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PART 2A
Arvest Wealth Management (CRD 42057), brochure dated March 30, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Part 2A of Form ADV: Firm Brochure
Arvest Investments, Inc.
Doing business as
Arvest Wealth Management
Physical Address:
913 West Monroe
Lowell, Arkansas 72745
Mailing Address:
P.O. Box 1515
Lowell, Arkansas 72745
Telephone: (888) 916-2121
Email: AWMSolutionsCenter@arvest.com
Web Address: https://www.arvest.com/personal/invest
March 27, 2026
This brochure provides information about the qualifications and business practices of Arvest Wealth
Management an investment adviser registered with the SEC (#801 – 63738). Please note that registration
with the SEC does not imply a certain level of skill or training. If you have any questions about the contents
of this brochure, please contact us at (888) 916-2121 or AWMSolutionsCenter@arvest.com. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Arvest Wealth Management also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. Our firm’s CRD number is 42057.
Arvest Wealth Management is the trade name used by Arvest Investments, Inc., an SEC registered
investment adviser and broker-dealer, member FINRA/SIPC, and a wholly owned subsidiary of Arvest
Bank.
Item 2 Material Changes
There have been no material changes to our Brochure since the last update dated May 23, 2025.
Consistent with the current rules, we will ensure that you receive a summary of any material changes to
this and subsequent Brochures within 120 days of the close of business’ fiscal year, which is December
31. Furthermore, we will provide you with other interim disclosures about material changes, as necessary.
the SEC’s website,
You can access additional information about our firm, management personnel, investment advisor
representatives and our most
located at
recent Firm Brochure at
https://adviserinfo.sec.gov/firm/summary/42057.
This site may also be reached through FINRA’s website, at https://brokercheck.finra.org/.
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Item 3 Table of Contents
Item 2
Material Changes .......................................................................................................................... 2
Item 3
Table of Contents.......................................................................................................................... 3
Item 4
Advisory Business ......................................................................................................................... 5
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................... 6
RETIREMENT PLAN CONSULTING .............................................................................................................. 6
FINANCIAL PLANNING SERVICES ............................................................................................................. 10
Item 5
Fees and Compensation ............................................................................................................. 11
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 11
RETIREMENT PLAN CONSULTING FEES ................................................................................................... 11
FINANCIAL PLANNING FEES .................................................................................................................... 13
Item 6
Performance-Based Fees and Side-By-Side Management ......................................................... 13
Item 7
Types of Clients ........................................................................................................................... 14
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 14
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 14
RETIREMENT PLAN CONSULTING ............................................................................................................ 14
Item 9
Disciplinary Information ............................................................................................................. 20
Item 10
Other Financial Industry Activities and Affiliations .................................................................... 20
FIRM REGISTRATIONS ............................................................................................................................. 20
MANAGEMENT PERSONNEL AND OTHER ASSOCIATES REGISTRATIONS................................................ 20
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 22
Item 12
Brokerage Practices .................................................................................................................... 24
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 24
RETIREMENT PLAN CONSULTING ............................................................................................................ 24
Item 13
Review of Accounts .................................................................................................................... 24
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 24
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RETIREMENT PLAN CONSULTING ............................................................................................................ 24
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FINANCIAL PLANNING SERVICES ............................................................................................................. 25
Item 14
Client Referrals and Other Compensation .................................................................................. 25
Item 15
Custody ....................................................................................................................................... 25
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 25
RETIREMENT PLAN CONSULTING ............................................................................................................ 26
Item 16
Investment Discretion ................................................................................................................ 26
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 26
RETIREMENT PLAN CONSULTING ............................................................................................................ 26
Item 17
Voting Client Securities ............................................................................................................... 26
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 26
RETIREMENT PLAN CONSULTING ............................................................................................................ 26
Item 18
Financial Information .................................................................................................................. 26
BUSINESS CONTINUITY PLAN ...................................................................................................................... 27
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Item 4 Advisory Business
Arvest Investments, Inc., doing business as Arvest Wealth Management (the “Firm”), is a corporation
organized under the laws of the State of Arkansas. The Firm is 100% owned by Arvest Bank, Fayetteville,
Arkansas. Arvest Bank is a wholly owned subsidiary of Arvest Bank Group, Inc. which is a corporation of
which Jim C. Walton and Samuel Robson Walton each own or control over 25%, but less than 50% of the
equity.
The Arvest mission statement: People helping people find financial solutions for life.
The Firm is an investment advisor registered with the Securities and Exchange Commission (SEC), with its
principal place of business located in Arkansas, with advisors located in Arvest Bank branches in Arkansas,
Oklahoma, Missouri, and Kansas. The Firm began conducting investment advisory business in 2004.
As of December 31, 2025, the Firm had regulatory advisory assets under management of 3,439,741,668.35
of which we managed $997,487,385.05 on a discretionary basis.
The Firm provides investment advisory services through its retirement plan consulting services and its
financial planning services, as described in this Part 2A of Form ADV (Firm Brochure). Also, through the
Firm-sponsored wrap fee programs, as further described in its Part 2A Appendix 1 of Form ADV wrap fee
program brochure (the “Arvest Wealth Management Wrap Fee Program Brochure”). The Wrap Fee
Program Brochure is provided separately to those applicable current and prospective clients.
The Firm, beginning in the third quarter 2024, started a process of written client notification and
reassignment of its agreements concerning the Retirement Plan Consulting Services’ employer-sponsored
retirement plan services from the Firm’s registered investment adviser to the Arvest Bank Trust
Department. As relayed in the notifications, this change is due to an internal restructuring and is not
intended to change clients’ experiences. The Firm’s Retirement Plan Relationship Managers are also
employees of Arvest Bank and there will be no changes in the scope of services provided or fees collected
as a result of the assignments. This process of notification and reassignment continues to the present.
Once the retirement plan relationship has completed this transition, services will no longer be delivered
through the Firm’s registered investment adviser.
The information and disclosures contained within this document are relevant for our investment advisory
clients and Retirement Plan Consulting Services clients, whose services are presently still delivered by the
Firm’s registered investment adviser.
The Firm’s Client Advisors, Retirement Plan Advisors and Retirement Plan Relationship Managers will
evaluate each client’s individual needs, financial goals, and attitudes towards risk to help the client identify
which accounts and program(s) are appropriate for the client. The services provided after the initial
recommendation will vary depending on account type and program selected. You should carefully review
each recommended advisory service with your Client Advisor to be sure you understand the nature of the
services being offered.
