fund’s advisory, administrative, distribution, and shareholder servicing fees. Distribution and shareholder servicing fees may be referred to as service fees, 12b-1 fees, or trail commissions (collectively “trails”). In general, the share classes that are eligible for the Managed Account Programs do not have associated sales or 12b-1 charges. However, there are some mutual funds available in the Programs that do have associated 12b-1 fees due to share class availability (i.e., there are not share classes available that do not include such fees). In such instances, BOKFS does not retain 12b-1 fees for the funds that pay them. The 12b-1 fees received by BOKFS will be credited back to your account, with one exception. Several money market funds available for your account provide remuneration to BOKFS. The payments received by BOKFS from the money market fund may include Services Fees, Administration Fees, Revenue Share, and/or Networking Fees. These money market fees are often bundled into one payment to BOKFS. If the 12b-1 fees are not segregated it is not possible to credit them back to your account. This presents a conflict of interest. A full description of the money market funds, and their fees and expenses BOKFA InvestOn™ Brochure | 9  are available in each fund’s prospectus. Contact your Advisor or the Firm at 877-781-6889 to ask about money market fund options that do not pay us a fee that may be available. If you intend to hold mutual funds for an extended period of time, you may find it more economical to buy fund shares that do not charge 12b-1 or service fees. You may be able to purchase mutual funds directly from a mutual fund family without incurring our advisory fee. If buying directly from a mutual fund family, you may incur front- or back-end sales charges, and you will not receive the management experience and guidance described in this Brochure. Certain share classes of mutual funds available in the MF/ETF Programs are charged a “surcharge” by our clearing firm, Pershing. The fund surcharge is assessed each time a buy or sell transaction is made in a fund to which a surcharge applies. The Advisor Select Flex Program reserves the right to not include share classes of mutual funds that result in the application of a surcharge and anticipates that it will avoid inclusion of such funds in the Program. This creates a conflict of interest, as certain investment share classes available through the Advisor Select Flex Program will be more expensive than a share class that the investor might be eligible to own or for similar products that might be available elsewhere. The original CPS Program does not currently limit inclusion of an investment based on the application of a surcharge. The CPS Program is not available to clients that do not already have assets invested in the CPS Program. At this time, any fund surcharge applicable to the MF/ETF Programs will be paid by the Firm. The MF/ETF Programs may include mutual funds that participate in Pershing’s FundVest program. FundVest offers no- load (and load-waived) mutual funds with a waiver of any transaction or surcharge, subject to certain restrictions on short term trading. Pershing, in its sole discretion, may add or remove mutual funds from the FundVest program without prior notice. BOKFA has conflicts of interest associated with its participation in the FundVest program. The mutual funds that participate pay Pershing fees to be in the program. BOKFA is eligible to receive a fee off-set based on the assets held in mutual funds participating in the FundVest program. Share classes of certain funds in the FundVest program are more expensive than the share classes of the same or similar funds offered outside of the FundVest program. BOKFA addresses the conflicts of interest by not sharing FundVest revenue with individuals making recommendations and monitoring trading activity. Cavanal Hill Fund Fees Your account may be invested in the Cavanal Hill Mutual Funds (“CH Funds”). BOKFA and certain of its affiliates receive fees for providing services to the CH Funds. Please refer to the section below entitled “Investment Companies and Pooled Investment Vehicles” for more information about these service and fee arrangements. A full description of the CH Funds and their fees and expenses are available in each fund's prospectus. The prospectus for each may be viewed at http://www.cavanalhillfunds.com. If your account has balances that “sweep” to a money market fund daily, the default money market fund is a CH Fund. These sweep funds do pay a percentage (in basis points) to BOKFS, which presents a conflict of interest. Other money market funds are available for you to choose, some of which do not pay a fee to us. Contact us at 877-781-6889 to ask about other options that may be available. IRA Account Fees IRA accounts in the Program will be subject to the following fees imposed by Pershing: Account Type Annual Maintenance Fee Termination or Transfer Fee Traditional IRA, Roth IRA, Coverdell Education Savings Accounts, and IRS Model 5305 SEP Accounts1 $55.00 $95.00 SAR-SEP/Prototype SEP, SIMPLE IRA2 $58.50 Qualified Retirement Plans $75.00 $95.00 $95.00 BOKFA InvestOn™ Brochure | 10  Please note that annual fees are not prorated for an account closed prior to its anniversary. 1 Invoiced annually, charged in arrears 2 Due at account setup, invoiced annually. Could be $125.00 depending on your QRP type. IRAs are subject to eligibility requirements and annual contribution limits. You are responsible for ensuring your eligibility and that contributions do not exceed applicable IRS limits. Please consult your tax advisor or a BOKFA advisor with contribution limit questions. Administrative Fees Certain administrative fees charged by Pershing are passed on to you as separate charges that are not covered by the Program Fee. Currently there is a paper delivery surcharge for statements, confirms, notifications, or quarterly performance reports, if applicable, of $2.00 per month per account. This fee accrues monthly and is charged quarterly. This charge may be adjusted to reflect changes in postage or other cost factors. This fee can be avoided by enrolling in E-delivery for statements, confirms, notifications, and quarterly performance reports, if applicable. Similarly, there is an annual paper fee of $10 per year for the receipt of tax documents in paper form. Any account that elects to receive paper tax documents will be subject to the paper fee. The paper fee will accrue as of December 31 and be assessed the following March. This fee can be avoided by enrolling in E-delivery for tax documents. Some fees charged by Pershing to you may be “marked-up” by BOKFA and that mark-up will be paid to BOKFA. We feel these fees are still within normal industry practices. These include items such as: Inactive account fees • Account transfer fees • Fed fund wire fees • IRA custodial fees • Stop payment and returned check fees • • Mandatory reorganization fees • Tax lot fees • Foreign received and deliver fees You may also pay for administrative and transaction fees not related to the management of your account(s). These include such fees as charges for returned checks or wires sent at your request that are not related to the opening or servicing of your account. All charges outlined in this section are subject to change without prior notice. Other fees that may not be covered by the Program Fee include: • Certain dealer markups and odd-lot differentials • Taxes • Exchange fees charged to clients to offset fees we pay to exchanges and/or regulatory agencies on certain transactions • Other charges imposed by law with regard to