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Item 1: Cover Page
Part 2A of Form ADV: Firm Brochure
February 2026
NV Office:
10161 Park Run Dr., #150
Las Vegas, NV 89145
CA Office:
2535 Townsgate Road
Suite 300
Westlake Village, CA 91361
Website:
www.oakasset.com
AZ Office:
123 S. San Francisco Street
Suite 15
Flagstaff, AZ 86001
Firm Contact:
Thomas Robertson
Chief Compliance Officer
This brochure provides information about the qualifications and business practices of Oak Asset
Management, LLC. If clients have any questions about the contents of this brochure, please contact
us at (805) 778-0818. 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 our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by
searching CRD # 287856.
Please note that the use of the term “registered investment adviser” and description of our firm
and/or our associates as “registered” does not imply a certain level of skill or training. Clients are
encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise
clients for more information on the qualifications of our firm and our employees.
Item 2: Material Changes
Oak Asset Management, LLC is required to make clients aware of information that has changed since
the last annual update to the Firm Brochure (“Brochure”) and that may be important to them. Clients
can then determine whether to review the brochure in its entirety or to contact us with questions
about the changes.
Since our last annual amendment filed on 02/19/2025, we have no material changes to report.
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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 & Compensation ............................................................................................................................................. 5
Item 6: Performance-Based Fees & Side-By-Side Management ........................................................................... 6
Item 7: Types of Clients & Account Requirements .................................................................................................... 6
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ................................................................... 6
Item 9: Disciplinary Information..................................................................................................................................... 16
Item 10: Other Financial Industry Activities & Affiliations .................................................................................. 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 16
Item 12: Brokerage Practices ........................................................................................................................................... 17
Item 13: Review of Accounts or Financial Plans ....................................................................................................... 20
Item 14: Client Referrals & Other Compensation ..................................................................................................... 20
Item 15: Custody .................................................................................................................................................................... 21
Item 16: Investment Discretion ....................................................................................................................................... 21
Item 17: Voting Client Securities ..................................................................................................................................... 22
Item 18: Financial Information ........................................................................................................................................ 22
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Item 4: Advisory Business
Our firm provides individuals and other types of clients with a wide array of investment advisory
services. Our firm is a limited liability company formed under the laws of the State of California in
2003 and has been in business as an investment adviser since 2017. Our firm is wholly owned by Jack
Noe, Thomas Robertson, Janet Robinson and Plateau Advisors, LLC. David Watson is an indirect
owner of Oak Asset Management, LLC through his ownership interest in Plateau Advisors, LLC.
Our firm provides asset management and investment consulting services for many different types of
clients to help meet their financial goals, while remaining sensitive to risk tolerance and time
horizons. As a fiduciary, it is our duty to always act in the client’s best interest; this is accomplished
in part by knowing the client and their objectives.
Types of Advisory Services Offered
Wrap Comprehensive Portfolio Management:
Please see our Form ADV Part 2A Appendix 1 (“Wrap Fee Program Brochure”) for information
regarding our Wrap Comprehensive Portfolio Management service.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing,
monitoring and reviewing their company’s plan. As the needs of the plan sponsor dictate, areas of
advising could include: investment options, plan structure and participant education. Retirement
Plan Consulting services typically include:
Establishing an Investment Policy Statement – Our firm will assist in the development of
a statement that summarizes the investment goals and objectives along with the broad
strategies to be employed to meet the objectives.
Investment Options – Our firm will work with the Plan Sponsor to evaluate existing
investment options and make recommendations for appropriate changes.
Asset Allocation and Portfolio Construction – Our firm will develop strategic asset
allocation models to aid in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
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services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Wrap Comprehensive Portfolio Management
clients. General investment advice will be offered to our Retirement Plan Consulting clients.
Each Wrap Comprehensive Portfolio Management client may place reasonable restrictions on the types
of investments to be held in the portfolio. Restrictions on investments in certain securities or types of
securities may not be possible due to the level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Our firm only offers wrap fee accounts to our clients, which are managed on an individualized basis
according to the client’s investment objectives, financial goals, risk tolerance, etc. Please see our
Wrap Fee Program Brochure for more information.
Regulatory Assets Under Management
As of December 31, 2025, our firm manages $413,780,114 on a discretionary basis.
Item 5: Fees & Compensation
Compensation for Our Advisory Services
Wrap Comprehensive Portfolio Management:
Please see our Wrap Fee Program Brochure for information regarding our fees and compensation
for our Wrap Comprehensive Portfolio Management service.
Retirement Plan Consulting:
Retirement Plan Consulting services are only available to clients who are currently utilizing our Wrap
Comprehensive Portfolio Management service. Retirement Plan Consulting services are included in
the total advisory fee charged by our firm for our Wrap Comprehensive Portfolio Management
service. Clients will not be charged an additional fee for requesting Retirement Plan Consulting
services.
