HERITAGE OAK WEALTH ADVISORS LLC

s Form ADV Part 2A Firm Brochure October 8, 2025 This Brochure provides information about the qualifications and business practices of Heritage Oak Wealth Advisors. If you have any questions about the contents of this Brochure, please contact us at 479-230-3113, or via e-mail at micah@heritageoakwealthadvisors. 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. Heritage Oak Wealth Advisors is a registered investment advisory firm. Registration of an investment advisory firm does not imply a particular level of skill or training. Heritage Oak Wealth Advisors IARD# 323925 105 Garfield St. Santa Rosa Beach, FL 32459 479-230-3113 micah@heritageoakwealthadvisors.com www.heritageoakwealthadvisors.com Additional information about Heritage Oak Wealth Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of our Firm Brochure. This Item discusses only specific material changes made to this Brochure and provides our clients with a summary of such changes. Material Changes since the Last Update Since our last ADV amendment on August 18, 2025, Heritage Oak Wealth Advisors has made material changes to the brochure. Item 4: Advisory Business Item 5: Fees and Compensation Item 12: Brokerage Practices • • • Full Brochure and Additional Information Full Brochure and additional information about Heritage Oak Wealth Advisors are available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with us who are registered or are required to be registered as investment adviser representatives (“IAR”). 2  ITEM 3 Table of Contents ITEM 1 Cover Page ................................................................................................................................. 1 ITEM 2 Material Changes ....................................................................................................................... 2 ITEM 3 Table of Contents ....................................................................................................................... 3 ITEM 4 Advisory Business ...................................................................................................................... 4 ITEM 5 Fees and Compensation ............................................................................................................. 6 ITEM 6 Performance-Based Fees and Side-By-Side Management ......................................................... 9 ITEM 7 Types of Clients .......................................................................................................................... 9 ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss .................................................. 9 ITEM 9 Disciplinary Information .......................................................................................................... 11 ITEM 10 Other Financial Activities and Affiliations ................................................................................ 12 ITEM 11 Code of Ethics, Participation in Client Transactions, and Personal Trading ............................. 12 ITEM 12 Brokerage Practices ................................................................................................................. 14 ITEM 13 Review of Accounts ................................................................................................................. 16 ITEM 14 Client Referrals and Other Compensation ............................................................................... 16 ITEM 15 Custody .................................................................................................................................... 17 ITEM 16 Investment Discretion .............................................................................................................. 17 ITEM 17 Voting Client Securities ............................................................................................................ 17 ITEM 18 Financial Information ............................................................................................................... 18 3  ITEM 4 Advisory Business FIRM INFORMATION Heritage Oak Wealth Advisors (“Heritage Oak,” “we,” “us,” “our”), formed on April 5, 2019, is a registered investment advisory firm located in Santa Rosa Beach, FL. We have been a registered investment advisory firm since 2022. PRINCIPAL OWNERS Heritage Oak is owned and controlled by Micah Gibson, its Founder, and Chief Compliance Officer. INVESTMENT ADVISORY SERVICES Asset Management Services: We provide asset management services in which we manage your custodial accounts and provide you with continuous and ongoing supervision of your custodial accounts. Our services provide additional investment opportunities among stocks, bonds, mutual funds, exchange-traded funds (ETFs), Real Estate Investment Trusts (REITs), options, and additional securities. Financial Planning and Consulting Services: We provide various financial planning and consulting services that find ways to help you understand your overall financial situation and help you set financial objectives. We accomplish this by helping you review your financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis. Generally, such financial planning and consulting services will involve preparing a financial plan or rendering a financial consultation based on your financial goals and objectives. We will summarize our services to you in a written plan, which will typically include general recommendations for a course of action or specific actions to be taken by you. Implementation of the recommendations will be at your discretion. We provide our financial planning and consulting services on an ongoing basis. Ongoing Financial Planning and Consulting Services Upon completion of the client’s financial plan or consulting engagement, we will revisit all or some of the following areas of analysis: financial goals, tax planning strategies, asset allocation, risk management, retirement planning, and other areas and objectives such as budgeting, education planning, cash flow planning, charitable planning, lines of credit analysis, insurance analysis, business financial planning, mortgage/debt analysis, and real estate analysis throughout the course of a year via scheduled meetings, calls, or follow-up emails to ensure that the initial recommendations in the financial plan or consulting engagement are implemented or to make adjustments to the Client’s financial plan and/or the Client’s objectives. 