any transactions in the account (not commissions) • Offering concessions and related fees for purchases of public offerings of securities as more fully disclosed in the prospectus • Execution expenses associated with trades affected by broker-dealers other than Pershing Item 5. Account Requirements and Types of Clients Electronic Relationship Clients will complete a Risk Profile Questionnaire, open an account, and sign or acknowledge Program documents, including the Client Agreement and this Brochure, electronically through the Program website or electronic delivery. BOKFA InvestOn™ Brochure | 11  Clients must agree to accept electronic delivery of contracts, disclosure documents, prospectuses, statements, and other materials. Assistance from a BOKFA advisor is available by telephone or email, as necessary, upon Client request. Types of Clients The Program is most appropriate for clients who want investment management solutions but are not interested in being involved in day-to-day investment selections. The Program is generally available to individuals, IRA accounts, and joint accounts. Program Minimums The minimum investment requirement for your account in the Program is $1,000. We may change this minimum at any time. Item 6. Portfolio Manager Selection and Evaluation Advisory Business The investment selection aspect of the Program is professionally managed by BOKF, NA’s Strategic Investment Advisors (SIA). SIA provides the research and analytics that build the foundation for investment services within BOK Financial Corp. Asset allocation research, manager selection and oversight, and market analysis conducted by the group is utilized by BOKFA to deliver sophisticated investment solutions for clients. SIA establishes, monitors, and updates target asset allocation models as deemed necessary. Methods of Analysis In reviewing and/or managing investment solutions for you, SIA utilizes a combination of quantitative and qualitative analysis for research and evaluation of investments for inclusion in the Program. Selection Process The initial universe for investments is the Morningstar mutual funds and exchange traded funds database, with the universe limited to include those fund families that currently have a selling agreement with BOKFS or an established business relationship with BOKFA. We may pursue selling agreements with fund companies that meet our criteria but for which we do not yet have a business relationship. Our screening process checks such quantitative areas as the fund’s history, manager tenure, amount of assets under management, ranking compared to other funds in their peer category, and the performance of the fund as compared to others in their peer category. Qualitative areas we may review include the investment team, philosophy, and process of the strategy. Ongoing Monitoring/Due Diligence Our monitoring process is performed quarterly to ensure the funds chosen still meet the criteria established by SIA. Removal Process Funds that no longer meet our criteria over a period of time will be removed. BOKFA will use its discretion to invest in replacement funds. Affiliated Managers BOKF, NA Strategic Investment Advisors As discussed above, the investment selection aspect of the Program is professionally managed by an affiliate of BOKFA, BOKF, NA’s Strategic Investment Advisors. BOKFA Managers Because BOKFA acts as the sponsor and investment adviser of our wrap fee programs and is also a broker-dealer (BOKFS) for your accounts, there is a conflict of interest. BOKFA understands we owe you a fiduciary duty and that your BOKFA InvestOn™ Brochure | 12  interests come first. With that in mind, we strive to choose the investment allocation strategy that best fits your needs regardless of the compensation received by BOKFA or our affiliates. BOKFA offers discretionary advisory services through the Program. This means you delegate investment discretion (through a limited power of attorney) to us over your account(s). A limited power of attorney does not give us authorization to withdraw funds (other than for payment of your fees) or to send funds to any place other than your address of record without your signature. Risk of Loss Investing in securities involves the risk of loss. Diversification and asset allocation can help reduce the risk of a portfolio, but they do not remove all risk or chance of loss of the principal amount invested. You should be prepared to bear this loss. No investment strategy is guaranteed to be successful or profitable. Stated goals and objectives are not guaranteed and may not be achieved. Past performance does not guarantee future results. Because of these risks, the value of the securities held in your account will fluctuate. The more risk you are comfortable with in your portfolio, the more susceptible to these risks your investments will be. If you have a very conservative portfolio, many of these risks will not be applicable to your investments, although you may still face the possible loss of some of your principal. Program accounts can be subject to the following risks: • Alternative Strategy Mutual Funds. Certain mutual funds available invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes, and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. These types of funds tend to have higher expense rations than more traditional funds. They also tend to be newer with less of a track record. • Business Risk. These are risks associated with a particular industry or company. A company or industry may need to go through a lengthy process before realizing a profit or may be particularly affected by political events in foreign countries. A utility company, for example, generates income from a steady stream of customers who need its product, no matter what the economy is like. • Credit Risk. The risk that the issuer of a security, or the counterparty to a contract, will default or otherwise become unable to honor a financial obligation. Credit risk is generally higher for non- investment grade securities. The price of a security can be adversely affected prior to actual default as its credit status deteriorates and the probability of default rises. Credit risk includes the risk that performance may be affected by political and economic factors at the state, regional or national level, including budgetary problems and declining tax bases. • • • • • • Currency Risk. Fluctuations in the value of the dollar against the currency of the investment’s originating country will cause fluctuations in the price of the investment. This may also be referred to as exchange rate risk. Income Risk. Income risk involves the possibility that the Fund’s yield will decrease due to a decline in interest rates. Inflation Risk. With inflation, a dollar today will not buy as much as a dollar next year. Purchasing power is eroded at the rate of inflation. Interest Rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For example, there is an inverse relationship between the yields on bonds and interest rates. When interest rates rise, the yields on bonds you own may become less attractive, causing market values to decline. Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by BOKFA) will be profitable or achieve any specific performance level(s). Issuer Specific Risk. The value of a security may decline for a number of reasons which directly relate to BOKFA InvestOn™ Brochure | 13  the issuer, such as management performance, earnings and sales trends, investor perceptions, financial leverage and reduced demand for the issuer’s goods or services. • Leveraged Mutual Funds. Leveraged mutual funds are designed to provide a multiple of the underlying index’s return, typically on a daily basis. These products are different from and can be far riskier than a traditional mutual fund. These products are designed to replicate the performance of the underlying index but they may not be able to exactly replicate because of underlying fund expenses and other factors. In highly volatile markets with large positive and negative swings, return distortions are magnified over time. To accomplish their objectives, this type of product uses a range of strategies, including swaps, futures contracts and other derivatives. These products may have higher expense ratios and be less tax-efficient than more traditional mutual funds. • Liquidity Risk. Liquidity refers to the ability to readily convert an investment into cash. A money market account is highly liquid but turning real estate into cash takes more time and has transaction costs. Thus, real estate is not considered a liquid investment. • Market Risk. The risk that the market value of a security may move up and down, sometimes rapidly and unpredictably. This type of risk is caused by external factors independent of the security’s underlying circumstances. Examples include political, economic and social conditions that may trigger market events. This is particularly applicable to foreign investments. • Options. Certain types of option trading are permitted in order to generate income or hedge a security held in the account. The types of option trading generally permitted include the selling (writing) of covered call options or the purchasing of put options on a security held in the account. The use of options involves additional risks. The risks of covered call writing include the potential for the market to rise sharply. If this happens, the security may be called away and the account will no longer hold the security. The risk of buying long puts is limited to the loss of the premium paid for the purchase of the put if the option is not exercised or otherwise sold by the account. • Prepayment/Call Risk. The risk that the principal repayment of a security will occur at an unexpected time. Prepayment risk is the chance that the repayment of certain types of securities (e.g., asset-backed securities, mortgage-backed securities and collateralized mortgage obligations) will occur sooner than expected. Call risk is the possibility that during periods of falling interest rates, a bond issuer will “call” — or repay — their high-yielding bonds before the bond’s maturity date. Changes in prepayment/call rates can result in greater price and yield volatility. Prepayments/calls generally accelerate when interest rates decline. When mortgage and other obligations are pre-paid, a Fund may have to reinvest in securities with a lower yield. In this event, the Fund would experience a decline in income — and the potential for taxable capital gains. Further, with early prepayment, a Fund may fail to recover any premium paid, resulting in an unexpected capital loss. Prepayment/call risk is generally low for securities with a short-term maturity, moderate for securities with an intermediate-term maturity, and high for securities with a long-term maturity. • Reinvestment Risk. This is the risk that proceeds received in the future from investments may need to be reinvested at a potentially lower rate of return or interest rate. This risk relates primarily to fixed income securities. BOKFA and its affiliates perform investment advisory services for other clients. BOKFA and its affiliates may give advice or take action in the performance of duties to other clients that may differ from advice given, or the timing and nature of action taken, with respect to the Program, and BOKFA and its affiliates and their respective clients may trade and have positions in securities of issuers where the Program may own equivalent or related securities, and where action may or may not be taken or recommended for the Program. BOKFA and its affiliates shall not be under any obligation to purchase or sell, or recommend for purchase or sale for the Program, any security or any other property that BOKFA or any of its affiliates may purchase, sell or hold for its own account or the account of any other client. Because rebalancing often results in selling assets that have appreciated, rebalancing may result in tax implications for non-qualified accounts. Item 7. Client Information Provided to Portfolio Managers BOKFA InvestOn™ Brochure | 14  As part of the online enrollment process, BOKFA collects certain nonpublic personal identifying information about you and your financial circumstances, risk tolerance, time horizon, and other relevant information relating to your account. We will rely on information you provide in managing your assets. It is your responsibility to notify us promptly of any updates to such information. You can do this by updating your account information through the Program website or by phone at 1-877-781- 6889. Failure to do so could affect the suitability of the services being provided. In the Client Agreement, you represent that the information that you provide is accurate and complete in all material respects. We will not be required to verify the accuracy of any such information. We also collect information about your account, such as, account number, account investment objective, account holdings, and related account transactions. Information that is material to the management of your account(s) is accessible to investment managers that are available to discuss the management of your Program account. This may include your risk tolerance, time horizon, investment objectives, financial information as it relates to the account you are opening, your name, address, Social Security number, etc. We do not disclose the nonpublic personal information we collect about you to anyone except to service our business relationship with you, to market possible services that may be of interest to you through BOKFA or our affiliates, and as required by law. Our privacy policy, which may be amended from time to time, is provided in Exhibit A. Item 8. Client Contact with Portfolio Managers BOKFA does not place any restrictions on a client’s ability to contact a BOKFA Investment Advisor Representative (“IAR”), within reason, during normal business hours. Clients have the ability to discuss the management of their Program account with an IAR, including the activities of the Portfolio Managers. BOKFA personnel will endeavor to contact you shortly after account opening to answer any questions you may have and provide information regarding the asset allocation models. Item 9. Additional Information Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of BOKFA or the integrity of BOKFA’s management. The following is a summary of such disclosures. You can find additional information regarding these settlements in Part 1 of BOK Financial Securities’ ADV at: adviserinfo.sec.gov/IAPD. Note that BOK Financial Securities was formerly known as BOSC, Inc. • On December 3, 2024, FINRA signed a letter of Acceptance, Waiver, and Consent (“AWC”) issued to BOKFS. Without admitting or denying the findings, BOKFS consented to the sanctions and to the entry of findings that it inaccurately reported approximately 24,200 transactions in TRACE-eligible securities that did not include a mark-up, mark-down, or commission without the required no remuneration (NR) indicator. As a result, BOKFS was censured and fined $110,000. • On March 11, 2019, the SEC filed an order instituting administrative and cease-and-desist proceedings against BOKFS (the “Order”). BOKFS consented to the Order without admitting or denying the findings. The