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Fees vary between the various services and programs offered by the Firm. This presents a conflict of
interest in that the Firm may receive higher fees from some services and programs than from others and,
because the salaries and/or bonuses of our Client Advisors and Retirement Plan Advisors (RPAs) are based
in part on production, i.e. the amount of Client Advisory fees and other revenues generated to the Firm
by their advisory client accounts, we may have an incentive to recommend higher-priced services or
programs when a comparable lower priced alternative may be available. Note, Retirement Plan
Relationship Managers’ (RPRMs) do not receive compensation directly from advisory fees, the sale of
securities or other investment products through their salary or annual bonus opportunity.
The Firm’s policies require all Client Advisors, RPAs and RPRMs to only recommend those services that are
in the best interest of each client. Furthermore, Client Advisors’ salaries are calculated and set semi-
annually. For each performance-based salary calculation, 6 months of prior production are used to
determine application of the Client Advisor’s performance to a payout grid used to set an Advisor’s salary
level. Retirement Plan Advisors (RPAs) receive a base annual salary that is not production based. However,
RPAs and Client Advisors may qualify for certain bonus opportunities that are production based.
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
The Firm offers investment advisory services (including Firm advisory and portfolio management services,
Arvest Wealth Management Portfolio Management and Research (PMR), formerly known as Investment
Management Group Portfolio Management, portfolio management of the IMG Portfolios, and third-party
portfolio management services) through the Firm-sponsored wrap fee programs:
● Arvest Wealth Management SMA Equity and Balanced Strategies
● Arvest Wealth Management SMA Fixed Income Strategies
● Arvest Wealth Management Unified Managed Account
● BNY Mellon Advisors, Inc. (BNYMA) AdvisorFlex Portfolios
● BNY Mellon Advisors, Inc. (BNYMA) Target Risk Portfolios
● Mutual Funds & ETF Strategists
●
IMG Equity & Balanced Strategies
●
IMG ETF Models
●
IMG Fixed Income Strategies
● Advisor Directed – Discretionary
● Advisor Directed-Non-Discretionary
Please refer to the Firm Wrap Fee Program Brochure for a description of sponsored wrap fee programs.
RETIREMENT PLAN CONSULTING
The Firm, through its Retirement Plan Consulting Group offers (1) Discretionary Investment Management
Services, (2) Non-Discretionary Investment Advisory Services and/or (3) Retirement Plan Consulting
Services to employer-sponsored retirement plans and their participants. Depending on the type of the
Plan and the specific arrangement with the Sponsor, we may provide one or more of these services. Prior
to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2A along with a copy of
our Privacy Policy and the Retirement Plan Investment Advisory Agreement (“Agreement”) that contains
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the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA")
as applicable.
The Agreement authorizes our investment adviser representatives ("IARs") acting as RPAs, RPRMs or
Client Advisors, as described below, to deliver one or more of the following services:
Discretionary Investment Management Services
These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring, and
disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974
("ERISA"). We will perform these investment management services through our RPAs and/or RPRMs (described as
IARs) and charge fees as described in this Form ADV and the Agreement. If the Plan is subject to ERISA, we will
perform these services as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to
the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may determine that we perform the:
following services:
SELECTION, MONITORING & REPLACEMENT OF DESIGNATED INVESTMENT ALTERNATIVES ("DIA"):
IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to
the Sponsor an Investment Policy Statement (IPS) that contains criteria from which the IAR will select, monitor,
and replace the Plan's DIA. Once approved by the Sponsor, applicable IARs will review the investment options
available to the Plan and will select the Plan's DIA in accordance with the criteria set forth in the IPS. On a periodic
basis, IARs will monitor and evaluate the DIA and replace any DIA that no longer meet the IPS criteria.
CREATION & MAINTENANCE OF MODEL ASSET ALLOCATION PORTFOLIOS ("MODELS"):
IARs will create a series of risk-based Models comprised solely among the Plan's DIA; and, on a periodic basis and/or
upon reasonable request, IARs will reallocate and rebalance the Models in accordance with the IPS or other
guidelines approved by the Sponsor.
SELECTION, MONITORING & REPLACEMENT OF QUALIFIED DEFAULT INVESTMENT ALTERNATIVES ("QDIA"):
Based upon the options available to the Plan, IARs will select, monitor, and replace the Plan's QDIA in accordance
with the IPS.
MANAGEMENT OF TRUST FUND:
IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to
the Sponsor an IPS that contains criteria from which IARs will select, monitor, and replace the Plan's investments.
Once approved by the Sponsor, IARs will review the investment options available to the Plan and will select the
Plan's investments in accordance with the criteria set forth in the IPS. On a periodic basis, IARs will monitor and
evaluate the investments and replace any investment(s) that no longer meet the IPS criteria.
Non-Discretionary Fiduciary Services
These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the
Plan. We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary
investment advisory services through our IARs, acting as either RPAs, RPRMs or Client Advisors, and charge fees as
described in this Form ADV 2A and the Agreement. If the Plan is covered by ERISA, we will perform these
investment advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may
engage us to perform one or more of the following Non-Discretionary investment advisory services:
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INVESTMENT POLICY STATEMENT ("IPS"):
IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does
not have an IPS, IARs will provide recommendations to the Sponsor to assist with establishing an IPS. If the Plan
has an existing IPS, IARs will review it for consistency with the Plan's objectives. If the IPS does not represent the
objectives of the Plan, IARs will recommend to the Sponsor revisions to align the IPS with the Plan's objectives.
ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIA"):
Based on the Plan's IPS or other guidelines established by the Plan, IARs will review the investment options
available to the Plan and will make recommendations to assist the Sponsor with selecting DIA to be offered to Plan
participants. Once the Sponsor selects the DIA, IARs will, on a periodic basis and/or upon reasonable request,
provide reports and information to assist the Sponsor with monitoring the DIA. If a DIA is required to be removed,
IARs will provide recommendations to assist the Sponsor with replacing the DIA.
