Overview
- Headquarters
- Albuquerque, NM
- Total Firm Assets
- $150 million
- Average High-Net-Worth Client Portfolio Size
- $1.2 million
- Minimum Account Size
- $100,000
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A & 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.20% |
| $500,001 | $1,000,000 | 0.95% |
| $1,000,001 | $3,000,000 | 0.75% |
| $3,000,001 | and above | 0.45% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,750 | 1.08% |
| $5 million | $34,750 | 0.70% |
| $10 million | $57,250 | 0.57% |
| $50 million | $237,250 | 0.47% |
| $100 million | $462,250 | 0.46% |
Clients
- High-Net-Worth Share of Firm Assets
- 47.78%
- Number of High-Net-Worth Clients
- 58
- Total Client Accounts
- 1,146
- Discretionary Accounts
- 1,112
- Non-Discretionary Accounts
- 34
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 158890
Primary Brochure: FORM ADV PART 2A & 2B (2026-05-26)
View Document Text
Oakmont Advisory Group, LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Oakmont Advisory Group,
LLC. If you have any questions about the contents of this brochure, please contact us at (505) 821-6966 or by email
at: info@oakmontadvisory.com. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Additional information about Oakmont Advisory Group, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Oakmont Advisory Group, LLC’s CRD number is: 158890.
2001 Carlisle Blvd NE Suite D
Albuquerque, NM 87110
(505) 821-6966
info@oakmontadvisory.com
https://oakmontadvisory.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 05/26/2026
i
Item 2: Material Changes
There are no material changes in this brochure from the last annual updating amendment on 03/31/2026
of Oakmont Advisory Group, LLC. Material changes relate to Oakmont Advisory Group, LLC’s policies,
practices or conflicts of interests.
ii
Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................2
Item 5: Fees and Compensation .............................................................................................................................4
Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................9
Item 7: Types of Clients ..........................................................................................................................................9
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................9
Item 9: Disciplinary Information .........................................................................................................................14
Item 10: Other Financial Industry Activities and Affiliations .........................................................................14
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............16
Item 12: Brokerage Practices ................................................................................................................................17
Item 13: Review of Accounts ................................................................................................................................18
Item 14: Client Referrals and Other Compensation ..........................................................................................19
Item 15: Custody ....................................................................................................................................................19
Item 16: Investment Discretion ............................................................................................................................19
Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................20
Item 18: Financial Information .............................................................................................................................20
Form ADV Part 2B – Supplement Brochure…………………………………………………………….....................22
iii
Item 4: Advisory Business
A. Description of the Advisory Firm
Oakmont Advisory Group, LLC (hereinafter “OAK”) is a Limited Liability Company
organized in the State of New Mexico. The firm was formed in October 2011, and the
principal owners are Ralph William Hicks and David Bradford Hicks.
B. Types of Advisory Services
Portfolio Management Services
OAK offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. OAK creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
OAK evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. OAK will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
OAK seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of OAK’s economic,
investment or other financial interests. To meet its fiduciary obligations, OAK attempts to
avoid, among other things, investment or trading practices that systematically advantage
or disadvantage certain client portfolios, and accordingly, OAK’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is OAK’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent among its
clients on a fair and equitable basis over time.
OAK may direct clients to third-party investment advisers to manage all or a portion of
the client's assets. Before selecting other advisers for clients, OAK will always ensure those
other advisers are properly licensed or registered as an investment adviser. OAK conducts
due diligence on any third-party investment adviser, which may involve one or more of
the following: phone calls, meetings and review of the third-party adviser's performance
2
and investment strategy. OAK then makes investments with a third-party investment
adviser by referring the client to the third-party adviser. OAK will review the ongoing
performance of the third-party adviser as a portion of the client's portfolio.
Pension Consulting Services
OAK offers consulting services to pension or other employee benefit plans (including but
not limited to 401(k) plans). Pension consulting may include, but is not limited to:
•
•
•
identifying investment objectives and restrictions
providing guidance on various assets classes and investment options
recommending money managers to manage plan assets in ways designed
to achieve objectives
•
monitoring performance of money managers and investment options and
making recommendations for changes
•
recommending other service providers, such as custodians, administrators
and broker-dealers
•
creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Services Limited to Specific Types of Investments
OAK generally limits its investment advice to mutual funds, fixed income securities,
insurance products including annuities, equities, ETFs and non-U.S. securities. OAK may
use other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
3
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
OAK will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by OAK on behalf of the client. OAK may use model allocations together
with a specific set of recommendations for each client based on their personal restrictions,
needs, and targets. Clients may impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs. However, if the restrictions
prevent OAK from properly servicing the client account, or if the restrictions would
require OAK to deviate from its standard suite of services, OAK reserves the right to end
the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. OAK does not participate in wrap fee
programs.