proceedings arose out of breaches of fiduciary duty and inadequate disclosures by the firm in connection with its mutual fund share class selection practices and the fees BOKFS and its associated persons received pursuant to Rule 12b-1 under the Investment Company Act of 1940 (“12b-1 fees”). At times during the period January 1, 2014 to July 6, 2018 (the “Relevant Period”), Respondent purchased, recommended, or held for advisory clients mutual fund share classes that charged 12b-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. Respondent and its associated persons received 12b-1 fees in connection with these investments. Respondent failed to disclose in its Form ADV or otherwise the conflicts of BOKFA InvestOn™ Brochure | 15  interest related to (a) its receipt of 12b-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. The violations were self-reported by BOKFS under the SEC’s Share Class Selection Disclosure Initiative. BOKFS will pay $182,318.31 in disgorgement and $15,482.92 in prejudgment interest as a result of the violations in accordance with the standards set forth in the Order. In addition, BOKFS will review its disclosure documents, client accounts and policies and procedures and will make changes reasonably designed to prevent future violations of the Advisers Act and will notify affected investors. • On September 2, 2017, FINRA signed a letter of Acceptance, Waiver, and Consent (“AWC”) issued to BOKFS. BOKFS consented to the AWC without admitting or denying the allegations. The allegations related to the firm’s failure to maintain approximately 732,000 electronic brokerage records in a non-erasable and non-rewriteable format, known as WORM format, as required by Section 17(A) of the Exchange Act of 1934, Exchange Act Rule 17A-4(F), NASD Rule 3110, and FINRA Rule 4511. FINRA also alleged the firm failed to implement an audit system regarding retaining and preserving electronic records. Finally, FINRA alleged that the firm’s written supervisory procedures were not reasonably designed to achieve compliance with Rule 17A-4(F). As a result, the firm was censured and fined $175,000. • On September 9, 2016, BOKF, NA (“BOKF”), an affiliate of BOK Financial Securities, Inc., entered into a consent decree (the “Consent Decree") with the Securities Exchange Commission (the “SEC”). BOKF neither admitted nor denied the findings of the Consent Decree. This matter relates to BOKF’s relationship with Christopher Brogdon, who has been accused by the SEC of violating antifraud provisions of the federal securities laws. BOKF served as indenture trustee and dissemination agent for several conduit municipal bond offerings for which Mr. Brogdon's entities acted as borrower since 2000. The Consent Decree states that BOKF, primarily through the actions of a former employee, allowed Mr. Brogdon to perpetuate his fraud by failing to perform disclosure and notice obligations it owed to bondholders. BOKF agreed to pay disgorgement of $984,200.73 of the fees it collected from its work with Mr. Brogdon. Additionally, BOKF also agreed to pay interest totaling $83,520.63 and a penalty of $600,000. BOKF has also undertaken to enhance its policies, procedures, and training in order to prevent such an event from occurring again. • On October 21, 2015, FINRA signed an Acceptance, Waiver and Consent (AWC) issued to BOSC. BOSC consented to the AWC without admitting or denying the findings. FINRA’s Department of Market Regulation reviewed BOSC’s compliance with FINRA rules governing markup/markdown during the period from July 1, 2013 through September 30, 2013. As a result of its reviews, the Department of Market Regulation determined that BOSC violated NASD Conduct Rules 2440, IM-2440-1 and IM-2440-2, and FINRA Rule 2010. During the review, BOSC bought or sold corporate bonds to or from customers and failed to buy or sell such bonds at a price that was fair, taking into consideration all relevant circumstances, including market conditions with respect to each bond at the time of the transaction, the expense involved and that the firm was entitled to a profit. The transactions resulted in a censure; a fine to BOSC of $12,500; and restitution for eight transactions totaling $4873.96 (including interest). The fine was paid by BOSC to FINRA on 11/10/2015 and the restitution to clients was sent on 11/23/2015. • On June 18, 2015, the SEC filed an order instituting administrative and cease-and-desist proceedings against BOSC (the “Order”). BOSC consented to the Order without admitting or denying the findings. This matter involved violations of an anti-fraud provision of the federal securities laws in connection with BOSC’s underwriting of certain municipal securities offerings. The SEC found that BOSC conducted inadequate due diligence in certain offerings and, as a result, failed to form a reasonable basis for believing the truthfulness of certain material representations in official statements issued in conjunction with those offerings. This resulted in BOSC offering and selling municipal securities on the basis of materially misleading disclosure documents. As a result, the SEC found that BOSC willfully violated Section 17(a)(2) of the Securities Act. The violations were self-reported by BOSC to the SEC pursuant to the Division of Enforcement’s Municipalities Continuing Disclosure Cooperation Initiative. BOSC paid a civil monetary penalty of $250,000.00 to the SEC. In addition, BOSC agreed to retain an independent consultant, approved by the SEC, to conduct a review of BOSC’s policies and procedures as they relate to municipal securities underwriting due diligence. The independent consultant BOKFA InvestOn™ Brochure | 16  prepared a written report of its findings and submitted it to the SEC, which included the independent consultant’s recommendations for changes in or improvements to BOSC’s policies and procedures. All agreed- upon recommendations from the independent consultant were adopted by BOSC within 90 days of the date of the report. The independent consultant submitted a final certification, in writing, to the SEC of BOSC’s compliance with the required undertakings no later than 365 days from June 18, 2015. The final certification showing compliance with the required undertakings was submitted to the SEC on June 16, 2016. Other Financial Industry Activities and Affiliations BOKFA engages in a number of financial industry activities and is affiliated with other firms in the financial industry. Following is a description of material relationships and affiliations that are important to us and to you. In each category, the relationships and affiliations are identified and material conflicts of interest are discussed. BOK Financial Securities, Inc. - Broker-Dealer. The principal business of BOKFS is that of a general securities broker- dealer, government securities seller, and municipal securities underwriter. BOKFS is a registered broker-dealer, member FINRA and SIPC. Many of our principal executive officers, investment committee members, and the individuals who determine general investment advice may also be registered representatives with the broker-dealer. In this capacity, these registered representatives may recommend investments and insurance products outside of this Program for which they receive reasonable and customary compensation. The opportunity to receive additional compensation for effecting securities transactions or selling insurance products outside of this Program or purchasing securities in the Program that pay additional compensation to us or our affiliates (e.g., 12b-1 fees, etc.) represents a conflict of interest. Other conflicts of interest