ADVICE REGARDING MODEL ASSET ALLOCATION PORTFOLIOS ("MODELS"):
Based on the Plan's IPS or other guidelines established by the Plan, IARs will make recommendations to assist the
Sponsor with creating risk-based Models comprised solely among the Plan's DIA. Once the Sponsor approves the
Models, IARs will provide reports, information, and recommendations, on a periodic basis, designed to assist the
Sponsor with monitoring the Models. Upon reasonable request, and depending upon the capabilities of the
recordkeeper, IARs will make recommendations to the Sponsor to reallocate and/or rebalance the Models to
maintain their desired allocations.
ADVICE REGARDING QUALIFIED DEFAULT INVESTMENT ALTERNATIVES ("QDIA"):
Based on the Plan's IPS or other guidelines established by the Plan, IARs will review the investment options
available to the Plan and will make recommendations to assist the Sponsor with selecting or replacing the Plan's
QDIA.
ADVICE REGARDING INVESTMENT OF TRUST FUND:
Based on the Plan's IPS, IARs will review the investment options available to the Plan and will make
recommendations to assist the Sponsor with selecting investments that meet the IPS criteria. Once the Sponsor
selects the investment(s), IARs will, on a periodic basis and/or upon reasonable request, provide reports and
information to assist the Sponsor with monitoring the investment(s). If the IPS criteria require any investment(s)
to be replaced, IARs will provide recommendations to assist the Sponsor with replacing the investment(s).
Retirement Plan Consulting Services
Retirement Plan Consulting services are designed to allow our IARs, acting as either RPAs, RPRMs or Client Advisors,
to assist the Sponsor in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan
participants and their beneficiaries. Retirement Plan Consulting services are performed so that they would not be
considered “investment advice” under ERISA. The Sponsor may elect for our IARs to assist with any of the following
services:
Administrative Support
Assist the Sponsor in reviewing objectives and options available through the Plan
Review Plan committee structure and administrative policies/procedures
Recommend Plan participant education and communication policies under ERISA 404(c)
Assist with development/maintenance of fiduciary audit file and document retention policies
Deliver fiduciary training and/or education periodically or upon reasonable request
Recommend procedures for responding to Plan participant requests
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Service Provider Support
Assist fiduciaries with a process to select, monitor and replace service providers
Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking
Coordinate and assist with CSP replacement and conversion
Investment Monitoring Support
Periodic review of investment policy in the context of Plan objectives
Assist the Plan committee with monitoring investment performance
Educate Plan committee members, as needed, regarding replacement of DIA and/or QDIA
Participant Services
Facilitate group enrollment meetings and coordinate investment education
Assist Plan participants with financial wellness education, retirement planning and/or gap analysis
Potential Additional Retirement Services Provided Outside of the Agreement
In providing Retirement Plan Consulting services, the Firm and its IARs may establish a client relationship
with one or more Plan participants or beneficiaries. Such client relationships develop in various ways,
including, without limitation:
● as a result of a decision by the Plan participant or beneficiary to purchase services from the Firm
not involving the use of Plan assets,
● as part of an individual or family financial plan for which any specific recommendations
concerning the allocation of assets or investment recommendations relating to assets held
outside of the Plan, or
●
through a rollover of an Individual Retirement Account ("IRA Rollover").
If the Firm is providing Retirement Plan Consulting services to a plan, IARs may, when requested by a Plan
participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate
agreement. If a Plan participant or beneficiary desires to affect an IRA Rollover from the Plan to an account
advised or managed by the Firm, IARs will have a conflict of interest if his/her fees are reasonably expected
to be higher than those paid to the Firm in connection with the Retirement Plan Consulting services. IARs
will disclose relevant information about the applicable fees charged by the Firm prior to opening an IRA
account. Any decision to affect the rollover or about what to do with the rollover assets remain that of
the Plan participant or beneficiary alone.
In providing these optional services, we may offer employers and employees information on other
financial and retirement products or services offered by the Firm and our IARs.
Individually Tailored Services
When providing investment fiduciary services, we will tailor our advice or (if applicable) discretion to meet
the investment policies or other written guidelines adopted by the Sponsor. The Firm IARs may also
provide advice, under a separate advisory agreement, to plan participants of retirement plans that are
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not associated with the Firm. When providing Participant Investment Advice, such advice will be based
upon the investment objectives, risk tolerance and investment time horizon of each individual Plan
participant.
FINANCIAL PLANNING SERVICES
We provide financial planning services in addition to the advisory services listed previously.
Financial planning is a comprehensive evaluation of a client’s current and future financial state by using
currently known variables to predict future cash flows, asset values and withdrawal plans. Through the
financial planning process, all questions, information, and analysis are considered as they impact and are
impacted by the entire financial and life situation of the client. Clients utilizing this service receive a
written report, which provides the client with a detailed financial plan designed to assist the client achieve
his or her financial goals and objectives.
In general, the financial planning process may address some or all, of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and
financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax, spending and planning for past, current,
and future years; then illustrate the impact of various investments on the client’s current income
tax and future tax liability. However, we do not give specific tax advice, deferring to the client’s
personal accountant or tax preparer.
•
INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
•
INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-
term care, liability, home, and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his
or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as
appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans,
nursing homes, Medicaid, and elder law. However, we do not give tax, legal advice or prepare
estate planning documents, such as wills, trusts or powers of attorney.
We gather required information through in-depth personal interviews. Information gathered includes the
client’s current financial status, tax status, future goals, performance objectives and attitudes towards
risk. We carefully review documents supplied by the client, including a questionnaire completed by the
client, and prepare a written report. Should the client choose to implement the recommendations
contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance
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agent and/or financial advisor. Implementation of financial plan recommendations is entirely at the
client’s discretion.
LIMITATIONS: Client Advisors of the Firm are registered representatives of a broker-dealer and/or
insurance agents/brokers of various insurance companies. Specific product recommendations made in
financial plans are limited to only those products offered through approved companies, as well as our
clearing firm.
Item 5 Fees and Compensation
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs.