Other Types of Fees & Expenses
Wrap Comprehensive Portfolio Management clients will not incur transaction costs for trades. More
information about this can be found in our separate Wrap Fee Program Brochure. Clients may also
pay holdings charges imposed by the chosen custodian for certain investments, charges imposed
directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s
prospectus (e.g., fund management fees, distribution fees, surrender charges, variable annuity fees,
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IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers,
fees for trades executed away from custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions). Our firm does not receive a portion of these fees.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Wrap Comprehensive
Portfolio Management services in writing at any time. Upon notice of termination our firm will
process a pro-rata refund of the unearned portion of the advisory fees charged in advance.
Commissionable Securities Sales
Our firm and representatives do not sell securities for a commission in advisory accounts.
Item 6: Performance-Based Fees & Side-By-Side Management
Our firm does not charge performance-based fees.
Item 7: Types of Clients & Account Requirements
Our firm has the following types of clients:
Individuals and High Net Worth Individuals;
Trusts, Estates or Charitable Organizations;
Pension and Profit-Sharing Plans;
Corporations, Limited Liability Companies and/or Other Business Types
Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging
us.
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
The following methods of analysis and investment strategies may be utilized in formulating our
investment advice and/or managing client assets, provided that such methods and/or 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.
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in response
to certain events taking place around the world. These include events directly involving the issuers
of securities held as underlying assets of mutual funds in a client’s account, conditions affecting the
general economy, and overall market changes. Other contributing factors include local, regional, or
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global political, social, or economic instability and governmental or governmental agency responses
to economic conditions. Finally, currency, interest rate, and commodity price fluctuations may also
affect security prices and income.
The prices of, and the income generated by, most debt securities held by a client’s account may be
affected by changing interest rates and by changes in the effective maturities and credit ratings of
these securities. For example, the prices of debt securities in the client’s account generally will decline
when interest rates rise and increase when interest rates fall. In addition, falling interest rates may
cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result
in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt
securities generally have higher rates of interest and may be subject to greater price fluctuations than
shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility
that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make
timely payments of principal or interest and the security will go into default.
The guarantee of a security backed by the U.S. Treasury or the full faith and credit of the U.S.
government only covers the timely payment of interest and principal when held to maturity. This
means that the current market values for these securities will fluctuate with changes in interest rates.
Investments in securities issued by entities based outside the United States may be subject to
increased levels of the risks described above. Currency fluctuations and controls, different
accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices
could also affect investments in securities of foreign issuers. Additional factors may include
expropriation, changes in tax policy, greater market volatility, different securities market structures,
and higher transaction costs.
Various administrative difficulties, such as delays in clearing and settling portfolio transactions, or in
receiving payment of dividends can increase risk. Finally, investments in securities issued by entities
domiciled in the United States may also be subject to many of these risks.
Methods of Analysis
Securities analysis methods rely on the assumption that the companies whose securities are
purchased and/or sold, the rating agencies that review these securities, and other publicly available
sources of information about these securities, are providing accurate and unbiased data. While our
firm is alert to indications that data may be incorrect, there is always a risk that our firm’s analysis
may be compromised by inaccurate or misleading information.
Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the
business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing
a stock, futures contract, or currency using fundamental analysis there are two basic approaches one
can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis
from other types of investment analysis, such as quantitative and technical. Fundamental analysis is
performed on historical and present data, but with the goal of making financial forecasts. There are
several possible objectives: (a) to conduct a company stock valuation and predict its probable price
evolution; (b) to make a projection on its business performance; (c) to evaluate its management and
make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the
intrinsic value of the share.
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When the objective of the analysis is to determine what stock to buy and at what price, there are two
basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may
misprice a security in the short run but that the "correct" price will eventually be reached. Profits can
be made by purchasing the mispriced security and then waiting for the market to recognize its
"mistake" and reprice the security.; and (b) Technical analysis maintains that all information is
reflected already in the price of a security. Technical analysts analyze trends and believe that
sentiment changes predate and predict trend changes. Investors' emotional responses to price
movements lead to recognizable price chart patterns. Technical analysts also analyze historical
trends to predict future price movement. Investors can use one or both of these different but
complementary methods for stock picking. This presents a potential risk, as the price of a security
can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating the stock.
Technical Analysis: A security analysis methodology for forecasting the direction of prices through
the study of past market data, primarily price and volume. A fundamental principle of technical
analysis is that a market's price reflects all relevant information, so their analysis looks at the history
of a security's trading pattern rather than external drivers such as economic, fundamental and news
events. Therefore, price action tends to repeat itself due to investors collectively tending toward
patterned behavior – hence technical analysis focuses on identifiable trends and conditions.
Technical analysts also widely use market indicators of many sorts, some of which are mathematical
transformations of price, often including up and down volume, advance/decline data and other
inputs. These indicators are used to help assess whether an asset is trending, and if it is, the
probability of its direction and of continuation. Technicians also look for relationships between
price/volume indices and market indicators. Technical analysis employs models and trading rules
based on price and volume transformations, such as the relative strength index, moving averages,
regressions, inter-market and intra-market price correlations, business cycles, stock market cycles
or, classically, through recognition of chart patterns. Technical analysis is widely used among traders
and financial professionals and is very often used by active day traders, market makers and pit
traders. The risk associated with this type of analysis is that analysts use subjective judgment to
decide which pattern(s) a particular instrument reflects at a given time and what the interpretation
of that pattern should be.
Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis: Analysis of the experience and
track record of the manager of the mutual fund or ETF in an attempt to determine if that manager
has demonstrated an ability to invest over a period of time and in different economic conditions. The
underlying assets in a mutual fund or ETF are also reviewed in an attempt to determine if there is
significant overlap in the underlying investments held in another fund(s) in the Client’s portfolio. The
funds or ETFs are monitored in an attempt to determine if they are continuing to follow their stated
investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments,
past performance does not guarantee future results. A manager who has been successful may not be
able to replicate that success in the future. In addition, as our firm does not control the underlying
investments in a fund or ETF, managers of different funds held by the Client may purchase the same
security, increasing the risk to the Client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which
could make the holding(s) less suitable for the Client’s portfolio.
Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies,
and past performance of independent third-party investment managers in an attempt to determine
if that manager has demonstrated an ability to invest over a period of time and in different economic
conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies,
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concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and
reviewed. A risk of investing with a third-party manager who has been successful in the past is that
they may not be able to replicate that success in the future. In addition, as our firm does not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager
may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable
investment for our clients. Moreover, as our firm does not control the manager’s daily business and
compliance operations, our firm may be unaware of the lack of internal controls necessary to prevent
business, regulatory or reputational deficiencies.
Asset Classes & Investment Strategies
Our firm has developed the following proprietary investment strategy as part of our investment
process. The purpose of this strategy is to create a foundation for clients’ investment portfolios based
on their individual risk tolerance, investment timeframe, and specific investment goals.
Our investment philosophy is to assist in the growth of client wealth over time by investing in
companies with strong cash flow, consistent earnings and management committed to creating
shareholder value. Companies with these characteristics tend to have the ability to reinvest in their
business, acquire other business, buy back company stock or provide shareholders with a cash
dividend. Dividends are a direct source of income and historically have been an important component
of a stock’s total return. Even more compelling are companies that choose to reward shareholders by
regularly increasing their dividend payments. These businesses are generally less sensitive to
downward swings in the economy and can help provide a hedge against inflation. Most importantly,
we believe that if a company can consistently raise dividends, capital appreciation will follow. The
core of our clients’ portfolios is built on this principle.
Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus
reward by adjusting the percentage of each asset in an investment portfolio according to the
investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle
that different assets perform differently in different market and economic conditions. A fundamental
justification for asset allocation is the notion that different asset classes offer returns that are not
perfectly correlated, hence diversification reduces the overall risk in terms of the variability of
returns for a given level of expected return. Although risk is reduced as long as correlations are not
perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation
and variance) that existed over some past period. Expectations for return are often derived in the
same way.
Cash & Cash Equivalents: Cash and cash equivalents generally refer to either United States dollars
or highly liquid short-term debt instruments such as, but not limited to, treasury bills, bank CD’s and
commercial papers. Generally, these assets are considered nonproductive and will be exposed to
inflation risk and considerable opportunity cost risk. Investments in cash and cash equivalents will
generally return less than the advisory fee charged by our firm. Our firm may recommend cash and
cash equivalents as part of our clients’ asset allocation when deemed appropriate and in their best
interest. Our firm considers cash and cash equivalents to be an asset class. Therefore, our firm assess
an advisory fee on cash and cash equivalents unless indicated otherwise in writing.
Equity Securities: Equity securities represent an ownership position in a company. Equity securities
typically consist of common stocks. The prices of equity securities fluctuate based on, among other
things, events specific to their issuers and market, economic and other conditions. For example,
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prices of these securities can be affected by financial contracts held by the issuer or third parties
(such as derivatives) relating to the security or other assets or indices. There may be little trading in
the secondary market for particular equity securities, which may adversely affect Our firm 's ability
to value accurately or dispose of such equity securities. Adverse publicity and investor perceptions,
whether or not based on fundamental analysis, may decrease the value and/or liquidity of equity
securities. Investing in smaller companies may pose additional risks as it is often more difficult to
value or dispose of small company stocks, more difficult to obtain information about smaller
companies, and the prices of their stocks may be more volatile than stocks of larger, more established
companies. Clients should have a long-term perspective and, for example, be able to tolerate
potentially sharp declines in value.
Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or
periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income
investors are typically retired individuals who rely on their investments to provide a regular, stable
income stream. This demographic tends to invest heavily in fixed-income investments because of the
reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid
income face the risk of inflation eroding their spending power.
Some examples of fixed-income investments include treasuries, money market instruments,
corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk
associated with fixed-income investments is the borrower defaulting on his payment. Other
considerations include exchange rate risk for international bonds and interest rate risk for longer-
dated securities. The most common type of fixed-income security is a bond. Bonds are issued by
federal governments, local municipalities and major corporations. Fixed-income securities are
recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio
dedicated to fixed income depends on your own personal investment style. There is also an
opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products,
such as junk bonds and longer-dated products, should comprise a lower percentage of your overall
portfolio.
The interest payment on fixed-income securities is considered regular income and is determined
based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed-
income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate,
because they are considered riskier. The longer the security is on the market, the more time it has to
lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns
the amount borrowed, also referred to as the principal or par value.