E. Assets Under Management
OAK has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$141,615,510
$7,891,213
December 31,
2025
Item 5: Fees and Compensation
For clients whose assets are managed through the Signal Advisors Wealth, LLC platform, a
platform fee of 0.30% annually is charged in addition to Oakmont Advisory Group\'s reduced
management fee. The combined fee is billed monthly in arrears and collected directly from the
client\'s custodial account at Altruist Financial, LLC. The total combined fee charged to clients
on the Signal Advisors platform ranges from 0.55% to 1.30% annually depending on the client\'s
asset level, as set forth in the firm\'s fee schedule.
A. Fee Schedule
Portfolio Management Fees
4
Total Assets Under Management Annual Fees
$1 - $500,000
1.20%
$500,001 - $1,000,000
0.95%
$1,000,001 - $3,000,000
0.75%
$3,000,000 - AND UP
0.45%
OAK uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals, for purposes of determining the market
value of the assets upon which the advisory fee is based.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of OAK's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract generally
with 30 days' written notice.
Selection of Other Advisers Fees
OAK will be compensated via a fee share from the advisers to which it directs those
clients. This relationship will be memorialized in each contract between OAK and each
third-party adviser. The fees shared will not exceed any limit imposed by any regulatory
agency.
OAK may direct clients to Signal Advisors. The annual fee schedule is as follows:
Total
OAK’s Fee
Signal’s Fee
Total Assets Under
Management
$1- $500,000
1.30%
1.00%
0.30%
$500,001 – $1,000, 000
1.05%
0.75%
0.30%
$1,000,001 - $3,000,000
0.85%
0.55%
0.30%
$3,000,001 - AND UP
0.55%
0.25%
0.30%
5
OAK may direct clients to Brookstone Capital Management The annual fee schedule is as
follows:
Total
OAK’s Fee
Total Assets Under
Management
Brookstone’s
Fee
$1- $250,001
1.50%
0.95%
0.55%
$250,001 – $500,000
1.40%
0.85%
0.55%
$500,001- $750,000
1.25%
0.75%
0.50%
$750,001 - $1,000,000
1.15%
0.65%
0.50%
0.90%
0.45%
0.45%
$1,000,001 – AND UP
OAK may direct clients to Gradient Investments. The annual fee schedule is as follows:
Total
OAK’s Fee
Total Assets Under
Management
Gradient’s
Fee
$1- $250,001
1.95%
0.95%
1.00%
$250,001 – $500,000
1.85%
0.85%
1.00%
$500,001- $750,000
1.75%
0.75%
1.00%
$750,001 - $1,000,000
1.65%
0.65%
1.00%
1.45%
0.45%
1.00%
$1,000,001 – AND UP
OAK may direct clients to CLS Investments, LLC. The annual fee schedule is as follows:
Total
OAK’s Fee
CLS’s Fee
Total Assets Under
Management
All Assets
0.90%
0.65%
0.25%
6
OAK uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals. for purposes of determining the market
value of the assets upon which the advisory fee is based.
These fees are negotiable.
Pension Consulting Services Fees
Asset-Based Fees for Pension Consulting
Total Assets Under Management Annual Fee
$1 - $500,000
1.20%
$500,001 - $1,000,000
0.95%
$1,000,001 - $3,000,000
0.75%
$3,000,001 - AND UP
0.45%
OAK uses the value of the account as of the last business day of the billing period, after
taking into account deposits and withdrawals, for purposes of determining the market
value of the assets upon which the advisory fee is based.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement.
Clients may terminate the agreement without penalty for a full refund of OAK's fees
within five business days of signing the Investment Advisory Contract. Thereafter, clients
may terminate the pension consulting agreement generally with 30 days' written notice.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly basis. Fees are paid in arrears.