RETIREMENT PLAN CONSULTING FEES
Fees for Retirement Plan Consulting’s (“Fees”) services are negotiable and vary based upon the nature,
scope, and frequency of our services as well as the size and complexity of the plan. A general description
of the different types of fees for Retirement Plan Consulting services appears in the fee schedule below:
Fee Type
Fee Range
Assets Under Management – Plan or Account Value
Flat Fee
Project Fee
0.15% - 1.00% (Annualized)
Negotiable
Negotiable
Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, we may
collect our Fees in arrears or in advance. Typically, Sponsors instruct the Plan’s recordkeeper or custodian
to automatically deduct our Fees from the Plan account; however, in some cases a Sponsor may request
that we send invoices directly to the Sponsor or recordkeeper/custodian. Some Plans have monthly fee
assessment and collection, while others are quarterly. Please also consult the plan custodian’s disclosures
and your advisory agreement with the Firm for additional information regarding fees and fee collection.
Upon termination of any Retirement Plan Consulting services contract, any prepaid, unearned fees will be
promptly refunded.
Sponsors receiving Retirement Plan Consulting services may pay more than or less than a client might
otherwise pay if purchasing the Retirement Plan Consulting services separately or through another service
provider. There are several factors that determine whether the costs would be more or less, including,
but not limited to, the size of the Plan, the specific investments made by the Plan, the number of or
locations of Plan participants, services offered by another service provider, and the actual costs of
Retirement Plan Consulting services purchased elsewhere. Considering the specific Retirement Plan
Consulting services offered by the Firm, the Fees charged may be more or less than those of other similar
service providers.
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In determining the value of the Account for purposes of calculating any asset-based Fees, IARs will rely
upon the valuation of assets provided by the Sponsor or the Plan’s custodian or recordkeeper without
independent verification. If, however, there are circumstances which, in the IAR’s judgment, render the
custodian’s valuation inappropriate, IARs will value securities listed on any national securities exchange
at the closing price on the principal exchange on which they are traded and will value any other securities
in a manner determined in good faith by IARs to reflect fair market value. In all events, any such valuation
will not be any guarantee of the market value of any of the assets in the Plan.
Unless we agree otherwise, no adjustments or refunds will be made in respect of any period for (i)
appreciation or depreciation in the value of the Plan account during that period or (ii) any partial
withdrawal of assets from the account during that period. If the Agreement is terminated by us or by the
Sponsor, we will refund certain Fees to the Sponsor to the extent provided in Section 8 of the Agreement.
Unless we agree otherwise, all Fees shall be based on the total value of the assets in the account without
regard to any debit balance.
All Fees paid to the Firm for Retirement Plan Consulting services are separate and distinct from the fees
and expenses charged by mutual funds, variable annuities, and exchange-traded funds to their
shareholders. These fees and expenses are described in each investment's prospectus. These fees will
generally include a management fee, other expenses, and possible distribution fees. If the investment also
imposes sales charges, a client may pay an initial or deferred sales charge. The Retirement Plan Consulting
services provided by the Firm may, among other things, assist the client in determining which investments
are most appropriate to each client's financial condition and objectives and to provide other
administrative assistance as selected by the client. Accordingly, the client should review both the fees
charged by the funds, the fund manager, the Plan's other service providers and the fees charged by the
Firm to fully understand the total amount of fees to be paid by the client and to evaluate the Retirement
Plan Consulting services being provided.
While the following examples are not necessarily related to the Retirement Plan Consulting services,
various vendors, product providers, distributors and others have provided and may, in the future provide,
compensation by paying some expenses related to the following activities: training and education to
include the Firm’s training and recognition events. Also, certain vendors have, and may in the future,
provide marketing support (example seminars), invite us to participate in conferences, or on-line training
that may further IARs' and employees' skills and knowledge. Also, some have and may, in the future,
occasionally provide us with gifts, meals and entertainment of reasonable value consistent with industry
rules and regulations.
If applicable, and in the event the payments are received in connection with, or resulting from, the
Retirement Plan Consulting services, we will disclose such payments to Sponsors in accordance with ERISA
and Department of Labor regulations.
No increase in the Fees will be effective without prior written notice.
Advisory Fees in General: Clients should note that similar advisory services may be available from other
registered investment advisors for similar or lower fees.
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Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees more than
$1,200 more than six months in advance of services rendered.
Additional Fees and Expenses: In addition to our advisory fees, clients will be responsible for other fees
and expenses incurred by their accounts, including, but not limited to, account service fees (example loan
fees as applicable) charged by the custodian; any transaction charges imposed by a broker dealer; and
internal investment charges such as mutual fund or exchange traded fund management fees. Please refer
to disclosures and prospectuses provided by the plan custodian of your retirement plan.
FINANCIAL PLANNING FEES
The Firm has traditionally not charged for financial planning services and does not require the execution
of an advisory agreement, regarding these services, in instances where we are providing them at no
charge or requirement for future business.
Should the Firm enter into agreement to receive payment for financial planning services, the Firm’s
Financial Planning fee will be determined based on the nature of the services being provided and the
complexity of each client’s circumstances. All fees are agreed upon prior to entering a contract with any
client.
Our Financial Planning fees may be calculated and charged on an hourly basis, ranging from $25 to $100
per hour. Although the length of time it will take to provide a Financial Plan will depend on each client's
personal situation, we will provide an estimate for the total hours at the start of the advisory relationship.
Our Financial Planning fees also may be calculated and charged on a fixed fee basis, typically ranging from
$250 to $1,000, depending on the specific arrangement reached/negotiated with the client.
We may request a retainer upon completion of our initial fact-finding session with the client; however,
advance payment will never exceed $500 for work that will not be completed within six months. The
balance is due upon completion of the plan. Upon termination of any financial planning contract, any
prepaid, unearned fees will be promptly refunded.
Financial Planning Fee Offset: The Firm reserves the discretion to reduce or waive the hourly fee and/or
the minimum fixed fee if a financial planning client chooses to engage us for our Portfolio Management
Services.
Item 6 Performance-Based Fees and Side-By-Side
Management
The Firm does not charge clients performance-based fees.
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Item 7 Types of Clients
The Firm provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
•
• High net worth individuals
• Pension and profit-sharing plans
• Charitable organizations
• Corporations or other businesses not listed above.
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs, including the requirements for opening and maintaining a wrap fee program account.
Our Retirement Plan Consulting services are available to clients that are sponsors or other fiduciaries to
plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant-directed defined
contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. The Firm does
not have a minimum asset amount requirement for our Retirement Plan Consulting accounts, but various
plan custodians may.
Item 8 Methods of Analysis, Investment Strategies and
Risk of Loss
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs.