Exchange Traded Funds (“ETFs”): An ETF is a type of Investment Company (usually, an open-end
fund or unit investment trust) whose primary objective is to achieve the same return as a particular
market index. The vast majority of ETFs are designed to track an index, so their performance is close
to that of an index mutual fund, but they are not exact duplicates. A tracking error, or the difference
between the returns of a fund and the returns of the index, can arise due to differences in
composition, management fees, expenses, and handling of dividends. ETFs benefit from continuous
pricing; they can be bought and sold on a stock exchange throughout the trading day. Because ETFs
trade like stocks, you can place orders just like with individual stocks - such as limit orders, good-
until-canceled orders, stop loss orders etc. They can also be sold short. Traditional mutual funds are
bought and redeemed based on their net asset values (“NAV”) at the end of the day. ETFs are bought
and sold at the market prices on the exchanges, which resemble the underlying NAV but are
independent of it. However, arbitrageurs will ensure that ETF prices are kept very close to the NAV
of the underlying securities. Although an investor can buy as few as one share of an ETF, most buy in
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board lots. Anything bought in less than a board lot will increase the cost to the investor. Anyone can
buy any ETF no matter where in the world it trades. This provides a benefit over mutual funds, which
generally can only be bought in the country in which they are registered.
One of the main features of ETFs are their low annual fees, especially when compared to traditional
mutual funds. The passive nature of index investing, reduced marketing, and distribution and
accounting expenses all contribute to the lower fees. However, individual investors must pay a
brokerage commission to purchase and sell ETF shares; for those investors who trade frequently,
this can significantly increase the cost of investing in ETFs. That said, with the advent of low-cost
brokerage fees, small or frequent purchases of ETFs are becoming more cost efficient.
Master Limited Partnerships (“MLPs”): MLPs are publicly traded partnerships that trade mainly
on the New York Stock Exchange and/or the NASDAQ, the same as stocks. With a few exceptions,
MLPs hold and operate assets related to the transportation and storage of energy (certain MLPs may
have commodity risk). Most publicly traded companies are corporations. Corporate earnings are
usually taxed twice. The business entity is taxed on any money it makes and then shareholders are
taxed on the earnings the company distributes to them. In the 1980s, Congress allowed public trading
of certain types of companies as partnerships instead of corporations. The main advantage a
partnership has over a corporation is that partnerships are “pass through” entities for tax purposes.
This means that the company does not pay any tax on its earnings. Distributions are still taxed, but
this avoids the problem of double taxation that most publicly traded companies face. Congress
requires that any company designated as an MLP has to produce 90% of its earnings from “qualified
resources” (natural resources and real estate). Most MLPs are involved in energy infrastructure, i.e.
things like pipelines. MLPs are required to pay minimum quarterly distributions to limited partners.
A contract establishes the payments, so distributions are predictable. Otherwise, the shareholders
could find the company in breach of contract.
Real Estate Investment Trusts (“REITs”): REITs primarily invest in real estate or real estate-
related loans. Equity REITs own real estate properties, while mortgage REITs hold construction,
development and/or long-term mortgage loans. Changes in the value of the underlying property of
the trusts, the creditworthiness of the issuer, property taxes, interest rates, tax laws, and regulatory
requirements, such as those relating to the environment all can affect the values of REITs. Both types
of REITs are dependent upon management skill, the cash flows generated by their holdings, the real
estate market in general, and the possibility of failing to qualify for any applicable pass-through tax
treatment or failing to maintain any applicable exemptive status afforded under relevant laws.
Mutual Funds: A mutual fund is a company that pools money from many investors and invests the
money in a variety of differing security types based the objectives of the fund. The portfolio of the
fund consists of the combined holdings it owns. Each share represents an investor’s proportionate
ownership of the fund’s holdings and the income those holdings generate. The price that investors
pay for mutual fund shares is the fund’s per share net asset value (“NAV”) plus any shareholder fees
that the fund imposes at the time of purchase (such as sales loads). Investors typically cannot
ascertain the exact make-up of a fund’s portfolio at any given time, nor can they directly influence
which securities the fund manager buys and sells or the timing of those trades. With an individual
stock, investors can obtain real-time (or close to real-time) pricing information with relative ease by
checking financial websites or by calling a broker or your investment adviser. Investors can also
monitor how a stock’s price changes from hour to hour—or even second to second. By contrast, with
a mutual fund, the price at which an investor purchases or redeems shares will typically depend on
the fund’s NAV, which is calculated daily after market close.
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The benefits of investing through mutual funds include: (a) Mutual funds are professionally managed
by an investment adviser who researches, selects, and monitors the performance of the securities
purchased by the fund; (b) Mutual funds typically have the benefit of diversification, which is an
investing strategy that generally sums up as “Don’t put all your eggs in one basket.” Spreading
investments across a wide range of companies and industry sectors can help lower the risk if a
company or sector fails. Some investors find it easier to achieve diversification through ownership of
mutual funds rather than through ownership of individual stocks or bonds.; (c) Some mutual funds
accommodate investors who do not have a lot of money to invest by setting relatively low dollar
amounts for initial purchases, subsequent monthly purchases, or both.; and (d) At any time, mutual
fund investors can readily redeem their shares at the current NAV, less any fees and charges assessed
on redemption.