Payment of Pension Consulting Fees
Asset-based pension consulting fees are withdrawn directly from the client's accounts
with client's written authorization on a monthly basis. Fees are paid in arrears.
7
Payment of Selection of Other Advisers Fees
Fees for selection of Brookstone Capital Management as third-party adviser are
withdrawn directly from the client's accounts with client's written authorization. Fees are
paid monthly in arrears.
Fees for selection of CLS Investments, LLC as third-party adviser are withdrawn directly
from the client's accounts with client's written authorization. Fees are paid quarterly in
arrears.
Fees for selection of Gradient Investments as third-party adviser are withdrawn directly
from the client's accounts with client's written authorization. Fees are paid quarterly in
arrears.
Fees for selection of Signal Advisors Wealth, LLC as third-party adviser are withdrawn
directly from the client's accounts with client's written authorization. Fees are paid
monthly in arrears.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by OAK. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
OAK collects its fees in arrears. It does not collect fees in advance.
E. Outside Compensation For the Sale of Securities to Clients
Ralph William Hicks, David Bradford Hicks and Brandon Connor Kinsner are insurance
agents. In this role, they accept compensation for the sale of investment products to OAK
clients.
1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of investment products,
including asset based sales charges or service fees from the sale of mutual funds to
OAK's clients. This presents a conflict of interest and gives the supervised person an
incentive to recommend products based on the compensation received rather than on
the client’s needs. When recommending the sale of investment products for which the
supervised persons receives compensation, OAK will document the conflict of interest
in the client file and inform the client of the conflict of interest.
8
2. Clients Have the Option to Purchase Recommended Products From
Other Brokers
Clients always have the option to purchase OAK recommended products through
other brokers or agents that are not affiliated with OAK.
3. Commissions are not OAK's primary source of compensation for
advisory services
Commissions are not OAK’s primary source of compensation for advisory services.
4. Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or
markups on investment products recommended to clients.
Item 6: Performance-Based Fees and Side-By-Side Management
OAK does not accept performance-based fees or other fees based on a share of capital gains on or
capital appreciation of the assets of a client.
Item 7: Types of Clients
OAK generally provides advisory services to the following types of clients:
❖
❖
❖
Individuals
High-Net-Worth Individuals
Pension and Profit Sharing Plans
OAK generally requires a minimum household account value of $100,000 to open and maintain
an account. This minimum may be waived at the discretion of the Advisor based on client needs
and portfolio complexity.
Item 8: Methods of Analysis, Investment Strategies, & Risk of
Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
9
OAK’s methods of analysis include Cyclical analysis, Fundamental analysis, Modern
portfolio theory, Quantitative analysis and Technical analysis.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for
buying and/or selling a security.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
OAK uses long term trading, short term trading and options trading (including covered
options, uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Cyclical analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy are two-
fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors
begin to implement this strategy, then it changes the very cycles these investors are trying
to exploit.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Modern portfolio theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
10
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
Quantitative analysis Investment strategies using quantitative models may perform
differently than expected as a result of, among other things, the factors used in the models,
the weight placed on each factor, changes from the factors’ historical trends, and technical
issues in the construction and implementation of the models.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these
patterns can be identified then a prediction can be made. The risk is that markets do not
always follow patterns and relying solely on this method may not take into account new
patterns that emerge over time.
Investment Strategies
OAK's use of options trading generally holds greater risk, and clients should be aware
that there is a material risk of loss using any of those strategies.
Long term trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Options transactions involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the risk that
an option may expire out of the money resulting in minimal or no value, as well as the
possibility of leveraged loss of trading capital due to the leveraged nature of stock options.
Selection of Other Advisers: Although OAK will seek to select only money managers
who will invest clients' assets with the highest level of integrity, OAK's selection process
cannot ensure that money managers will perform as desired and OAK will have no
control over the day-to-day operations of any of its selected money managers. OAK would
not necessarily be aware of certain activities at the underlying money manager level,
including without limitation a money manager's engaging in unreported risks,
investment “style drift” or even regulatory breaches or fraud.
Short term trading risks include liquidity, economic stability, and inflation, in addition to
the long term trading risks listed above. Frequent trading can affect investment
performance, particularly through increased brokerage and other transaction costs and
taxes.