RETIREMENT PLAN CONSULTING
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice for retirement plan
sponsors and/or when acting as the plan’s investment manager (as applicable) and selecting the specific
Designated Investment Alternatives to be held by the plan:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a
good time to buy) or overpriced (indicating it may be a good time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk,
as the price of a security can move up or down along with the overall market regardless of the economic
and financial factors considered in evaluating the stock.
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Technical Analysis. We analyze past market movements and apply that analysis to the present to
recognize recurring patterns of investor behavior and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk
in that a poorly managed or financially unsound company may underperform regardless of market
movement.
Quantitative Analysis. We use mathematical models to obtain more accurate measurements of a
company’s quantifiable data, such as the value of share price or earnings per share and predict changes
to that data.
A risk in using quantitative analysis is that the models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement
and predict changes to share price based on that data. A risk in using qualitative analysis is that our
subjective judgment may prove incorrect.
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an
appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk
tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change
over time due to stock and market movements and, if not corrected, will no longer be appropriate for the
client’s goals.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly
available sources of information about these securities, are providing accurate and unbiased data. While
we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategies in providing advice to retirement plan participants and when providing
advice in financial planning services, provided that such strategies are appropriate to the needs of the
client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among
other considerations.
Long-term purchases. When utilizing this strategy, we advise that securities be purchased with the idea
of holding them in the client’s retirement plan or other accounts (as applicable) for a year or longer.
Typically, we employ this strategy when:
• We believe the securities to be currently undervalued, and/or
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• We want exposure to a particular asset class over time, regardless of the current projection for
this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not
take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are
incorrect, a security may decline sharply in value before we make the decision to sell.
Short-term purchases. When utilizing this strategy, we advise that securities be purchased with the idea
of selling them within a relatively brief time (typically a year or less). We do this to take advantage of
conditions that we believe will soon result in a price swing in the securities we purchase.
Risk of Loss
Investments in securities are inherently risky and clients should be prepared to bear the risk that they
could lose some or all the money they invest. Material risk factors related to the investment strategies
we, or other portfolio managers, may use and asset classes that may be invested into include, but are not
limited to, the following:
Asset Allocation Risk - A risk of asset allocation is that the client may not participate in sharp increases in
a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income,
and cash will change over time due to stock and market movements and, if not corrected, will no longer
be appropriate for the client’s goals.
Long-term purchase strategy risk - A risk in a long-term purchase strategy is that by holding the security
for this length of time, we may not take advantage of short-term gains that could be profitable to a client.
Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the
decision to sell.
Risks Associated with Investing in Commodities. An investment in commodity-linked derivative
instruments may be subject to greater volatility than investments in traditional securities, particularly if
the instruments involve leverage. The value of commodity-linked derivative instruments may be affected
by changes in overall market movements, commodity index volatility, changes in interest rates, or factors
affecting a particular industry or commodity, such as drought, floods, weather, livestock disease,
embargoes, tariffs, and international economic, political, and regulatory developments. The use of
derivatives presents risks different from, and possibly greater than, the risks associated with investing
directly in traditional securities. Among the risks presented are market risk, credit risk, counterparty risk,
leverage risk and liquidity risk. The use of derivatives can lead to losses because of adverse movements in
the price or value of the underlying asset, index, or rate which may be magnified by certain features of
the derivatives.
Risks Associated with Investing in Mutual Funds – Mutual Funds are subject to market risk, including the
possible loss of principal. The value of the portfolio will fluctuate with the value of the underlying
securities. Mutual Funds may have underlying investment strategy risks similar to investing in
commodities, bonds, real estate, international markets or currencies, emerging growth companies, or
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specific sectors. Investors should consider Mutual Funds investment objective, risks, charges, and
expenses carefully before investing. In addition to your annual management fee, you will have the fund’s
internal management fees (these fees are detailed in the fund’s prospectus). Mutual funds are required
to distribute capital gains to shareholders, typically at year-end. Even if the fund’s overall value has
decreased during the year, you may still owe taxes on capital gains distributions if the manager sold
underlying holdings for a profit.
Risks Associated with Investing in an Exchange-Traded Fund (ETF) - ETFs are subject to market risk,
including the possible loss of principal. The value of the portfolio will fluctuate with the value of the
underlying securities. ETFs may trade for less than their net asset value. ETFs may have underlying
investment strategy risks similar to investing in commodities, bonds, real estate, international markets or
currencies, emerging growth companies, or specific sectors. Investors should consider an ETF’s investment
objective, risks, charges, and expenses carefully before investing.
Convertible Securities Risk - Convertible securities are subject to the usual risks associated with debt
securities, such as interest rate risk and credit risk. Convertible securities also react to changes in the value
of the common stock into which they convert and are thus subject to market risk.
Counterparty Risk - The risk that a counterparty to a financial instrument entered into by the Portfolio
Manager or held by a special purpose or structured vehicle becomes bankrupt or otherwise fails to
perform its obligations due to financial difficulties, including making payments to the Portfolio.
● Counterparty risk involved in ETFs with full replication and ETFs with representative sampling
strategies – An ETF using a full replication strategy generally aims to invest into all constituent
assets in the same weightings as its benchmark. ETFs adopting a representative sampling strategy
will invest in some, but not all the relevant constituent assets. ETFs investing through synthetic
instruments issued by third by third parties carry more counterparty risk than ETFs investing
directly in the underlying assets.
● Synthetic replication strategies – ETFs using a synthetic replication strategy use swaps or other
derivative instruments to gain exposure to a benchmark. Currently, synthetic replication ETFs can
be further categorized into two forms:
● Swap-based ETFs – Total return swaps allow ETF managers to replicate the benchmark
performance of ETFs without purchasing the underlying assets. Swap-based ETFs are exposed to
counterparty risk of the swap dealers and may suffer losses if such dealers default or fail to honor
their contractual commitments.
● Derivative embedded ETFs – ETF managers may use other derivative instruments to synthetically
replicate the economic benefit of the relevant benchmark. The derivative instruments may be
issued by one or multiple issuers. Derivative embedded ETFs are subject to the counterparty risk
of the derivative instruments’ issuers and may suffer losses if such issuers default or fail to honor
their contractual commitments.