Mutual funds also have features that some investors might view as disadvantages: (a) Investors must
pay sales charges, annual fees, and other expenses regardless of how the fund performs. Depending
on the timing of their investment, investors may also have to pay taxes on any capital gains
distribution they receive. This includes instances where the fund went on to perform poorly after
purchasing shares.; (b) Investors typically cannot ascertain the exact make-up of a fund’s portfolio at
any given time, nor can they directly influence which securities the fund manager buys and sells or
the timing of those trades.; and (c) With an individual stock, investors can obtain real-time (or close
to real-time) pricing information with relative ease by checking financial websites or by calling a
broker or your investment adviser. Investors can also monitor how a stock’s price changes from hour
to hour—or even second to second. By contrast, with a mutual fund, the price at which an investor
purchases or redeems shares will typically depend on the fund’s NAV, which the fund might not
calculate until many hours after the investor placed the order. In general, mutual funds must calculate
their NAV at least once every business day, typically after the major U.S. exchanges close.
When investors buy and hold an individual stock or bond, the investor must pay income tax each year
on the dividends or interest the investor receives. However, the investor will not have to pay any
capital gains tax until the investor actually sells and makes a profit. Mutual funds are different. When
an investor buys and holds mutual fund shares, the investor will owe income tax on any ordinary
dividends in the year the investor receives or reinvests them. Moreover, in addition to owing taxes
on any personal capital gains when the investor sells shares, the investor may have to pay taxes each
year on the fund’s capital gains. That is because the law requires mutual funds to distribute capital
gains to shareholders if they sell securities for a profit, and cannot use losses to offset these gains.
Options: An option is a financial derivative that represents a contract sold by one party (the option
writer) to another party (the option holder). The contract offers the buyer the right, but not the
obligation, to buy (call) or sell (put) a security or other financial asset at an agreed-upon price (the
strike price) during a certain period of time or on a specific date (exercise date). Options are
extremely versatile securities. Traders use options to speculate, which is a relatively risky practice,
while hedgers use options to reduce the risk of holding an asset.
Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to
go up. Conversely, the option writer needs to provide the underlying shares in the event that the
stock's market price exceeds the strike due to the contractual obligation. An option writer who sells
a call option believes that the underlying stock's price will drop relative to the option's strike price
during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite
outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens,
the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if
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the underlying stock does not close above the strike price on the expiration date, the option buyer
would lose the premium paid for the call option.
Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to
go down. The opposite is true for put option writers. For example, a put option buyer is bearish on
the underlying stock and believes its market price will fall below the specified strike price on or
before a specified date. On the other hand, an option writer who shorts a put option believes the
underlying stock's price will increase about a specified price on or before the expiration date. If the
underlying stock's price closes above the specified strike price on the expiration date, the put option
writer's maximum profit is achieved. Conversely, a put option holder would only benefit from a fall
in the underlying stock's price below the strike price. If the underlying stock's price falls below the
strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike
price.
The potential risks associated with these transactions are that (1) all options expire. The closer the
option gets to expiration, the quicker the premium in the option deteriorates; and (2) Prices can move
very quickly. Depending on factors such as time until expiration and the relationship of the stock
price to the option’s strike price, small movements in a stock can translate into big movements in the
underlying options.
Long-Term Purchases: Our firm may buy securities for your account and hold them for a relatively
long time (more than a year) in anticipation that the security’s value will appreciate over a long
horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that
could have been profitable to your account, or it’s possible that the security’s value may decline
sharply before our firm make a decision to sell.
Margin Transactions: Our firm may purchase stocks, mutual funds, and/or other securities for your
portfolio with money borrowed from your brokerage account. This allows you to purchase more
stock than you would be able to with your available cash, and allows us to purchase stock without
selling other holdings. Margin accounts and transactions are risky and not necessarily appropriate
for every client. The potential risks associated with these transactions are (1) You can lose more
funds than are deposited into the margin account; (2) the forced sale of securities or other assets in
your account; (3) the sale of securities or other assets without contacting you; and (4) you may not
be entitled to choose which securities or other assets in your account(s) are liquidated or sold to
meet a margin call.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock
market may increase and the account(s) could enjoy a gain, it is also possible that the stock market
may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks
associated with investing in the stock market, are appropriately diversified in investments, and ask
any questions.
Capital Risk: Capital risk is one of the most basic, fundamental risks of investing; it is the risk that
you may lose 100% of your money. All investments carry some form of risk and the loss of capital is
generally a risk for any investment instrument.
Company Risk: When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
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and can be reduced through appropriate diversification. There is the risk that the company will
perform poorly or have its value reduced based on factors specific to the company or its industry.
For example, if a company’s employees go on strike or the company receives unfavorable media
attention for its actions, the value of the company may be reduced.
Credit Risk: Credit risk can be a factor in situations where an investment’s performance relies on a
borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or
unfavorable performance if a borrower does not repay the borrowed funds as expected or required.
Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit
risk.