11
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
OAK's use of options trading generally holds greater risk of capital loss. Clients should be
aware that there is a material risk of loss using any investment strategy. The investment
types listed below are not guaranteed or insured by the FDIC or any other government
agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Risks in investing in ETFs include
trading risks, liquidity and shutdown risks, risks associated with a change in authorized
participants and non-participation of authorized participants, risks that trading price
differs from indicative net asset value (iNAV), or price fluctuation and disassociation from
the index being tracked. With regard to trading risks, regular trading adds cost to your
portfolio thus counteracting the low fees that one of the typical benefits of ETFs.
Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even
paid fund managers struggle to do this every year, with the majority failing to beat the
12
relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same
level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading
conditions are more accurately reflected in implied liquidity rather than the average daily
volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded
in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks
of their underlying securities, which may include the risks associated with investing in
smaller companies, foreign securities, commodities, and fixed income investments (as
applicable). Foreign securities in particular are subject to interest rate, currency exchange
rate, economic, and political risks, all of which are magnified in emerging markets. ETFs
that target a small universe of securities, such as a specific region or market sector, are
generally subject to greater market volatility, as well as to the specific risks associated with
that sector, region, or other focus. ETFs that use derivatives, leverage, or complex
investment strategies are subject to additional risks. The return of an index ETF is usually
different from that of the index it tracks because of fees, expenses, and tracking error. An
ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value
in the case of exchange-traded notes). The degree of liquidity can vary significantly from
one ETF to another and losses may be magnified if no liquid market exists for the ETF’s
shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its
prospectus, offering circular, or similar material, which should be considered carefully
when making investment decisions.
Annuities are a retirement product for those who may have the ability to pay a premium
now and want to guarantee they receive certain monthly payments or a return on
investment later in the future. Annuities are contracts issued by a life insurance company
designed to meet requirement or other long-term goals. An annuity is not a life insurance
policy. Variable annuities are designed to be long-term investments, to meet retirement
and other long-range goals. Variable annuities are not suitable for meeting short-term
goals because substantial taxes and insurance company charges may apply if you
withdraw your money early. Variable annuities also involve investment risks, just as
mutual funds do.
Options are contracts to purchase a security at a given price, risking that an option may
expire out of the money resulting in minimal or no value. An uncovered option is a type
of options contract that is not backed by an offsetting position that would help mitigate
risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling
multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk,
sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk
and interest rate risk.
Non-U.S. securities present certain risks such as currency fluctuation, political and
economic change, social unrest, changes in government regulation, differences in
accounting and the lesser degree of accurate public information available.
13
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
Without admitting or denying the findings, Ralph Hicks signed a Letter of Acceptance, Waiver
and Consent with FINRA on March 28, 2013. The order alleged that Mr. Hicks did not obtain
prior approval on advertising by a registered principal of his employing firm before distribution
to clients. Mr. Hicks was fined as a result of this matter.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither OAK nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither OAK nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Ralph William Hicks is a licensed insurance agent with Oakmont Insurance, LLC. This
activity creates a conflict of interest since there is an incentive to recommend insurance
products based on commissions or other benefits received from the insurance company,
rather than on the client’s needs. Additionally, the offer and sale of insurance products
by supervised persons of OAK are not made in their capacity as a fiduciary, and products
14
are limited to only those offered by certain insurance providers. OAK addresses this
conflict of interest by requiring its supervised persons to act in the best interest of the
client at all times, including when acting as an insurance agent. OAK periodically reviews
recommendations by its supervised persons to assess whether they are based on an
objective evaluation of each client’s risk profile and investment objectives rather than on
the receipt of any commissions or other benefits. OAK will disclose in advance how it or
its supervised persons are compensated and will disclose conflicts of interest involving
any advice or service provided. At no time will there be tying between business practices
and/or services (a condition where a client or prospective client would be required to
accept one product or service conditioned upon the selection of a second, distinctive tied
product or service). No client is ever under any obligation to purchase any insurance
product. Insurance products recommended by OAK’s supervised persons may also be
available from other providers on more favorable terms, and clients can purchase
insurance products recommended through other unaffiliated insurance agencies.