Cybersecurity Risk – Investment Advisers, in addition to the clients they serve, are exposed to, and rely
on, a broad array of interconnected systems and networks, both internally and through service providers
such as custodians, brokers, dealers, and technology providers. All these parties use digital engagement
tools and other technology to varying degrees in their communications and engagements. As a result,
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they face cybersecurity risks and may experience cybersecurity incidents. Cybersecurity risks, include, but
are not limited to compromised company, employee, or client data, corruption or loss of data, and
disruption or inability to provide services.
Default Risk – The risk that the issuer of a fixed-income security or the counterparty to a contract may or
will default or otherwise become unable or unwilling to honor a financial obligation, such as making
interest or principal payments.
Foreign Currency Risk – Securities issued by foreign companies are frequently denominated in foreign
currencies. The change in value of a foreign currency against the U.S. dollar will result in a change in the
U.S. dollar value of securities denominated in that foreign currency.
Foreign Investment Risk – The Portfolio may invest in securities of foreign issuers. Investments in securities
of foreign securities are subject to risks associated with foreign markets, such as adverse political, social,
and economic developments, accounting standards or governmental supervision that is not consistent
with that to which U.S. companies are subject, limited information about foreign companies, and less
liquidity in foreign markets. These risks may be more pronounced for investments in developing countries.
Government Agency Risk – Direct obligations of the U.S. Government such as Treasury bills, notes and
bonds are supported by its full faith and credit. Indirect obligations issued by Federal agencies and
government-sponsored entities generally are not backed by the full faith and credit of the U.S. Treasury.
Accordingly, while U.S. Government agencies and instrumentalities may be chartered or sponsored by
Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Treasury.
Inflation risk – Prices of a Portfolio’s investments will likely move in response to changes in inflation and
interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing
power of an investor’s future interest payments and principal. Inflation also generally leads to higher
interest rates, which in turn may cause the value of many types of fixed income investments to decline.
Interest Rate Risk – Fixed income securities increase or decrease in value based on changes in interest
rates. If rates increase, the value of fixed income securities generally declines. On the other hand, if rates
fall, the value of the fixed income securities generally increases.
Legislative Risk – There can be no assurance as to what actions might be taken by any federal, state, or
municipal legal authority that may adversely affect investments held by the Portfolio. These actions may
include (but are not limited to) changes on environmental issues, regulation, social issues, and taxation.
Liquidity Risk – Due to a lack of demand in the marketplace or other factors, a Portfolio may not be able
to sell some or all the investments promptly or may only be able to sell investments at less than desired
prices.
Management Risk – The Portfolio is actively-managed. The Portfolio’s value may decrease if the Firm
pursues unsuccessful investments or fails to correctly identify risks affecting the broad economy or
specific issuers comprising the Portfolio.
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Market Risk – The market value of securities may fall or fail to rise. Market risk may affect a single issuer,
sector of the economy, industry, or the market as a whole. The market value of securities may fluctuate,
sometimes rapidly and unpredictably.
Municipal Obligation Risk – Municipal security prices can be significantly affected by political changes as
well as uncertainties in the municipal market related to taxation, legislative changes, or the rights of
municipal security holders. Because many municipal securities are issued to finance similar projects,
especially those relating to education, healthcare, transportation and utilities, conditions in those market
sectors can affect municipal bond prices.
Prepayment Risk – Issuers may choose to pay off debt earlier than the stated maturity date on a bond.
When this happens, the bond fund may not be able to reinvest the proceeds in an investment with as high
a return or yield.
Real Estate Industry and Real Estate Investment Trust (REIT) Risk - These risks can include fluctuations in
the value of the underlying properties, defaults by borrowers or tenants, market saturation, decreases in
market rates for rents, and other economic, political, or regulatory occurrences affecting the real estate
industry, including REITs. REITs depend upon specialized management skills, may have limited financial
resources, may have less trading volume, and may be subject to more abrupt or erratic price movements
than the overall securities markets. REITs are also subject to the risk of failing to qualify for tax-free pass-
through of income.
Risks in Commercial Real Estate Market – A Portfolio’s investments in commercial real estate are subject
to risks affecting real estate investments generally (including market conditions, competition, property
obsolescence, changes in interest rates and casualty to real estate).
Risk of Impaired Credit Quality – If debt obligations held by a Portfolio are downgraded by ratings agencies,
go into default, or if management action, legislation or other government action reduces the issuers’
ability to pay principal and interest when due, the obligations’ value may decline and a Portfolio’s value
may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including
particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain
than for an issuer of a higher rated obligation, lower-rated and unrated obligations are generally more
vulnerable than higher-rated obligations to default, ratings downgrades, and liquidity risk. Political,
economic, and other factors also may adversely affect governmental issues.
Small-Cap and Mid-Cap Risk – Securities of small or mid-capitalization companies that may not have the
size, resources, and other assets of large-capitalization companies. As a result, the securities of small- or
mid-cap companies held by the Portfolio may be subject to greater market risks and fluctuations in value
than large-cap companies or may not correspond to changes in the stock market in general.
Risks associated with Complex or Alternative Investments – These types of investments are often more
speculative, illiquid, expensive, and subject to higher degree of risk than traditional securities. The
potential benefits of using derivative and illiquid investments and, or complex trading strategies could
have a negative impact on a client’s ability to achieve their investment objectives.
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Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client’s or prospective
client’s evaluation of our advisory business or the integrity of our management.
The Firm, as a broker-dealer, is a member of FINRA. FINRA alleged that the Firm violated rules 4 and 5 of
Regulation S-P, NASD Rule 3010(a)(2) and (b)(1), and FINRA Rules 3110(a)(2), (b)(1) and 2010 by, between
January 2009 and December 2016, failing to provide required initial and annual privacy notices to certain
brokerage customers, and failing to establish and maintain a supervisory system reasonably designed to
ensure that it was meeting its privacy notice obligations. In May 2018, without admitting or denying
FINRA’s findings, the Firm consented to the entry of findings and to the following sanctions, including a
censure, a fine in the amount of $150,000, and an undertaking to revise as necessary its policies,
procedures, and internal controls, which the Firm has already complied with.
You can access additional information about our firm and our management personnel, including on the
SEC’s website, located at adviserinfo.sec.gov, as well as FINRA’s website, at: https://brokercheck.finra.org
Item 10 Other Financial Industry Activities and
Affiliations
FIRM REGISTRATIONS
In addition to the Firm being an investment advisor registered with the SEC, our firm is registered as a
FINRA member broker-dealer.