4  Estate Planning Heritage Oak will provide estate planning services through our partnership with Estately. With their assistance we will help you navigate estate planning with intuitive solutions, craft wills and trusts, and other essential documents. For intricate situations, we can easily pair with a specialized attorney. Retirement Plan Consulting Services: We provide advisory services to plan sponsors of employer-sponsored retirement plans for which it has been specifically engaged, in addition to supporting affiliated companies through other non-advisory services to retirement plans for corporations and other business entities. Such advisory services can include selection and/or de-selection and replacement of individual investment options pursuant to agreed investment criteria. In choosing and monitoring investment options for employer-sponsored retirement plans, we look for reliable fund companies that have a consistent track record and steady performance. Once a fund company is identified for possible selection for a particular retirement plan product, we conduct an in- depth review of the company’s operations, funds, and personnel before determining if the company’s funds as investment options. Quantitative and qualitative factors, such as regional exposure, fund management, and asset size/growth, are also evaluated. The fund companies are monitored on a continuous basis at the firm level. We will assist in the construction of the portfolio by ensuring that all core asset classes are covered to offer full diversification opportunities. However, the final decision of which funds to select is up to the plan sponsor and/or consultant. Private Investment Vehicles The Firm may sponsor or participate in private investment vehicles, including special purpose vehicles (“SPVs”), formed to access specific private investment opportunities. One such vehicle is Apptronik 2.3B LLC, a Delaware limited liability company organized to invest in preferred shares of Apptronik, Inc. at $21.00 per share. This opportunity is offered only to accredited investors and is not part of the Firm’s discretionary investment management services. Third-Party Money Management Services: We can recommend third-party money managers (“TPMMs”) to manage part or the client’s entire portfolio. TPMMs will be recommended when the TPMMs’ philosophy, investment strategy, and style meets the client's financial situation, investment objectives, and risk tolerance. The asset management services provided by the TPMMs, the compensation to be paid, and other terms of the relationship between the client and the TPMMs will be described in the TPMMs’ disclosure documents and its managed account agreement. We will receive a portion of the investment advisory fee paid by the client to the TPMMs. In certain circumstances Heritage Oak may facilitate the borrowing of funds against clients assets by utilizing the services of SyntheticFi. SyntheticFi is an investment advisor that translates your borrowing needs to a box spread, constructed with S&P 500 Index Options. A box spread is a basket of option contracts. These option contracts are designed to have a fixed payoff at a fixed future date. It is constructed with 4 option contracts, with a put and a call in each direction, which hedges out the risk from the underlying securities. Regardless of how the stock market moves, you will always pay a fixed amount when the options expire. That's because these options are hedging each other to remove any exposure to the underlying (S&P 500 Index). 5  TAILORED INVESTMENT ADVISORY SERVICES AND RESTRICTIONS Heritage Oak offers the same suite of services to all our clients; however, specific recommendations and their implementation are dependent upon the individual client’s current financial situation, such as income, net worth, and risk tolerance levels. On a case-by-case basis, our clients can impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent us from properly servicing the client’s account or if the restrictions would require us to deviate from our standard suite of services, we reserve the right to end the relationship. We can request additional information and documentation, such as current investments, tax returns, insurance policies, and estate plans. We will discuss your investment objectives, needs, and goals, but you must inform us of any changes. Unless directed by you, we do not independently verify any information provided to us by you or your attorney, accountant, or other professionals. WRAP FEE PROGRAMS Heritage Oak does not participate in, recommend, or offer wrap fee programs. Class Action Litigation Heritage Oak has engaged 11thEstate, Inc. (‘11thEstate’) to monitor for and file class action litigation paperwork on behalf of Heritage Oak clients entitled to participate in such class actions. Clients are typically requested to provide authorization through their Investment Management Agreements (“IMA”) at the time the initial IMA is executed. Clients are permitted to change their authorization at any time upon written notice to Heritage Oak. Where clients have decided to utilize 11thEstate, clients are permitted to opt out of any particular class action litigation claim by notifying 11thEstate in writing. Heritage Oak is not responsible for notifying eligible clients at the commencement of any particular class action and clients understand that, when a claim is settled, it will be necessary for to share client information such as client name and account number with 11thEstate in order to allow 11thEstate to process underlying client claims. ASSETS