Currency Risk: Fluctuations in the value of the currency in which your investment is denominated
may affect the value of your investment and thus, your investment may be worth more or less in the
future. All currency is subject to swings in valuation and thus, regardless of the currency
denomination of any particular investment you own, currency risk is a realistic risk measure. That
said, currency risk is generally a much larger factor for investment instruments denominated in
currencies other than the most widely used currencies (U.S. Dollar, British Pound, German Mark,
Euro, Japanese Yen, French Franc, etc.).
Economic Risk: The prevailing economic environment is important to the health of all businesses.
Some companies, however, are more sensitive to changes in the domestic or global economy than
others. These types of companies are often referred to as cyclical businesses. Countries in which a
large portion of businesses are in cyclical industries are thus also very economically sensitive and
carry a higher amount of economic risk. If an investment is issued by a party located in a country that
experiences wide swings from an economic standpoint or in situations where certain elements of an
investment instrument are hinged on dealings in such countries, the investment instrument will
generally be subject to a higher level of economic risk.
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market fluctuations
and to volatile increases and decreases in value as market confidence in and perceptions of their
issuers change. If you held common stock, or common stock equivalents, of any given issuer, you
would generally be exposed to greater risk than if you held preferred stocks and debt obligations of
the issuer.
ETF & Mutual Fund Risk: When investing in an ETF or mutual fund, you will bear additional
expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally
reflects the risks of owning the underlying securities the ETF or mutual fund holds. Clients will also
incur brokerage costs when purchasing ETFs.
Financial Risk: Financial risk is represented by internal disruptions within an investment or the
issuer of an investment that can lead to unfavorable performance of the investment. Examples of
financial risk can be found in cases like Enron or many of the dot com companies that were caught
up in a period of extraordinary market valuations that were not based on solid financial footings of
the companies.
Fixed Income Securities Risk: Typically, the values of fixed-income securities change inversely with
prevailing interest rates. Therefore, a fundamental risk of fixed-income securities is interest rate risk,
which is the risk that their value will generally decline as prevailing interest rates rise, which may
cause your account value to likewise decrease, and vice versa. How specific fixed income securities
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may react to changes in interest rates will depend on the specific characteristics of each security.
Fixed-income securities are also subject to credit risk, prepayment risk, valuation risk, and liquidity
risk. Credit risk is the chance that a bond issuer will fail to pay interest and principal in a timely
manner, or that negative perceptions of the issuer’s ability to make such payments will cause the
price of a bond to decline.
Inflation Risk: Inflation risk involves the concern that in the future, your investment or proceeds
from your investment will not be worth what they are today. Throughout time, the prices of resources
and end-user products generally increase and thus, the same general goods and products today will
likely be more expensive in the future. The longer an investment is held, the greater the chance that
the proceeds from that investment will be worth less in the future than what they are today. Said
another way, a dollar tomorrow will likely get you less than what it can today.
Interest Rate Risk: Certain investments involve the payment of a fixed or variable rate of interest to
the investment holder. Once an investor has acquired or has acquired the rights to an investment that
pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market
will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing
interest rates in the market will have an inverse relationship to the value of existing, interest paying
investments. In other words, as interest rates move up, the value of an instrument paying a particular
rate (fixed or variable) of interest will go down. The reverse is generally true as well.
Legal/Regulatory Risk: Certain investments or the issuers of investments may be affected by
changes in state or federal laws or in the prevailing regulatory framework under which the
investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws
can affect the performance of certain investments or issuers of those investments and thus, can have
a negative impact on the overall performance of such investments.
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very limited
market in which they trade. Thus, you may experience the risk that your investment or assets within
your investment may not be able to be liquidated quickly, thus, extending the period of time by which
you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable
pricing when exiting (i.e., not being able to quickly get out of an investment before the price drops
significantly) a particular investment and therefore, can have a negative impact on investment
returns.
Manager Risk: There is always the possibility that poor security selection will cause your
investments to underperform relative to benchmarks or other funds with a similar investment
objective.
Market Risk: The value of your portfolio may decrease if the value of an individual company or
multiple companies in the portfolio decreases or if our belief about a company’s intrinsic worth is
incorrect. Further, regardless of how well individual companies perform, the value of your portfolio
could also decrease if there are deteriorating economic or market conditions. It is important to
understand that the value of your investment may fall, sometimes sharply, in response to changes in
the market, and you could lose money. Investment risks include price risk as may be observed by a
drop in a security’s price due to company specific events (e.g. earnings disappointment or downgrade
in the rating of a bond) or general market risk (e.g. such as a “bear” market when stock values fall in
general). For fixed-income securities, a period of rising interest rates could erode the value of a bond
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since bond values generally fall as bond yields go up. Past performance is not a guarantee of future
returns.
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Purchasing and writing put and call options are highly
specialized activities and entail greater than ordinary investment risks.
Past Performance: Charting and Technical Analysis are often used interchangeably. Technical
analysis generally attempts to forecast an investment’s future potential by analyzing its past
performance and other related statistics. In particular, Technical Analysis often times involves an
evaluation of historical pricing and volume of a particular security for the purpose of forecasting
where future price and volume figures may go. As with any investment analysis method, Technical
Analysis runs the risk of not knowing the future and thus, investors should realize that even the most
diligent and thorough technical analysis cannot predict or guarantee the future performance of any
particular investment instrument or issuer thereof.