are disclosed throughout this Brochure. A BOKFA Advisor may have an economic incentive for recommending this Program. The amount of the incentive may be more than what the BOKFA Advisor would receive if you participated in other programs offered by BOKFA; paid separately for investment advisory services, brokerage, and other services; or invested in other types of investments; therefore, the BOKFA Advisor would have a financial incentive (a conflict of interest) to recommend this Program over other offerings or services. Investment Company or Other Pooled Investment Vehicle. BOKFS is affiliated with the Cavanal Hill Mutual Funds (“CH Funds”). Shares in each CH Fund are sold by BOKFS. Customers purchasing shares of CH Funds may include officers, directors, or employees of BOKFS and its affiliates. For the provision of distribution and shareholder services, BOKFS will receive 12b-1 and shareholder servicing fees from CH Funds. The 12b-1 fees that BOKFS earns on advisory accounts are rebated. Cavanal Hill Investment Management (“CHIM”) serves as the investment adviser and administrator to the CH Funds. CHIM receives investment advisory and administrator fees for the services it provides to the CH Funds. In addition, BOKF, NA serves as CH Fund’s custodial bank and also provides distribution and shareholder services to CH Funds. BOKF, NA receives custody, 12b-1 and shareholder services fees for these services. CH Funds are included as investments in some client accounts and certain CH Funds serve as the default sweep vehicle for Program accounts in the Program. In this instance, CH Funds, CHIM, and its affiliates, would earn the aforementioned fees in addition to the fees charged to the client for participation in the Program. A more detailed description of the available CH Funds and other fees and expenses are available in each fund's prospectus. This presents a conflict of interest since not all clients are eligible to purchase the sweep funds offered by CH Funds and BOKFA and its affiliates will earn fees in addition to those charged to you directly for your participation in the Program. Investment Adviser or Financial Planner. Cavanal Hill Investment Management (“CHIM”) is a registered investment adviser affiliate of BOKFA. BOKFS will receive compensation if BOKFA or one of its representatives introduces a client to CHIM. Such a fee will be paid in accordance with Rule 206(4)-1 of the Advisers Act and any state or other regulatory requirements. BOKFA employees are required to disclose the status of their relationship with CHIM at the time of the solicitation or referral. For more information on referral and solicitation arrangements, see the “Client Referrals and Other Compensation” section of this Wrap Fee Program Brochure. BOKFA InvestOn™ Brochure | 17  Investment Adviser or Financial Planner. BOK Financial Private Wealth, Inc. is a registered investment adviser affiliate of BOKFA and is a wholly-owned subsidiary of BOK Financial Corporation. Banking or Thrift Institution. BOK Financial Corporation, a financial holding company, owns all of the capital stock of BOKFS. BOKF, NA is the wholly-owned national banking association subsidiary of BOK Financial Corporation. Customers of BOKF, NA may also be customers of BOKFA. BOKF, NA’s SIA group manages the investment selection aspect of the Program. The BOKFA account documents and other communications with customers clearly disclose that investments made through BOKFA are not obligations of, or guaranteed by, BOKFS, BOKFA, BOKF, NA or any bank affiliate and investments made through BOKFA are not deposits of any bank or insured by the Federal Deposit Insurance Corporation (FDIC) or any other government agency. In addition, all investments may lose money, and you are not guaranteed a profit. Some employees of BOKFA are also employees of or registered with our affiliates. Insurance Company or Agency. Some BOKFA Advisors are licensed to sell insurance products through BOSC Agency, Inc., BOK Financial Securities, Inc. and BOSC Insurance Services, affiliated insurance agencies. Fixed insurance products are not included in the Program accounts. Properly licensed individuals may present insurance products to you that they believe will meet your financial objectives and liquidity needs. If purchased, these individuals will receive reasonable and customary commissions outside of any advisory fees they earn on your Program accounts. Municipal Advisors. BOK Financial Securities, Inc. is registered as a municipal advisor with the SEC and the MSRB. Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading BOKFA has adopted a Code of Ethics describing its standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to prohibitions on insider trading, restrictions on the acceptance of gifts and the requirement to report certain gifts and personal securities trading, among other things. All employees of BOKFA must acknowledge the terms of the Code of Ethics annually. BOKFA will provide a free copy of its Code of Ethics to clients and prospective clients upon request. BOKFA anticipates that securities may be purchased or sold in advisory accounts in which BOKFA, its employees and affiliates, and clients, directly or indirectly, also own. BOKFA employees are required to follow BOKFA’s Code of Ethics in conducting their personal securities transactions. Subject to satisfying this policy and applicable laws, officers, directors and employees of BOKFA may trade for their own accounts in securities that are also recommended to and/or purchased for BOKFA clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of employees of BOKFA will not interfere with (i) making decisions in the best interest of clients, and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that such securities would not materially interfere with the best interest of BOKFA’s clients. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code of Ethics in an effort to reasonably prevent conflicts of interest between BOKFA and its clients. Our Code of Ethics does not have “black-out dates” so our employees may buy or sell the same security as you at a better price on occasion. We endeavor to watch this and normally prohibit the employee from receiving a better price than you do for transactions involving the same security within a 24-hour time period. If the difference is non-material in nature (usually defined as $10 or less in total and not price per share), then no adjustments are made to either account. BOKFS, as broker-dealer and as principal, buys securities for itself from, or sells securities it owns to, its non-advisory BOKFA InvestOn™ Brochure | 18  clients. We will not act as principal in a transaction involving advisory accounts. In rare circumstances, we may effect a transaction in which BOKFS acts as a broker for both the advisory client and the other party to the transaction. If this occurs, we will obtain consent from you, and will disclose all material information regarding the transaction to you, as required under Rule 206(3)-2 of the Advisers Act. Soft Dollar Benefits BOKFA does not participate in soft dollar benefits. Although our affiliate, Cavanal Hill Investment Management, does participate in soft dollar benefits for some of its transactions and clients. The BOKFS clearing arrangement with Pershing LLC does provide BOKFS, BOKFA, and its Advisors with certain benefits. These benefits include access to custody of securities, trade execution, clearance, and settlement of transactions, as well as receipt of duplicate client statements and confirmations; research related products and tools; access to block trading; the ability to have advisory