UNDER MANAGEMENT As of December 31, 2024, Heritage Oak manages $289,910,705 on a discretionary basis only. Fees and Compensation ITEM 5 ANNUAL FEES FOR ADVISORY SERVICES Heritage Oak is compensated for providing asset management services by charging a negotiable fee based on the total assets under management. The fees and billing will be pre-determined in writing in the Investment Advisory Agreement executed by you and Heritage Oak. The fees charged for financial planning services are negotiable and vary depending on the complexity of the process undertaken, the types of issues addressed, the scope of services provided, and the frequency with which the services are rendered. All fees are agreed upon before entering the Financial Planning and 6  Consulting Agreement you sign. Fees for retirement plan services are negotiated before the signing of the Retirement Plan Advisory and Consulting Agreement. The agreement language includes the negotiated fee, which can be charged as a percentage of the total retirement plan assets and/or a flat annual fee. The below ranges are the standard fee ranges that are typically charged. We can waive the agreed-upon financial planning fees if you engage our asset management services. Asset Management Fee Schedule All Assets Up to 1.25% Financial Planning and Consulting Fee Schedule Hourly Fee $250 Fixed Fee $1,000 - $5,000 Annual Retainer Fee $1,000 - $5,000 Retirement Plan Advisory and Consulting Fee Schedule Percentage of Plan Assets Up to 1.25% FEE BILLING & PAYMENT Our asset management fees are annual fees and are negotiable. Asset management fees are paid monthly in advance. Payments are due on the first day of the calendar month and are based on the account’s asset value as of the first business day of the month multiplied by the applicable annual rate and divided by twelve (12). The fee for the current month is billed and payable within ten (10) days after the end of the prior month. We will deduct our asset management fee only when in receipt of your written authorization by executing an investment advisory agreement permitting the fees to be paid directly from your account. We will send a copy of your invoice to the custodian at the same time that we send a copy to you. The qualified custodian will deliver an account statement to you at least quarterly, which will show all disbursements from your account. We urge you to review all statements for accuracy. Your account at the custodian can also be charged for certain additional assets managed for you by us but not held by the custodian (i.e., variable annuities, mutual funds, 401(k)s). Financial planning and consulting fees are assessed. on an hourly basis, as a one-time project fee, or as an annual fee payable either monthly or quarterly. An estimate for total hours will be determined at the start of the relationship in order to determine whether hourly planning or a project-based plan is in the Client’s best interest. Hourly fees will be invoiced upon completion of the financial plan or the rendering of consulting services with a thirty (30) day written notice. For one-time projects, the Client agrees to pay one-half of the total fee upon signing the Financial Planning and Consulting Agreement and the remaining fee upon delivery of the plan. For ongoing financial planning or consulting services, the 7  Client agrees to pay a one-time initial planning fee in addition to an annual fee paid out [either monthly or quarterly, arrears.] Retirement plan consulting fees will be billed on a monthly basis, in advance, at the beginning of each calendar month, due within thirty (30) days after the date of invoice, unless otherwise agreed to by the parties. The fee will either be billed directly to the plan sponsor or paid directly from the plan assets if authorized by the plan fiduciary. Estate planning services fees will be in addition to the current fee schedule and will range from $150 (minimal documents) to $1,500 (full documents). In TPMM accounts, the adviser deducts the advisory fee from the client’s account and will forward a portion of the fee to our firm. We urge our clients to refer to the selected TPMM’s disclosure documents for the exact fees and expenses charged by each such TPMM, as well as minimum account requirements, refund, and termination provisions. A complete description of each program can be found in disclosure materials prepared by the TPMM, which we will provide to the client at the time we recommend the program. SythenticFi charges interest rates depending on the duration of your loan, In addition, you may need to pay trading fees and commissions, as well as other exchange fees when executing the trades. There is no closing cost associated with these box spread offer. Interest rates will be provided on SyntheticFi’s agreement and disclosure documents. You are responsible for all third-party fees (i.e., custodian fees, mutual fund fees, transaction fees, etc.). These fees are separate and distinct from the fees and expenses charged by Heritage Oak. TERMINATION OF AGREEMENT Either party can terminate the agreement by providing a 30-day advance written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable up to and including the effective date of termination. Notwithstanding the above, if we do not deliver the appropriate disclosure statement to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract without penalty within five (5) business days after entering into the contract. OTHER EXPENSES AND FEES The fees discussed above include payment solely for the investment advisory services provided by us and are separate from certain fees or charges that are imposed by third parties in connection with investments made on your behalf for your account. Third-party fees can include markdowns, markups, brokerage commissions, other transaction costs, and/or custodial fees. All fees paid to us for asset management services are separate from the expenses charged by exchange- traded funds and mutual funds to their shareholders. These fees and expenses will be used to pay management fees for the funds, other fund expenses, account administration, and a possible distribution fee. Exchanged traded funds and mutual funds can be invested in directly by you without our services. However, you would not receive our services to assist you in determining which products or services are most suitable for your financial situation and objectives. You should review both the fees we charge and the fees charged by the fund(s) to understand the total fees to be paid fully. Please refer to Item 12 of this brochure for a more detailed explanation of brokerage practices. 