David Bradford Hicks is a licensed insurance agent with Oakmont Insurance, LLC. This
activity creates a conflict of interest since there is an incentive to recommend insurance
products based on commissions or other benefits received from the insurance company,
rather than on the client’s needs. Additionally, the offer and sale of insurance products
by supervised persons of OAK are not made in their capacity as a fiduciary, and products
are limited to only those offered by certain insurance providers. OAK addresses this
conflict of interest by requiring its supervised persons to act in the best interest of the
client at all times, including when acting as an insurance agent. OAK periodically reviews
recommendations by its supervised persons to assess whether they are based on an
objective evaluation of each client’s risk profile and investment objectives rather than on
the receipt of any commissions or other benefits. OAK will disclose in advance how it or
its supervised persons are compensated and will disclose conflicts of interest involving
any advice or service provided. At no time will there be tying between business practices
and/or services (a condition where a client or prospective client would be required to
accept one product or service conditioned upon the selection of a second, distinctive tied
product or service). No client is ever under any obligation to purchase any insurance
product. Insurance products recommended by OAK’s supervised persons may also be
available from other providers on more favorable terms, and clients can purchase
insurance products recommended through other unaffiliated insurance agencies.
Brandon Connor Kinsner is a licensed insurance agent with Oakmont Insurance, LLC.
This activity creates a conflict of interest since there is an incentive to recommend
insurance products based on commissions or other benefits received from the insurance
company, rather than on the client’s needs. Additionally, the offer and sale of insurance
products by supervised persons of OAK are not made in their capacity as a fiduciary, and
products are limited to only those offered by certain insurance providers. OAK addresses
this conflict of interest by requiring its supervised persons to act in the best interest of the
client at all times, including when acting as an insurance agent. OAK periodically reviews
recommendations by its supervised persons to assess whether they are based on an
objective evaluation of each client’s risk profile and investment objectives rather than on
the receipt of any commissions or other benefits. OAK will disclose in advance how it or
its supervised persons are compensated and will disclose conflicts of interest involving
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any advice or service provided. At no time will there be tying between business practices
and/or services (a condition where a client or prospective client would be required to
accept one product or service conditioned upon the selection of a second, distinctive tied
product or service). No client is ever under any obligation to purchase any insurance
product. Insurance products recommended by OAK’s supervised persons may also be
available from other providers on more favorable terms, and clients can purchase
insurance products recommended through other unaffiliated insurance agencies.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
OAK may direct clients to third-party investment advisers to manage all or a portion of
the client's assets. OAK will be compensated via a fee share from the advisers to which it
directs those clients. This relationship will be memorialized in each contract between OAK
and each third-party advisor. The fees shared will not exceed any limit imposed by any
regulatory agency. This creates a conflict of interest in that OAK has an incentive to direct
clients to the third-party investment advisers that provide OAK with a larger fee split.
OAK will always act in the best interests of the client, including when determining which
third-party investment adviser to recommend to clients. OAK will ensure that all
recommended advisers are licensed or notice filed in the states in which OAK is
recommending them to clients.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
OAK has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. OAK's Code of Ethics is available free upon request to any client
or prospective client.
B. Recommendations Involving Material Financial Interests
OAK does not recommend that clients buy or sell any security in which a related person
to OAK or OAK has a material financial interest.
16
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of OAK may buy or sell securities for themselves that
they also recommend to clients. This may provide an opportunity for representatives of
OAK to buy or sell the same securities before or after recommending the same securities
to clients resulting in representatives profiting off the recommendations they provide to
clients. Such transactions may create a conflict of interest. OAK will always document any
transactions that could be construed as conflicts of interest and will never engage in
trading that operates to the client’s disadvantage when similar securities are being bought
or sold.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of OAK may buy or sell securities for themselves at or
around the same time as clients. This may provide an opportunity for representatives of
OAK to buy or sell securities before or after recommending securities to clients resulting
in representatives profiting off the recommendations they provide to clients. Such
transactions may create a conflict of interest; however, OAK will never engage in trading
that operates to the client’s disadvantage if representatives of OAK buy or sell securities
at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on OAK’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and OAK may also
consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in OAK's research efforts. OAK will never charge a
premium or commission on transactions, beyond the actual cost imposed by the broker-
dealer/custodian.
OAK recommends Altruist Financial, LLC as custodian.