fees deducted directly from client accounts; access to an electronic network for client order entry and account information; access to mutual funds with no transaction fees; and to certain institutional money managers. While the charges you pay for the services provided by Pershing are comparable to what you would pay at other full-service brokerage firms, it is possible that you could purchase the same investments we recommend elsewhere (through brokers or agents unaffiliated with us) without these services at the same, higher, or lower costs to you. It is also possible that BOKFS may choose to remain with Pershing LLC as a clearing firm because of these services even though it may increase our costs. BOKFS follows the regulatory requirements for best execution and Pershing LLC remains well within the industry norms for execution and pricing. Best Execution As an SEC registered introducing broker-dealer, BOKFS routes all orders through Pershing for the Program. We are obligated to seek best execution pursuant to our fiduciary duty as an SEC registered investment adviser and under FINRA Conduct Rule 2320 for all trades executed. Better executions may be available via another broker-dealer based on such factors as volume, order flow, and the market making activity of the other broker-dealer. We endeavor to put the interests of our advisory clients first, but you should be aware that the receipt of economic benefits by BOKFS (or its related persons) creates a conflict of interest. Review of Accounts We rely on you to provide accurate information on the Risk Profile Questionnaire and to provide updates when changes to your financial situation or investment objectives occur. You will make the final decision with respect to the investment strategy and Program. We shall periodically contact you to request updated information or confirm the information we have on file, and we rely on you to provide us this information. Client Reporting At a minimum, clients will receive quarterly account statements from Pershing. Pershing will provide quarterly statements that include a summary of account activity and an inventory of holdings. The statements for taxable accounts include a summary of realized gains, dividends, interest and Program Fees deducted from your account(s). Clients should always review their statements for unauthorized withdrawals. We do not verify the accuracy of any performance information provided to you by affiliated or non-affiliated investment managers, nor do we verify its accuracy or compliance with presentation standards. We also do not hire a third party to verify performance calculations. Performance information may be calculated in different manners by different investment managers, thus the information you receive may not be calculated on a uniform or consistent basis between managers. Client Referrals and Other Compensation Referrals to BOKFA. You may have been introduced to BOKFA by either a non-affiliated, affiliated, or employee promoter, and we may pay that promoter a referral fee in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any state or other regulatory requirements. The referral fee shall be paid solely from the Program Fee BOKFA InvestOn™ Brochure | 19  and shall not result in any additional charges to you. If you are introduced to BOKFA by a non-affiliated promoter, they should provide you with a copy of the BOKFA promoter’s disclosure statement containing the terms and conditions of the referral arrangement, including compensation. Any affiliated or employee promoter of BOKFA shall disclose the nature of the relationship to prospective clients at the time of the referral and provide all prospective clients with a copy of BOKFA’s promoter’s disclosure statement at or prior to the time a client agreement is executed. BOKFA does not receive client referrals from Pershing. Mutual Fund Fees. BOKFA has fee arrangements with some mutual fund companies that issue mutual funds that are available through the Program as cash “sweep” vehicles. These payments are often referred to as “revenue sharing.” Under these revenue sharing arrangements, the mutual fund company can pay BOKFA a fee that is based on: 1. The amount of client sales; 2. Assets invested in the mutual company’s mutual funds; and/or 3. A fixed fee. The actual amounts that we may receive will vary from one mutual fund company to another and may have minimum dollar amounts prior to BOKFA being eligible to receive a revenue sharing payment. In all cases, such revenue sharing payments will not be paid from client funds or assets, they will be paid out of the related party’s assets. Such arrangements will have no impact on the fees being charged to clients in the Program. This type of fee arrangement creates a conflict of interest by providing BOKFA a financial incentive to have clients invest in participating mutual funds instead of mutual funds whose mutual fund company does not have such revenue sharing payments available to us. BOKFA does not share revenue sharing payments with its Advisors. Therefore, there is no financial incentive for an Advisor to select a participating mutual fund for the Program over another mutual fund because of a revenue sharing arrangement. BOKFA Referrals to Cavanal Hill Investment Management. In addition, BOKFA and Cavanal Hill Investment Management have entered into a Solicitation Agreement where CHIM agrees to pay BOKFA a fee for the referring, soliciting, and ongoing client servicing of CHIM clients. The fee is based on CHIM’s revenues attributable to the client account placed with them. This is a revenue sharing fee that continues until the client is no longer a client of CHIM. The fee will be paid in accordance with relevant regulatory requirements, including Rule 206(4)-1 of the Advisers Act, and any state or other regulatory requirements. A conflict of interest exists because BOKFA is incented to refer its clients to an affiliate, who in turn shares the revenues associated with the referred account with BOKFA. Other Referrals. Employees of BOKF, NA and BOKFA may introduce clients to other services offered by BOKF, NA or its affiliates. As a result of this referral, the employee may receive a fee. This fee may range from a nominal amount to a percentage of the anticipated revenue for the account over a set period of time. These payments are not added to client fees, but are deducted from the revenue received by BOKF, NA, BOKFA, or an affiliate. These referral payments are paid as allowed according to banking regulations and do not affect the fees clients pay BOKFA. Intercompany Payments between Affiliates. BOKFA and its affiliates make certain intercompany payments to compensate each other for performing various administrative services. These may be amended or terminated at any time and are outlined in service agreements between the various affiliates. Other Compensation. Separate and apart from the Program, BOKFS earns commissions as a broker/dealer and BOKFA Advisors earn commissions for investment and insurance products they sell outside of Program account(s). You may have accounts that pay commissions to a BOKFA Advisor (in their role as a registered representative) and BOKFS that are not considered a “wrap fee,” “managed”, or “advisory” account. Such compensation will be in addition to the fees charged for the Program. BOKFA Advisors and BOKFS will not earn commissions on transactions in your Program account(s). Conflicts of Interest. Since different products pay different commissions or advisory fees, BOKFA and its Advisors may be incented to recommend products based on the compensation we receive, rather than recommending