8  OTHER COMPENSATION Certain of our associated persons are also licensed insurance agents. In this capacity, the IARs can recommend insurance, advisory, or other products and receive normal insurance commissions if products are purchased through the IAR(s) in this capacity. Thus, a conflict of interest exists between the interests of these individuals and those of the advisory clients, creating an incentive for the IAR(s) to recommend products based on the compensation received rather than on a client’s needs. However, clients are under no obligation to act upon any of these recommendations. Although our recommendations can include products offered by third parties, these recommendations are not limited to such products, as all financial planning advice provided is of a generic nature. Clients have the option to purchase insurance products recommended by the IAR through other agents not affiliated with our firm. Please refer to Item 10 of this Brochure for a more detailed explanation of how our firm handles and mitigates these conflicts of interest. Class Action Litigation Heritage Oak does not receive any fees or remuneration from 11thEstate for allowing 11thEstate to provide class action litigation services. 11thEstate earns fees based on a percentage of the total claim awarded. 11thEstate’s fee (up to 20% of any claim awarded) is generally deducted from each client’s settlement proceeds and net settlement proceeds are then processed into client accounts. Although unusual, where payment for 11thEstate services through the reduction of client settlement proceeds is limited or not available, 11thEstate will make other suitable payment arrangements with clients directly. If a client opts out of the service or particular class action litigation claim, is under no obligation to advise or act on behalf of that client regarding class action claims. ITEM 6 Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees, which are fees based on a share of capital gains on or capital appreciation of your assets. ITEM 7 Types of Clients We provide our investment advisory services to: - Individuals - High Net Worth Individuals We do not have a minimum account size for our asset management services. ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss METHODS OF ANALYSIS 9  We use various methods of analysis and investment strategies, including the following: Fundamental Analysis – We evaluate economic and financial factors to determine if a security can be underpriced, overpriced, or fairly priced. This method entails assessing a security by attempting to determine its intrinsic value by examining related financial, economic, and other qualitative and quantitative factors. Fundamental analysis requires an in-depth look at all factors that can affect the security's value, from macroeconomic factors (like the overall economy and industry conditions) to individually specific factors (like the financial situation and management of companies). The overall objective of performing the fundamental analysis is to determine a value that an investor can use to determine what sort of position to take with that security. This method of security analysis is contrary to technical analysis. Fundamental analysis involves using real data to evaluate a security's value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be used for just about any type of security. 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. Therefore, unforeseen market conditions and/or company developments can result in significant price fluctuations that can lead to investor losses. Technical Analysis – This method involves the evaluation of securities by performing an analysis of statical information that is generated by market activity, such as past prices and volume. Technical analysis does not attempt to measure a security's intrinsic value but instead use charts and other tools to determine the patterns that can suggest future activity. Technical analysts believe that the historical performance of stocks and markets are an indication of future performance. A substantial risk in relying upon technical analysis is that spotting historical trends cannot help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that we will be able to accurately predict such a reoccurrence. INVESTMENT STRATEGIES When formulating investment advice or managing client assets, we will use the following investment strategies. There are inherent risks associated with each of these strategies. Long-Term Strategy - A long-term strategy cannot take advantage of short-term gains or can experience more volatility over the life of the portfolio. Short-Term Strategy – A short-term strategy involves the purchase of securities with the idea of selling them within a relatively short time, typically a year or less. This strategy is done in an attempt to take advantage of conditions that result in market fluctuations in the securities purchased. Your accounts are managed separately with your underlying investment strategies, restrictions, or investment limitations defined within the investment management agreement. POTENTIAL RISKS Investing involves different levels of risk that can result in the loss of any profits and/or principal you have not realized. We manage your account in a manner consistent with your pre-determined risk tolerance and suitability profile. However, we cannot guarantee that our efforts will be successful. Investing in 10  securities involves the risk of loss that clients should be prepared to bear. Investing involves the assumption of risk, including: Financial Risk: which is the risk that the companies we recommend to you perform poorly, which affects the price of your investment. Market Risk: which is the risk that the stock market will decline, decreasing the value of the securities we recommend to you with it. Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock. Political and Governmental Risk: which is the risk that the value of your investment will is affected by the introduction of new laws or regulations. Interest Rate Risk: which is the risk that the value of the investments we recommend to you will fall if interest rates rise. Call Risk: which is the risk that your investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you. Default Risk: which is the risk that the issuer is unable to pay the contractual interest or principal on the investment promptly or at all. Manager Risk: which is the risk that an actively managed mutual fund’s investment adviser will fail to execute the fund’s stated investment strategy. Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. Short-Term Purchases: Short-term purchases can incur more trading and brokerage costs in the form of increased commissions and transaction costs and increased tax obligations on the gains of a security’s value. A short-term strategy runs the risk that certain anticipated market movements do not occur, resulting in the client holding a security for longer than intended. Private Fund Risk: Investments in SPVs such as Apptronik 2.3B LLC involve significant risk, including illiquidity, lack of diversification, lack of control, reliance on a single underlying investment, and long investment time horizons. Clients considering such investments should be prepared to lose the entire amount invested. These investments are only offered to qualified accredited investors and are not appropriate for all clients. ITEM 9 Disciplinary Information As of the date of this brochure, we have not been subject to any disciplinary, legal, or regulatory events related to past or present investment clients. There has been no disciplinary, legal, or regulatory events related to us or any of our management persons. 11  ITEM 10 Other Financial Activities and Affiliations FINANCIAL INDUSTRY ACTIVITIES Neither Heritage Oak nor its management persons are registered or has an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither Heritage Oak nor its management persons are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or commodity trading advisor. AFFILIATIONS Certain associates of the firm are also registered representatives, licensed to sell securities. As a registered representative of an unaffiliated broker-dealer, he or she can earn additional compensation in the form of commissions for the sale of general securities products such as stocks, bonds, mutual funds, exchange- traded funds, and a variable annuity to investment advisory clients. As such, your IAR can suggest that you implement investment advice by purchasing securities products through a commission-based account introduced through our unaffiliated broker-dealer in addition to an investment advisory account. In the event that you elect to purchase these products through our unaffiliated broker-dealer, your investment adviser, in the capacity as a registered representative, and our unaffiliated broker-dealer will receive the standard and customary commission compensation in connection with the particular product purchased. Certain associates of the firm are also insurance agents licensed to sell insurance products. A conflict of interest exists in that these services pay a commission, which conflicts with the IAR’s fiduciary duties. Heritage Oak does not require its IARs to encourage clients to implement investment advice through our insurance product recommendations. Clients have the right to implement insurance product recommendations through the insurance agency and agent of their choice. We require that all IARs disclose this conflict of interest when such recommendations are made. We also require IARs to disclose that the client has the right to purchase recommended products from individuals not affiliated with us. Heritage Oak is a principal or member of Apptronik 2.3B LLC, a Delaware SPV formed to invest in preferred shares of Apptronik, Inc. The Firm or its personnel may receive compensation from the SPV in the form of a management fee and/or a performance-based carried interest (typically 20% of net profits after return of capital). This creates a potential conflict of interest when recommending participation in the SPV to clients. The Firm addresses this conflict by: - Requiring all investors to be accredited and receive a private placement memorandum; - Providing full disclosure of all compensation terms; - Recommending SPV participation only on a non-discretionary basis; - Advising clients to seek independent legal and tax counsel. SELECTION OF OTHER INVESTMENT ADVISERS We recommend or select TPMMs for our clients and receive compensation from the third-party via a fee share; thus, a material conflict of interest exists between our interests, and those of our clients in that Heritage Oak has the incentive to direct clients to TPMMs that provide us with a larger fee split. Heritage Oak will always act in the best interest of our clients when making recommendations or selecting TPMMs. 12  The client always has the right to decide whether to act on our recommendations and whether to utilize the services of the recommended TPMM. The client always has the right to utilize the professional of his or her choice. All TPMMs will be properly licensed and registered as investment advisers in the proper jurisdictions. The fees shared will not exceed any limit imposed by any regulatory agency. ITEM 11 Code of Ethics, Participation in Client Transactions, and Personal Trading CODE OF ETHICS Heritage Oak has developed a code of ethics that will apply to all of our supervised persons. We and our IARs must act in a fiduciary capacity when providing investment advisory services to you. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Heritage Oak has a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle of our code of ethics, which also covers our insider trading and personal securities transactions policies and procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will acknowledge that they have read, understand, and agree to comply with our Code of Ethics. Our Code of Ethics is available to clients and prospective clients upon request. RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST Neither we nor any related person recommend to clients or buys or sells for clients’ accounts securities in which we or a related person has a material financial interest. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS There are instances where an IAR will recommend to investment advisory clients or prospective clients the purchase or sale of securities in which an IAR, its affiliates, or other clients can also have a position or interest. Certain affiliated accounts can trade in the same securities with client accounts on an aggregated basis. Generally, in such circumstances, the affiliated and client accounts will share execution costs equally. Completed trade orders will be allocated according to the instructions from the initial trade order. Partially filled trade orders will be allocated on a pro-rata basis. Any exceptions will be explained in the trade order. PERSONAL TRADING Employees are permitted to have personal securities accounts as long as personal investing practices are in line with fiduciary standards and regulatory requirements and do not conflict with their duty to Heritage Oak and our clients. Heritage Oak monitors and controls personal trading through pre-approval of all personal securities transactions or blackout periods imposed upon employees trading in the same securities as Heritage Oak. We forbid any officer or employee, either personally or on behalf of others, 13  to trade on material, nonpublic information or communicate such information to others in violation of the law. ITEM 12 Brokerage Practices Heritage Oak currently has arrangements with Charles Schwab & Co. (“Schwab”), Altruist Financial, LLC (“Altruist”) and TradePMR/Robinhood, (“Robinhood”). Schwab, Altruist, and Robinhood are the unaffiliated, qualified custodians, whereby Heritage Oak would suggest you custody your accounts. Schwab, Altruist, and Robinhood are independent SEC-registered broker-dealers and members of FINRA and SIPC. As a fiduciary, we are obligated to seek out the best execution of client transactions for accounts that we manage. In general, the execution of securities transactions is at a total cost to process each transaction and are the most favorable under the circumstances. However, we do not limit the best execution to the lowest available price. Additional factors are taken into consideration when determining the arrangement and services in the selection of a broker-dealer or qualified custodian. Our review consists of reviewing the commission and fee structures of various broker-dealers, research platforms, and execution services. Accordingly, while we consider competitive rates, we do not necessarily obtain the lowest possible commission rates for account transactions. Therefore, the overall services provided by unaffiliated broker- dealers and qualified custodians are evaluated to determine the best execution. You can pay trade execution charges and higher commissions through the trading platforms approved by us than through platforms that have not been approved by us. RESEARCH AND OTHER BENEFITS Products & Services Available to Us from Schwab Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis and at no charge to us as long as we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab. Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access, or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but cannot directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We can use this research to service all or some substantial number of our clients’ accounts, including accounts 14  not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); • facilitates trade execution and allocates aggregated trade orders for multiple client accounts; • provides pricing and other market data; • facilitates payment of our fees from our clients’ accounts; and • assists with back-office functions, recordkeeping, and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events • technology, compliance, legal, and business consulting; • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Schwab can provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. BROKERAGE FOR CLIENT REFERRALS We do not receive client referrals from broker-dealers. DIRECTED BROKERAGE Clients will be permitted to select any broker-dealer of their choosing. In these situations, we are unable to achieve the most favorable execution for client transactions. Directing brokerage can cost clients more money in that the client can pay higher brokerage commissions because we are not able to aggregate orders to reduce transaction costs, or the client can receive less favorable prices. TRADE AGGREGATION We attempt to allocate trade executions in the most equitable manner possible, taking into consideration current asset allocation and availability of funds using price averaging, proration, and consistently non- arbitrary methods of allocation. We can aggregate orders in order to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among our clients’ differences in prices and commission or other transaction costs. In aggregated orders, transactions will be price-averaged and allocated among our clients in proportion to the purchase and sale orders placed for each client account on any given day. 15  Review of Accounts ITEM 13 PERIODIC REVIEWS We review asset management, and retirement plan accounts no less than