Description of Material, Significant or Unusual Risks
Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of
Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, our
firm tries to achieve the highest return on client cash balances through relatively low-risk
conservative investments. In most cases, at least a partial cash balance will be maintained in a money
market account so that our firm may debit advisory fees for our Wrap Comprehensive Portfolio
Management service.
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to the evaluation of our advisory business
or the integrity of our management.
Item 10: Other Financial Industry Activities & Affiliations
Representatives of our firm are licensed insurance agents. As a result of these transactions, they
receive normal and customary commissions. A conflict of interest exists as these commissionable
sales create an incentive to recommend products based on the compensation earned. To mitigate this
potential conflict, our firm will act in the client’s best interest.
Item 11: Code of Ethics, Participation or Interest in
Client Transactions & Personal Trading
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. Our fiduciary duty is the
underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities
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transaction and insider trading. Our firm requires all representatives 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 with our firm, and at least annually thereafter, all representatives of our firm will
acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure
is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to
review our Code of Ethics in its entirety, a copy will be provided promptly upon request.
Our firm recognizes that the personal investment transactions of our representatives demands the
application of a Code of Ethics with high standards and requires that all such transactions be carried out
in a way that does not endanger the interest of any client. At the same time, our firm also believes that if
investment goals are similar for clients and for our representatives, it is logical, and even desirable, that
there be common ownership of some securities.
In order to prevent conflicts of interest, our firm has established procedures for transactions effected by
our representatives for their personal accounts1. In order to monitor compliance with our personal
trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting
system for all of our representatives.
Neither our firm nor a related person recommends, buys or sells for client accounts, securities in
which our firm or a related person has a material financial interest without prior disclosure to the
client.
Related persons of our firm may buy or sell securities and other investments that are also
recommended to clients. In order to minimize this conflict of interest, our related persons will place
client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which
is available upon request.
Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they
buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our
related persons will place client interests ahead of their own interests and adhere to our firm’s Code of
Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying
or selling the same securities prior to buying or selling for our clients in the same day unless included in
a block trade.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
Our firm does not maintain custody of client assets. Client assets must be maintained by a qualified
custodian. Our firm seeks to recommend a custodian who will hold client assets and execute
1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse,
his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our
associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect
beneficial interest in.
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transactions on terms that are overall most advantageous when compared to other available
providers and their services. The factors considered, among others, are these:
Timeliness of execution
Timeliness and accuracy of trade confirmations
Research services provided
Ability to provide investment ideas
Execution facilitation services provided
Record keeping services provided
Custody services provided
Frequency and correction of trading errors
Ability to access a variety of market venues
Expertise as it relates to specific securities
Financial condition
Business reputation
Quality of services
With this in consideration, our firm has an arrangement with Trade-PMR, Inc. and Wells Fargo Clearing
Services, LLC (hereinafter referred to as the “Custodian”), a qualified custodian from whom our firm is
independently owned and operated. The Custodian offers services to independent investment advisers
which includes custody of securities, trade execution, clearance and settlement of transactions. The
Custodian enables us to obtain many no-load mutual funds without transaction charges and other no-
load funds at nominal transaction charges. The Custodian does not charge client accounts separately
for custodial services.
The Custodian may make certain research and brokerage services available at no additional cost to
our firm. Research products and services provided by the Custodian may include: research reports on
recommendations or other information about particular companies or industries; economic surveys,
data and analyses; financial publications; portfolio evaluation services; financial database software and
services; computerized news and pricing services; quotation equipment for use in running software
used in investment decision-making; and other products or services that provide lawful and appropriate
assistance by the Custodian to our firm in the performance of our investment decision-making
responsibilities. The aforementioned research and brokerage services qualify for the safe harbor
exemption defined in Section 28(e) of the Securities Exchange Act of 1934.
The Custodian does not make client brokerage commissions generated by client transactions
available for our firm’s use. The aforementioned research and brokerage services are used by our
firm to manage accounts for which our firm has investment discretion. Without this arrangement,
our firm might be compelled to purchase the same or similar services at our own expense.
As part of our fiduciary duty to our clients, our firm will endeavor at all times to put the interests of
our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm
or our related persons creates a potential conflict of interest and may indirectly influence our firm’s
choice of the Custodian as a custodial recommendation. Our firm examined this potential conflict of
interest when our firm chose to recommend the Custodian and have determined that the
recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations,
including our duty to seek best execution.
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Oak Asset Management, LLC
In seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including the value of research provided, execution capability, commission
rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients,
our firm may not necessarily obtain the lowest possible commission rates for specific client account
transactions.
Soft Dollars
Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities
Exchange Act of 1934. The safe harbor research products and services obtained by our firm will
generally be used to service all our clients but not necessarily all at any one particular time.
Brokerage Commissions & Client Referrals
The Custodian does not make client brokerage commissions generated by client transactions
available for our firm’s use. Our firm does not direct client transactions to a particular broker-dealer
in return for soft dollar benefits. Our firm does not receive brokerage for client referrals.