1. Research and Other Soft-Dollar Benefits
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While OAK has no formal soft dollars program in which soft dollars are used to pay
for third party services, OAK may receive research, products, or other services from
custodians and broker-dealers in connection with client securities transactions (“soft
dollar benefits”). OAK may enter into soft-dollar arrangements consistent with (and
not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange
Act of 1934, as amended. There can be no assurance that any particular client will
benefit from soft dollar research, whether or not the client’s transactions paid for it,
and OAK does not seek to allocate benefits to client accounts proportionate to any soft
dollar credits generated by the accounts. OAK benefits by not having to produce or
pay for the research, products or services, and OAK will have an incentive to
recommend a broker-dealer based on receiving research or services. Clients should be
aware that OAK’s acceptance of soft dollar benefits may result in higher commissions
charged to the client.
2. Brokerage for Client Referrals
OAK receives no referrals from a broker-dealer or third party in exchange for using
that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
OAK recommends clients to use a specific broker-dealer to execute transactions. Not
all advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
If OAK buys or sells the same securities on behalf of more than one client, then it may (but
would be under no obligation to) aggregate or bunch such securities in a single transaction
for multiple clients in order to seek more favorable prices, lower brokerage commissions,
or more efficient execution. In such case, OAK would place an aggregate order with the
broker on behalf of all such clients in order to ensure fairness for all clients; provided,
however, that trades would be reviewed periodically to ensure that accounts are not
systematically disadvantaged by this policy. OAK would determine the appropriate
number of shares and select the appropriate brokers consistent with its duty to seek best
execution, except for those accounts with specific brokerage direction (if any).
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client accounts for OAK's advisory services provided on an ongoing basis are
reviewed at least Quarterly by David Bradford Hicks, Partner & Chief Compliance
18
Officer, with regard to clients’ respective investment policies and risk tolerance levels. All
accounts at OAK are assigned to this reviewer.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
C. Content and Frequency of Regular Reports Provided to Clients
Each client of OAK's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian. OAK will also
provide at least quarterly a separate written statement to the client.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
OAK may receive compensation in connection with its use of third-party advisers.
B. Compensation to Non – Advisory Personnel for Client Referrals
OAK does not directly or indirectly compensate any person who is not advisory personnel
for client referrals.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, OAK will be
deemed to have limited custody of client's assets and must have written authorization from the
client to do so. Clients will receive all account statements and billing invoices that are required in
each jurisdiction, and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
OAK provides discretionary and non-discretionary investment advisory services to clients. The
advisory contract established with each client sets forth the discretionary authority for trading.
Where investment discretion has been granted, OAK generally manages the client’s account and
19
makes investment decisions without consultation with the client as to when the securities are to
be bought or sold for the account, the total amount of the securities to be bought/sold, what
securities to buy or sell, or the price per share. In some instances, OAK’s discretionary authority
in making these determinations may be limited by conditions imposed by a client (in investment
guidelines or objectives, or client instructions otherwise provided to OAK.
Item 17: Voting Client Securities (Proxy Voting)
OAK will not ask for, nor accept voting authority for client securities. Clients will receive proxies
directly from the issuer of the security or the custodian. Clients should direct all proxy questions
to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
OAK neither requires nor solicits prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither OAK nor its management has any financial condition that is likely to reasonably
impair OAK’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
OAK has not been the subject of a bankruptcy petition in the last ten years.
20
This brochure supplement provides information about Ralph Hicks and supplements the
Oakmont Advisory Group, LLC brochure. You should have received a copy of that brochure.
Please contact David B. Hicks if you did not receive Oakmont Advisory Group, LLC’s brochure
or if you have any questions about the contents of this supplement.
Additional information about Ralph Hicks (CRD#1500855) is available on the SEC’s website
at www.adviserinfo.sec.gov.