annually. These accounts will be reviewed by Micah Gibson, CCO. Accounts are reviewed to evaluate asset allocation, investment strategy and objectives, cash balance, and performance, as well as the general economic outlook and current investment trends. Financial plans created utilizing our ongoing financial planning services will be reviewed monthly or quarterly by {name/title of person}. We can make adjustments to the Client’s financial plan and/or the Client’s objectives. REVIEW TRIGGERS We conduct periodic reviews to evaluate the current market, economic and political events and how these can affect client accounts. Additional reviews can be triggered by these events or by events in the client’s financial or personal status. REGULAR REPORTS Asset management clients will receive advisory account reports no less than quarterly. These reports show asset value by cash balances, security, unit cost, total cost, current per share values, etc. Clients are urged to review the quarterly reports provided by us with those provided by their custodians and notify us of any differences. Clients are encouraged to phone or e-mail us as often as they deem necessary to receive information regarding the investment tactics and strategies being followed. Financial plans created utilizing our ongoing financial planning services will receive status updates and/or reports during plan reviews. Project-based financial planning and consulting clients are provided a one- time written financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. We can create and/or review the plan’s Investment Policy Statement (“IPS”) for our retirement plan clients. The plan client can also receive quarterly written reports evaluating the performance of the plan’s investments as well as comparing the performance thereof to benchmarks set forth in the IPS or as otherwise determined in our judgment. The information used to generate the reports will be derived from statements provided by the plan fiduciary or third party. This review will include a quantitative and qualitative analysis of investment selections included within the plan and provide third-party commentary on investment options whenever available. ITEM 14 Client Referrals and Other Compensation While we do not have any current arrangements with any TPMMs, at such time that we do, we will receive compensation based on the service they provide to our clients. Any such compensation arrangement will be formalized in an agreement and disclosed to our clients. Please see Item 12, Brokerage Practices, for information regarding the benefits we receive from our 16  custodian. We do not pay a referral fee to third-party solicitors. ITEM 15 Custody We are deemed to have custody of client funds and securities due to our ability to deduct management fees from clients’ accounts. We will not take physical custody of clients’ funds and will not assign or transfer trading authorization to another advisor. Clients will receive account statements from the qualified custodian(s) holding their funds and securities at least quarterly. The custodian’s account statements will indicate the amount of our advisory fees deducted from the clients’ account(s) each billing period. These statements should be carefully reviewed by the client for accuracy. Item 5 – Fees and Compensation has additional information regarding our ability to deduct management fees from clients’ accounts. Investment Discretion ITEM 16 DISCRETIONARY AUTHORITY FOR TRADING If you are participating in our asset management services, upon receiving your written authorization via our executed investment advisory agreement, we will maintain trading authorization over your designated account and can also implement trades on a discretionary basis. When discretionary authority is granted, we will have the limited authority to determine the type of securities to be purchased, sold, or exchanged and a number of securities that can be bought, sold, or exchanged for your portfolio without obtaining your consent for each transaction. If you do not grant this limited investment discretion, your IAR will be required to contact you and get affirmation regarding our investment recommendations, such as the security being recommended, the number of shares, and whether the security should be bought or sold before implementing changes in your account. Once the above factors are agreed upon, we will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. If your accounts are managed on a non-discretionary basis, it is critical that you respond promptly. If we do not receive a response to our request immediately, the timing of trade implementation can lead to an adverse impact where we cannot achieve the optimal trading price. On a case-by-case basis, you can place reasonable restrictions on the types of investments that can be purchased or sold in your account so long as the restrictions are explicitly set forth or included as an attachment to the investment advisory agreement. ITEM 17 Voting Client Securities We do not have the authority to vote proxies as it pertains to the issuers of securities held in your account. The responsibility for voting your securities places increased liability to us and does not add enough value to the services provided to you to justify the additional compliance and regulatory costs associated with 17  voting your securities. Therefore, you are responsible for voting all proxies for securities held in accounts managed by us. Typically, our qualified custodian will forward you your proxy information. Although we do not vote your proxies, you can contact us if you have a question about a particular proxy. ITEM 18 Financial Information We are not required to include a balance sheet for our most recent fiscal year. We are not subject to a financial condition that is reasonably likely to impair our ability to meet contractual commitments to our clients. We are currently not in, nor have we been historically, in a financially precarious situation or the subject of a bankruptcy petition. 18