MANAGEMENT PERSONNEL AND OTHER ASSOCIATES REGISTRATIONS
Management personnel and some other associates of our firm, in addition to being licensed as investment
advisor representatives are also separately licensed as registered representatives of the Firm, in our
capacity as a FINRA member broker-dealer.
While the Firm, our management personnel and client advisors always endeavor to put the interest of the
clients first as part of our fiduciary duty, clients should be aware that the receipt of additional
compensation itself creates a conflict of interest and may affect the judgment of these individuals when
making recommendations.
We are a registered investment advisor, a FINRA member broker-dealer, and a wholly owned subsidiary
of Arvest Bank, a commercial bank that offers a broad spectrum of banking products, trust services and
other financial services to consumers, small businesses, and commercial clients. As a subsidiary of Arvest
Bank, our firm is under common ownership and control with several financial institutions, including Arvest
Insurance, Inc., a licensed insurance agency with which we have a material business relationship (referred
to collectively, together with Arvest Bank and the Firm in its capacity as a broker-dealer, as the “Related
Companies”).
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Where appropriate, the Firm and our associates may recommend the various investment and investment-
related services of the Related Companies to our advisory clients. The Related Companies and their
associates may also recommend the advisory services of our firm to their clients. The services provided
by the Related Companies are separate and distinct from our advisory services and are provided for
separate and additional compensation. There may also be arrangements between the Firm and these
Related Companies where the Firm and/or the Related Companies and their associates receive payment
in exchange for client referrals. No Firm client is obligated to use the services of any of the Related
Companies.
In addition, the management persons, and other associates of the Firm are management persons and
insurance agents of Arvest Insurance, Inc., a licensed insurance agency.
These individuals may also be insurance agents for one or more insurance companies. In their separate
capacities as registered representatives of the Firm and/or insurance agents, these individuals can affect
securities transactions and/or purchase insurance and insurance-related investment products for the
Firm’s advisory clients, for which these individuals may generate separate and additional compensation.
Clients, however, are not under any obligation to engage these individuals when considering the
purchase/sale of securities or insurance.
Clients should be aware that the receipt of additional compensation by the Firm and its Related
Companies, affiliates and associates creates a potential conflict of interest that may impair the objectivity
of our firm and these individuals when making advisory recommendations. The Firm endeavors always to
put the interest of its clients first as part of our fiduciary duty as a registered investment advisor. The
Firm’s policies require all Client Advisors to only recommend those services that are in the best interest
of each client. Furthermore, Client Advisors’ salaries are calculated and set semi-annually. For each
performance-based salary calculation, 6 months of prior production are used to determine application of
the Client Advisor’s performance to a payout grid used to set an Advisor’s salary level. Note: Retirement
Plan Advisors (RPAs) receive a base annual salary that is not production based. However, RPAs and Client
Advisors may be eligible for certain bonus opportunities that are production based.
Additionally, we take the following steps to address this conflict:
• We disclose to clients the existence of all material conflicts of interest, including the potential for our
firm and our associates to earn compensation from the sale of individual securities, brokerage and
insurance products and services in addition to our firm’s advisory fees,
• We disclose to clients that they are not obligated to purchase recommended investment products from
our associates or affiliated companies,
• We collect, maintain and document accurate, complete, and relevant client background information,
including the client’s financial goals, objectives and risk tolerance, our firm’s management and
compliance associates conduct regular reviews of client accounts to verify that recommendations
made to a client are suitable to the client’s needs and circumstances,
• We require that our associates seek prior approval of any outside employment activity so that we may
ensure that any conflicts of interests in such activities are properly addressed,
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• We periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by our firm, and
• We educate our associates regarding the responsibilities of a fiduciary, including the need for having
a reasonable and independent basis for the investment advice provided to clients.
Item 11 Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we
require of our employees, including compliance with applicable federal securities laws.
The Firm and our personnel owe a duty of care and a duty of loyalty to our clients and have an obligation
to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide
the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports, or statements and confirmations if capturing all securities activity, as well as initial and annual
securities holdings reports that must be submitted by the firm’s access persons. Among other things, our
Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g.,
private placement) or an initial public offering. Our code also provides for oversight, enforcement, and
recordkeeping provisions.
The Firm’s Code of Ethics further includes the firm’s policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public information, all
associates are reminded that such information may not be used in a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request
a copy by email sent to AWMSolutionsCenter@arvest.com , or by calling (888) 916-2121 .
Please do not hesitate to call your Client Advisor or the Firm Compliance number above if you have any
questions.
The Firm and individuals associated with our firm are prohibited from engaging in principal transactions
for advisory accounts.
The Firm and individuals associated with our firm are prohibited from engaging in agency cross
transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests
of our associates will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing associates to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal account’s securities
identical to or different from those recommended to our clients. In addition, any related person(s) may
have an interest or position in certain securities which may also be recommended to a client.
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It is the expressed policy of our firm that no Firm Client Advisor may purchase or sell any security prior to
a transaction(s) being implemented for their clients’ advisory accounts, when the Client Advisor has
received an order(s) or has knowledge of pending trades for their clients, thereby; preventing such
employee(s) from benefiting from transactions placed on behalf of advisory accounts.
We may aggregate our associate trades with client transactions where possible and when compliant with
our duty to seek best execution for our clients. In these instances, participating clients will receive an
average share price and transaction costs will be shared equally and on a pro rata basis. In the instances
where there is a partial fill of a particular batched order, we will allocate all purchases pro rata, with each
account paying the average price. Our associate accounts will be excluded in the pro rata allocation.
As these situations represent actual or potential conflicts of interest to our clients, we have established
the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm
complies with its regulatory obligations and provides our clients and potential clients with full and fair
disclosure of such conflicts of interest:
1. No principal or associate of our firm may put his or her own interest above the interest of an advisory
client.
2. No principal or associate of our firm may buy or sell securities for their personal portfolio(s) where
their decision is a result of information received because of his or her employment unless the
information is also available to the investing public.
3.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account. This prevents such associates
from benefiting from transactions placed on behalf of advisory accounts.
4. Our firm requires prior approval for any Initial Public Offering (IPO) or private placement investments
by related persons of the firm.