Oakmont Advisory Group, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Ralph Hicks, ChFC®, CLU®
Personal CRD Number: 1500855
Investment Adviser Representative
2001 Carlisle Blvd, Suite D
Albuquerque, NM 87110
PHONE: 505-821-6966
FAX: 505-312-7533
EMAIL: ralph@oakmontadvisory.com
https://oakmontadvisory.com
UPDATED: 05/26/2026
21
Item 2: Educational Background and Business Experience
Ralph Hicks, ChFC®, CLU®
Name:
Born: 1942
Educational Background and Professional Designations:
Education:
• American College; Chartered Financial Consultant Designation; 1991
• American College; Chartered Life Underwriter Designation; 1977
• Bridgewater College; Business Administration; 1965
Business Background:
02/2019 - Present
Owner
Lowkey Holdings, LLC
Managing Member/Investment Advisor
08/2011–Present
Representative
Oakmont Advisory Group, LLC, fka Hicks Advisory
Group, LLC
07/2010–Present
Owner/Insurance Agent
Oakmont Insurance, LLC, fka Ralph Hicks &
Associates, LLC
Designations:
Chartered Financial Consultant (ChFC): Chartered Financial Consultants are licensed by the
American College to use the ChFC mark. ChFC certification requirements:
• Complete ChFC coursework within five years from the date of initial enrollment.
• Pass the exams for all required elective courses. You must achieve a minimum
score of 70% to pass.
• Meet the experience requirements: Three years of business experience
immediately preceding the date of use of the designation are required. An
undergraduate or graduate degree from an accredited educational institution
qualifies as one year of business experience.
• Take the Professional Ethics Pledge.
• When you achieve your ChFC designation, you must earn your recertification
every two years.
22
Chartered Life Underwriter (CLU): Chartered Life Underwriters are licensed by the American
College to use the CLU mark. CLU certification requirements:
• Complete successfully CLU coursework 5 required and 3 electives
• Meet the experience requirements: Three years of business experience
immediately preceding the date of use of the designation are required. An
undergraduate or graduate degree from an accredited educational institution
qualifies as one year of business experience.
• Take the Professional Ethics Pledge.
• When you achieve your CLU designation, you must earn 30 hours of continuing
education credit every two years.
Item 3: Disciplinary Information
Without admitting or denying the findings, Ralph Hicks signed a Letter of Acceptance, Waiver
and Consent with FINRA on March 28, 2013. The order alleges that Mr. Hicks did not obtain prior
approval on advertising by a registered principal of his employing firm before distribution to
clients.
Item 4: Other Business Activities
Managing Member Ralph Hicks has a financial industry affiliated business as an insurance agent.
Less than 50% of his time is spent in this business. From time to time, he will offer clients advice
or products from those activities. As an insurance agent, he may receive separate yet typical
compensation in the form of commissions for the sale of insurance products.
These practices represent conflicts of interest because it gives Ralph Hicks an incentive to
recommend products based on the commission amount received. This conflict is mitigated by the
fact that Mr. Hicks has a fiduciary responsibility to place the interest of his clients first and the
clients are not required to purchase
any products. Clients have the option to purchase these products through another insurance
agent of their choosing.
Ralph Hicks is also an owner of Lowkey Holdings, LLC, a real estate holdings company. He
spends 1 hour a month outside of trading hours on this activity.
23
Item 5: Additional Compensation
As a result of the Advisor’s activities, the Advisor will be, in certain situations, but eligible for
additional incentive-based compensation based on sales. This compensation can be delivered in
many forms including by not limited to training, trip expenses, or payment of software costs.
Item 6: Supervision
Ralph W. Hicks is the, is the 50% owner. As a representative of Oakmont Advisory Group, LLC,
Ralph W. Hicks works closely with the supervisor, David Hicks, and all advice provided to clients
is reviewed by the supervisor prior to implementation. Ralph W. Hicks adheres to applicable
regarding the activities of an Investment Adviser Representative, together with all policies and
procedures outlined in the firm’s code of ethics and compliance manual. David Hicks’s phone
number is 505-821-6966.
24
This brochure supplement provides information about David B. Hicks and supplements the
Oakmont Advisory Group, LLC brochure. You should have received a copy of that brochure.
Please contact David B. Hicks if you did not receive Oakmont Advisory Group, LLC’s brochure
or if you have any questions about the contents of this supplement.
Additional information about David B. Hicks (CRD#6156912) is available on the SEC’s
website at www.adviserinfo.sec.gov.