Directed Brokerage
Neither our firm nor any of our firm’s representatives have discretionary authority in making the
determination of the brokers-dealers and/or custodians with whom orders for the purchase or sale
of securities are placed for execution, and the commission rates at which such securities transactions
are effected. Our firm recommends the use of the Custodian. Each client will be required to establish
their account(s) with the Custodian if not already done. Please note that not all advisers have this
requirement.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account
through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such
direction is permitted provided that the goods and services provided are reasonable expenses of the
plan incurred in the ordinary course of its business for which it otherwise would be obligated and
empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services
purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan
sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will
be for the exclusive benefit of the plan.
Client-Directed Brokerage
Our firm allows clients to direct brokerage outside our recommendation. Our firm may be unable to
achieve the most favorable execution of client transactions. Client directed brokerage may cost
clients more money. For example, in a directed brokerage account, clients may pay higher brokerage
commissions because our firm may not be able to aggregate orders to reduce transaction costs, or
clients may receive less favorable prices.
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Aggregation of Purchase or Sale
Our firm provides investment management services for various clients. There are occasions on which
portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same
security for numerous accounts served by our firm, which involve accounts with similar investment
objectives. Although such concurrent authorizations potentially could be either advantageous or
disadvantageous to any one or more particular accounts, they are affected only when our firm believes
that to do so will be in the best interest of the effected accounts. When such concurrent authorizations
occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts
involved. In any given situation, our firm attempts to allocate trade executions in the most equitable
manner possible, taking into consideration client objectives, current asset allocation and availability of
funds using price averaging, proration and consistently non-arbitrary methods of allocation.
Item 13: Review of Accounts or Financial Plans
Our management personnel or financial advisors review accounts on at least an annual basis for our
Wrap Comprehensive Portfolio Management clients. The nature of these reviews is to learn whether
client accounts are in line with their investment objectives, appropriately positioned based on
market conditions, and investment policies, if applicable. Our firm does not provide written reports
to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when
our Wrap Comprehensive Portfolio Management clients are contacted. Our firm may review client
accounts more frequently than described above. Among the factors which may trigger an off-cycle
review are major market or economic events, the client’s life events, requests by the client, etc.
Clients utilizing our Retirement Plan Consulting service will receive reviews of their retirement plans
for the duration of the service. Our firm also provides ongoing services where clients are met with
upon their request to discuss updates to their plans, changes in their circumstances, etc.
Item 14: Client Referrals & Other Compensation
Trade-PMR, Inc. & Wells Fargo Clearing Services, LLC
Except for the arrangements outlined in Item 12 of Form ADV Part 2A, our firm has no additional
arrangements to disclose.
Referral Fees
In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm does not provide
cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or
endorsements (which include client referrals).
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Item 15: Custody
Deduction of Advisory Fees:
While our firm does not maintain physical custody of client assets (which are maintained by a
qualified custodian, as discussed above), we are deemed to have custody of certain client assets if
given the authority to withdraw assets from client accounts, as further described below under “Third-
Party Money Movement.” All our clients receive account statements directly from their qualified
custodian at least quarterly upon opening of an account. If our firm decides to also send account
statements to clients, such notice and account statements include a legend that recommends that the
client compare the account statements received from the qualified custodian with those received
from our firm. Clients are encouraged to raise any questions with us about the custody, safety or
security of their assets and our custodial recommendations.
Third-Party Money Movement:
On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to the Rule 206(4)-2
(“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided
guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client
funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody.
As such, our firm has adopted the following safeguards in conjunction with the account custodian:
The client provides an instruction to the qualified custodian, in writing, that includes the
client’s signature, the third party’s name, and either the third party’s address or the third
party’s account number at a custodian to which the transfer should be directed.
The client authorizes the investment adviser, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified schedule or from
time to time.
The client’s qualified custodian performs appropriate verification of the instruction, such as
a signature review or other method to verify the client’s authorization, and provides a
transfer of funds notice to the client promptly after each transfer.
The client has the ability to terminate or change the instruction to the client’s qualified
custodian.
The investment adviser has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the
client’s instruction.
The investment adviser maintains records showing that the third party is not a related party
of the investment adviser or located at the same address as the investment adviser.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
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Generally, clients must provide our firm with investment discretion on their behalf, pursuant to an
executed investment advisory client agreement. By granting investment discretion, our firm is
authorized to execute securities transactions, determine which securities are bought and sold, and
the total amount to be bought and sold. Limitations may be imposed by the client in the form of
specific constraints on any of these areas of discretion with our firm’s written acknowledgement.
Item 17: Voting Client Securities
Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent
to our firm, our firm will forward them to the appropriate client and ask the party who sent them to
mail them directly to the client in the future. Clients may call, write or email us to discuss questions
they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
Our firm is not required to provide financial information in this Brochure because:
Our firm does not require the prepayment of more than $1,200 in fees when services cannot
be rendered within 6 months.
Our firm does not take custody of client funds or securities.
Our firm does not have a financial condition or commitment that impairs our ability to meet
contractual and fiduciary obligations to clients.
Our firm has never been the subject of a bankruptcy proceeding.
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