the products BOKFA InvestOn™ Brochure | 20  and services that are best for you. BOKFA endeavors at all times to place your interests ahead of its own and to take into account your personal investment objectives, goals, risk tolerance, and other important financial information before recommending one or more products or services. Ultimately, the choice of whether to participate in the Program is your decision. Participation will result in discretionary trading authority for BOKFA. Financial Information BOKFA does not require or solicit prepayment of more than $1,200 in fees per client more than six months in advance; therefore, a balance sheet is not being provided. We have not been the subject of a bankruptcy petition at any time. Business Resumption The BOKFA Business Resumption Plan has been developed in order to respond and recover should a disaster occur at one or more of our offices. The plan is designed for all of our business units to be able to resume business with the least amount of interruption to the many valuable services that we provide to our customers. Our plan outlines the actions BOKFA will take in the event of a building, city-wide, or regional incident, including relocating technology and operational personnel to pre-assigned alternate regional facilities. Technology data processing can also be switched to an alternate regional data center. All BOKFA operational facilities are equipped for resumption of business and are regularly tested. Our recovery time objective for business resumption, including those involving a relocation of personnel or technology, is typically three (3) business days. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond our control. In the event of a significant business interruption, customers may call the toll-free contact numbers listed on our website, advisors.bokfinancial.com. Privacy Notice Please refer to the BOKFA Privacy Policy to find out more about what we do with your personal information. The Privacy Notice is provided at the end of this Brochure. BOKFA InvestOn™ Brochure | 21  FACTS WHAT DOES BOK FINANCIAL SECURITIES DO WITH YOUR PERSONAL INFORMATION? WHY? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The types of personal information we collect and share depend on the product or service you have with us. When you are no longer our customer, we may continue to share your information as described in this notice. WHAT? This information can include: • Information we receive from you on applications or other forms • Information about your transactions with us, our affiliates and others • Information we receive from a consumer reporting agency HOW? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons BOK Financial Securities chooses to share; and whether you can limit this sharing. REASONS WE CAN SHARE YOUR PERSONAL INFORMATION DOES BOK FINANCIAL SECURITIES SHARE? CAN YOU LIMIT THIS SHARING? NO YES For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus NO YES For our marketing purposes — to offer our products and services to you NO For joint marketing with other financial companies YES YES NO For our affiliates’ everyday business purposes — information about your transactions and experiences NO We do not share For our affiliates’ everyday business purposes — information about your creditworthiness For our affiliates to market to you YES YES For non-affiliates to market to you NO We do not share OTHER IMPORTANT INFORMATION: • Do Not Call Policy. This privacy policy constitutes have an assigned advisor or team, they may continue to contact you to assist you in managing your portfolio or account relationship. • Nevada customers – In response to Nevada law, we are providing this notice to you. You may be placed on our internal Do Not Call list by following the directions in the To Limit Direct Marketing section. For more information contact us at 1-877-781-6889 or submit the Opt Out notice to us via US Mail. You may also contact the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; 702-486-3132 or by email at BCPINFO@ag.state.nv.us • For clients of BOK Financial Securities and advisors also affiliated with a bank, credit union or other financial institution: If your account was opened in our offices located at a non-affiliated financial institution, such as a bank, thrift or credit union, and that financial institution decides to enter into a relationship with a new financial services provider, we may share your information with the new financial services provider so that your account can continue to be serviced. BOK Financial Securities’ Do Not Call Policy under the Telephone Consumer Protection Act for all consumers. BOK Financial Securities maintains an internal Do Not Call list. Do Not Call requests will be honored within 30 days and will be effective for at least five years from the date of the request. No telemarketing calls will be made to residential or cellular phone numbers that appear on the BOK Financial Securities’ Do Not Call list. You may continue to receive marketing information in regular account mailings and statements, when you visit us online or at an ATM. You may also be contacted to service your account or participate in surveys. If you • Call 1-877-781-6889 • Mail the opt-out form provided Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. TO LIMIT OUR SHARING However, you can contact us at any time to limit our sharing. To limit our direct marketing to you by mail or telephone, call 1-877-781-6889 or return the opt-out form provided. QUESTIONS? Who is providing this brochure? BOK Financial Securities and its affiliates and BOKF, NA dba Institutional Investments, BOKF, NA.  WHAT WE DO How does BOK Financial Securities protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We collect your personal information, for example, when you • seek advice about your investments • open an investment advisory or brokerage account • tell us about your investments or retirement needs How does BOK Financial Securities collect my personal information? We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only • sharing for affiliates’ everyday business purposes— information about your creditworthiness Why can’t I limit all sharing? • affiliates from using your information to market to you • sharing for non-affiliates to market to you State laws and individual companies may give you additional rights to limit sharing. Your choices will apply to everyone on your account. What happens when I limit sharing for an account I hold jointly with someone else? DEFINITIONS Affiliates Companies related by common ownership or control. They can be financial and non- financial companies. Our affiliates include companies with a common ownership under BOK Financial Corporation; and financial companies such as financial institutions, securities companies, broker-dealers, insurance companies and trust companies. Companies not related by common ownership or control. They can be financial and non-financial companies. Non-affiliates • BOK Financial Securities does not share personal information with non-affiliates so they may market to you A formal agreement between non-affiliated financial companies that together market financial products or services to you. Joint Marketing • BOK Financial Securities does not have joint marketing agreements with non-affiliated financial companies Securities, insurance and advisory services offered through BOK Financial Securities, Inc., member FINRA/SIPC and a subsidiary of BOK Financial Corporation. Services may be offered under our trade name, BOK Financial Advisors. NOT FDIC INSURED | NO BANK GUARANTEE | MAY LOSE VALUE Rev 12/20 MAIL-IN OPT-OUT FORM Please complete all information legibly so we may update our records. If information is missing, we may be unable to honor this request. Mark any/all you want to limit: Do not allow your affiliates to use my personal information to market to me. Please add me to BOK Financial Securities’ Do Not Call list. Name Address line 1 Address line 2 Mail to: BOK Financial Securities Attn: Operations P.O. Box 2300, Plaza Tulsa, OK 74192-0002 City, State, Zip Pershing Account # or Social Security # Phone Signature Date  Privacy Notice for California Residents Only Effective Date: January 1, 2020 This Privacy Notice for California Residents supplements the information contained in our foregoing PRIVACY NOTICE and applies solely to residents of the State of California under the California Consumer Privacy Act (CCPA). INFORMATION WE COLLECT 1. Categories of Personal Information. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Depending on the type of products and services you use, we may have collected, and/or disclosed the following categories of personal information within the last twelve (12) months: CATEGORY EXAMPLES OF DATA WE MAY COLLECT A. Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers B. Personal information categories A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information C. Protected classification Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, gender or veteran or military status characteristics under California or federal law D. Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Information, such as, fingerprints, faceprints, and voiceprints, physical patterns such as keystrokes and sleep, health, or exercise data E. Biometric information F. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement Internet or other similar network activity Physical location or movements G. Geolocation data Audio, electronic, visual, thermal, olfactory, or similar information H. Sensory data I. Current or past job history or performance evaluations Professional or employment- related information J. Profile reflecting preferences, characteristics, predispositions or behavior Inferences drawn from other personal information 2. You and your authorized agents Public records or government agencies Joint marketing partners Categories of Sources for Information We obtain personal information from the following categories of sources: • • Our affiliates • • Consumer reporting agencies • Consumer data resellers • Other financial institutions, clearing, fund transfer, settlement systems, etc. • Customers • • Our service providers Internet participants and social media networks • 3. Use of Personal Information We may use or disclose the personal information we collect for one or more of the following business purposes: Provide you with information, products or services • Fraud prevention • Provide you with alerts and other notices concerning our products or services • • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us Improve our websites • Testing, research, analysis and product development • • Detect, investigate, report and prevent activities that may violate our policies or be illegal, respond to law enforcement requests and as required by applicable law • To evaluate or conduct a merger, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal information held by us is among the assets transferred To hire or retain employees, consultants and service providers • • As described to you when collecting your personal information 4. Sharing Personal Information In the preceding twelve (12) months, depending on the type of products and services you use, we may have disclosed the categories of personal information listed in number 1 above for a business purpose to the following categories of third parties: • Our affiliates • Our service providers Joint marketing partners • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you • In the preceding twelve (12) months, we have not sold any personal information that is subject to the CCPA.  5. Your Right to Make Requests The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. A. Request to Know About Personal Information Collected, Used or Disclosed for a Business Purpose You have the right to request that we disclose the personal information that we have collected or disclosed for a business purpose over the past 12 months when you request any or all of the following: The specific pieces of personal information we collected about you • The categories of personal information we collected about you • The categories of sources for the personal information we collected about you • The categories of personal information that we disclosed for a business purpose • The categories of third parties to whom the personal information was disclosed for a business purpose • Our business or commercial purpose for collecting your personal information • Request to Delete Personal Information Collected by Us B. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to: • Complete the transaction for which we collected the personal information, provide a good or service that you requested, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities • Debug to identify and repair errors that impair existing intended functionality • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law • Comply with the California Electronic Communications Privacy Act • Enable solely internal uses that are reasonably aligned with expectations based on your relationship with us • Comply with a legal obligation • • Make other internal and lawful uses of that information that are compatible with the context in which you provided it C. How to Exercise Your CCPA Rights Methods: To exercise the rights described above, please submit a request to us by one of the following methods: Call us at: 877-781-6889 Visit us at: https://securities.bokfinancial.com/landing-pages/privacy-request Information to Include in the Request: Provide sufficient information that allows us to verify you are the person about whom we collected personal information • • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. For instance, state whether your request is to disclose information we have about you or delete information and identify the category or type of information that is the subject of your request. Who Can Make the Request: Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. How Often You Can Make a Request: You may make a verifiable consumer request to know or delete personal information twice within a 12-month period. D. Our Process for Responding to Your Request First, the CCPA requires us to determine that the request to know or delete personal information is made by the consumer whose information is the subject of the request. This is referred to as a verifiable consumer request. Upon receipt of your request, we may need to ask you to provide additional information either to confirm your identity or to accurately respond to your request. Once we have the information to verify and respond to your request, we will review it and determine what specific information about you should be returned to you in response to a request to know and what information must be deleted by us and our service providers in response to a request to delete. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the preceding 12-month period. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For right to know requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 6. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. 7. Contact Information If you have any questions or comments about our privacy policies and practices, please contact us at: 877-781-6889 4NC_Privacy Policy_12-20