5. We maintain a list of all reportable securities holdings for our firm, and anyone associated with this
advisory practice that has access to advisory recommendations (access person). These holdings are
reviewed on a regular basis by our firm’s Chief Compliance Officer or his/her designee.
6. We have established procedures for the maintenance of all required books and records.
7. All clients are fully informed that related persons may receive separate commission compensation
when effecting transactions during the implementation process.
8. Clients can decline to implement any advice rendered, except in situations where our firm is granted
discretionary authority.
9. All Firm principals and associates must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
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10. We require delivery and acknowledgement of the Code of Ethics by each supervised, securities
licensed person of our firm on an annual basis.
11. We have established policies requiring the reporting of Code of Ethics violations to our senior
management.
12. Any individual who violates any of the above restrictions may be subject to termination.
As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm are separately
registered as securities representatives of a broker-dealer and licensed as an insurance agent of various
insurance companies. Please refer to Item 10 for a detailed explanation of these relationships and
important conflict of interest disclosures.
Item 12 Brokerage Practices
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs.
RETIREMENT PLAN CONSULTING
When appropriate, based upon the needs of each plan, we may recommend that a plan use a certain
retirement plan platform or service provider (such as a recordkeeper, administrator or broker-dealer).
That recommendation may include using our affiliated broker-dealer, also doing business as the Firm, to
serve as broker-dealer in connection with the sale of securities or insurance products to the Plan.
As noted above, for Plans that are subject to ERISA or are otherwise subject to Section 4975 of the Internal
Revenue Code of 1986, as amended (the "Code"), 12b-1 fees paid by product sponsors to the Firm as
broker-dealer of record to the Plan are either refunded to the plan or used to offset the fees.
Item 13 Review of Accounts
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs.
RETIREMENT PLAN CONSULTING
We will contact you at least once a year to review our Retirement Plan Consulting services. It is important
that you discuss any changes in the Plan's demographic information, investment goals, and objectives
with your IAR. Plans may receive written reports directly from their IAR based upon the services being
provided, including any reports evaluating the performance of Plan investment manager(s) or investments
and as applicable recommended changes.
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Regarding advisory services provided to retirement plan participants by the Firm Client Advisors, the Firm
Client Advisor will review items such as:
Investment Allocation,
1.
2. Participant Investor Profile or Suitability Changes, and
3. Any Recommended Investment Changes.
FINANCIAL PLANNING SERVICES
While reviews may occur at different stages depending on the nature and terms of the specific
engagement, typically no formal reviews will be conducted for financial planning clients unless otherwise
contracted for.
We appreciate your significant achievement in approaching the end of our disclosure document and hope
in the future that your continued “investment in knowledge always pays (you) the best interest” – Ben
Franklin.
Financial Planning clients will receive a completed financial plan. Additional reports will not typically be
provided unless otherwise contracted for.
Item 14 Client Referrals and Other Compensation
The Firm may pay Arvest Bank associates a nominal one-time cash award of no more than $25, for a
qualified referral to a licensed Client Advisor, which is not dependent upon a sale being made.
Additionally, the Firm securities licensed associates, to include IARs and Registered Representative (RR)s,
may receive compensation for referrals made to Retirement Plan Consulting.
Our firm does not pay referral fees to independent persons or firms (Solicitors) for introducing clients to
us.
It is the Firm’s policy not to accept or allow our related persons to accept direct compensation, including
cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide
to our clients. However, our firm does allow for soft dollar, indirect compensation from various vendors,
product providers, distributors, and others. These providers may provide non-monetary compensation by
paying some expenses related to training and education, excluding travel expenses. The Firm might
receive payments to subsidize our own training programs or to sponsor an event. Certain vendors may
invite us to participate in conferences, on-line training or receive publications that may further our skills
and knowledge. Some may occasionally provide us with nominal gifts, meals, and entertainment of
reasonable value consistent with industry rules and regulations.
Item 15 Custody
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs.
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RETIREMENT PLAN CONSULTING
Additionally, the Firm will not serve as custodian for plan assets in connection with brokerage or
investment advisory Retirement Plan Consulting services. Retirement plan sponsors are responsible for
selecting the custodian for plan assets. The Firm Retirement Plan Consulting Group may be listed as the
contact for the plan account held at an investment sponsor our custodian. Sponsor for the plan will
complete account paperwork with the outside custodian that will provide the name and address of the
custodian. The custodian for the plan is responsible for providing the plan with periodic confirmations and
statements. We recommend that sponsors review the statements and reports received directly from the
custodian or investment sponsor.
Item 16 Investment Discretion
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to our Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap
fee programs, including programs where we accept discretionary authority to manage securities accounts
on behalf of clients.
RETIREMENT PLAN CONSULTING
When providing Retirement Plan Consulting services described herein, we may exercise discretionary
authority or control over the investments specified in the Agreement. We perform these services to the
Plan as a fiduciary under ERISA Section 3(21) and investment manager under ERISA Section 3(38). We are
legally required to act with the degree of diligence, care, and skill that a prudent person rendering similar
services would exercise under similar circumstances. This discretionary authority is specifically granted to
us by Sponsor, as specified in the Agreement (see also, Item 4 above).
Item 17 Voting Client Securities
ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS
Please refer to our Wrap Fee Program Brochure for a description of our wrap fee programs.
RETIREMENT PLAN CONSULTING
The Firm’s Retirement Plan Consulting services has no authority or responsibility to vote any security held
by the Plan or the related proxies. The Sponsor or trustee of the Plan reserves that authority. The Firm
does not accept proxy voting authority in connection with any Retirement Plan Consulting services.
Item 18 Financial Information
The Firm has no additional financial circumstances to report.
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Under no circumstances do we require or solicit payment of fees more than $1,200 per client more than
six months in advance of services rendered. Therefore, we are not required to include a financial
statement.
The Firm has not been the subject of a bankruptcy petition at any time.
BUSINESS CONTINUITY PLAN
The Firm is committed to safeguarding the interests of our clients and customers in the event of an
emergency or significant business disruption. Our Business Continuity Plan, which enables us to respond
to events that significantly disrupt our business, may be obtained from our Retirement Plan Advisors and
Retirement Plan Relationship Managers or Client Advisors (as applicable) and can also be found at our
disclosures’ website:
https://www.arvest.com/documents-and-resources/awm-disclosures
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March 27, 2026