Oakmont Advisory Group, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
David B. Hicks
Personal CRD Number: 6156912
Investment Adviser Representative
2001 Carlisle Blvd, Suite D
Albuquerque, NM 87110
PHONE: 505-821-6966
FAX: 505-312-7533
EMAIL: ralph@oakmontadvisory.com
https://oakmontadvisory.com
UPDATED: 05/26/2026
25
Item 2: Educational Background and Business Experience
David B. Hicks
Name:
Born: 1979
Educational Background and Professional Designations:
Education:
• Abilene Christian University, BBA Degree in Marketing and Management; 2002
Business Background:
02/2019 - Present
Owner
Lowkey Holdings, LLC
Managing Member/Investment Advisor
01/2013–Present
Representative
Oakmont Advisory Group, LLC, fka Hicks Advisory
Group, LLC
Managing Member/Marketing/Insurance
08/2009–Present
Broker/Agent
Oakmont Insurance, LLC, fka Ralph Hicks &
Associates, LLC
Item 3: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business.
Item 4: Other Business Activities
David B. Hicks has financial industry affiliated businesses as an insurance agent. Mr. Hicks
spends less than 50% of his time in this capacity and from time to time, he offers clients advice or
products from those activities. Clients are not required to purchase any products. He may receive
separate, yet typical, compensation in the form of commissions for the sale of insurance products.
These practices represent conflicts of interest because it gives Mr. Hicks an incentive to
recommend products based on the commission amount received. This conflict is mitigated by the
26
fact that clients are not required to purchase any products. Clients have the option to purchase
these products through another insurance agent of their choosing.
David B. Hicks is also an owner of Lowkey Holdings, LLC, a real estate holding company. He
spends approximately 12 hours a month on this business activity, the majority of those are outside
of trading hours.
David B. Hicks is on the Board of Directors for Oak Grove Classical Academy, a private Christian
school.
Item 5: Additional Compensation
As a result of the Advisor’s activities, the Advisor will be, in certain situations, but eligible for
additional incentive-based compensation based on sales. This compensation can be delivered in
many forms including by not limited to training, trip expenses, or payment of software costs.
Item 6: Supervision
As the Chief Compliance Officer of Oakmont Advisory Group, LLC, David B. Hicks supervises
all duties and activities of the firm. David B. Hicks’s contact information is on the cover page of
this disclosure document. David B. Hicks adheres to applicable regulatory requirements, together
with all policies and procedures outlined in the firm’s code of ethics and compliance manual.
David B. Hicks’ contact information:
Phone: 505-821-6966, or by email at: david@oakmontadvisory.com
27
This brochure supplement provides information about Brandon Connor Kinsner and
supplements the Oakmont Advisory Group, LLC brochure. You should have received a copy of
that brochure. Please contact Brandon Connor Kinsner if you did not receive Oakmont
Advisory Group, LLC’s brochure or if you have any questions about the contents of this
supplement.
Additional information about Brandon Connor Kinsner (CRD#7621973) is available on the
SEC’s website at www.adviserinfo.sec.gov.
Oakmont Advisory Group, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Brandon Connor Kinsner
Personal CRD Number: 7621973
Investment Adviser Representative
2001 Carlisle Blvd, Suite D
Albuquerque, NM 87110
PHONE: 505-821-6966
FAX: 505-312-7533
EMAIL: brandon@oakmontadvisory.com
https://oakmontadvisory.com
UPDATED: 05/26/2026
28
Item 2: Educational Background and Business Experience
Name:
Brandon Connor Kinsner
Born: 1996
Educational Background and Professional Designations:
Education:
• Associates Degree Psychology, Central New Mexico Community College - 2022
Business Background:
01/2021–Present
Investment Advisor Representative/Advisor
Oakmont Advisory Group, LLC
Operations Manager
12/2018–01/2021
OPS BTFO
Item 3: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s
evaluation of this advisory business.
Item 4: Other Business Activities
Brandon Connor Kinsner is not engaged in any investment-related business or occupation (other
than this advisory firm).
Item 5: Additional Compensation
As a result of the Advisor’s activities, the Advisor will be, in certain situations, but eligible for
additional incentive-based compensation based on sales. This compensation can be delivered in
many forms including by not limited to training, trip expenses, or payment of software costs.
29
Item 6: Supervision
As a representative of Oakmont Advisory Group, LLC, Brandon Connor Kinsner is supervised
by David B Hicks, the firm's Chief Compliance Officer. David B Hicks is responsible for ensuring
that Brandon Connor Kinsner adheres to all required regulations regarding the activities of an
Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s
Code of Ethics and compliance manual. The phone number for David B Hicks is (505) 821-6966.
30