OAKTRUST WEALTH ADVISORS, LLC

OakTrust Wealth Advisors, LLC Form ADV Part 2A – Disclosure Brochure Effective: February 6, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com. OakTrust is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about OakTrust to assist you in determining whether to retain the Advisor. Additional information about OakTrust and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD # 170827. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about Advisory Persons of OakTrust. For convenience, the Advisor has combined these documents into a single disclosure document. OakTrust believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. OakTrust encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on February 16th, 2024. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD # 170827. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 2  Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................... 1 Item 2 – Material Changes ..................................................................................................................................... 2 Item 3 – Table of Contents .................................................................................................................................... 3 Item 4 – Advisory Services ................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................. 4 B. Advisory Services Offered .............................................................................................................................................. 4 C. Client Account Management .......................................................................................................................................... 6 D. Wrap Fee Programs ....................................................................................................................................................... 6 E. Assets Under Management ............................................................................................................................................ 6 Item 5 – Fees and Compensation ......................................................................................................................... 6 A. Fees for Advisory Services ............................................................................................................................................. 6 B. Fee Billing ....................................................................................................................................................................... 7 C. Other Fees and Expenses ............................................................................................................................................. 7 D. Advance Payment of Fees and Termination .................................................................................................................. 8 E. Compensation for Sales of Securities ............................................................................................................................ 8 Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9 Item 7 – Types of Clients ....................................................................................................................................... 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9 A. Methods of Analysis ....................................................................................................................................................... 9 B. Risk of Loss .................................................................................................................................................................. 10 Item 9 – Disciplinary Information ....................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 11 A. Code of Ethics .............................................................................................................................................................. 11 B. Personal Trading with Material Interest ........................................................................................................................ 12 C. Personal Trading in Same Securities as Clients .......................................................................................................... 12 D. Personal Trading at Same Time as Client ................................................................................................................... 12 Item 12 – Brokerage Practices ............................................................................................................................ 12 A. Recommendation of Custodian[s] ................................................................................................................................ 12 B. Aggregating and Allocating Trades .............................................................................................................................. 13 Item 13 – Review of Accounts ............................................................................................................................ 13 A. Frequency of Reviews .................................................................................................................................................. 13 B. Causes for Reviews ..................................................................................................................................................... 13 C. Review Reports ............................................................................................................................................................ 13 Item 14 – Client Referrals and Other Compensation ........................................................................................ 13 A. Compensation Received by OakTrust .......................................................................................................................... 13 B. Compensation for Client Referrals ............................................................................................................................... 14 Item 15 – Custody ................................................................................................................................................ 14 Item 16 – Investment Discretion ......................................................................................................................... 14 Item 17 – Voting Client Securities ...................................................................................................................... 14 Item 18 – Financial Information .......................................................................................................................... 14 Form ADV Part 2A Appendix 1 (Wrap Fee Brochure) ....................................................................................... 14 Form ADV Part 2B – Brochure Supplement (Papa, Thomas) .......................................................................... 22 Form ADV Part 2B – Brochure Supplement (Zizzadoro, Nicholas) ................................................................. 25 Privacy Policy ...................................................................................................................................................... 28 OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 3  Item 4 – Advisory Services A. Firm Information OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Connecticut. OakTrust was founded in March 2014, and is owned and operated by Thomas J. Papa (Managing Partner and Chief Compliance Officer) and Nicholas Zizzadoro (Managing Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by OakTrust. B. Advisory Services Offered OakTrust offers investment advisory services to individuals, high net worth individuals, trusts, and estates (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services OakTrust provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. OakTrust works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. OakTrust will then construct a portfolio of mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, alternative investments, and independent managers to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. OakTrust’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. OakTrust will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. OakTrust evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. OakTrust may recommend, on occasion, redistributing investment allocations to diversify the portfolio. OakTrust may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. OakTrust may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 4  new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. At no time will OakTrust accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the terms of the Client investment advisory agreement, please see Item 12 – Brokerage Practices. Use of Independent Managers – When deemed to be in the Client’s best interest, OakTrust will recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). Independent Managers may be sourced directly or accessed through an investment management platform. The Client may be required to enter into a separate agreement with the Independent Manager[s] and/or provide authorization through its custodial application to utilize the Independent Manager[s]. OakTrust serves as the Client’s primary advisor and relationship manager. However, the Independent Manager[s] will assume discretionary authority for the day-to-day investment management of those assets placed in their control. OakTrust will assist and advise the Client in establishing investment objectives for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the account[s]. OakTrust will continue to provide oversight of the Client’s account[s] and ongoing monitoring of the activities of these unaffiliated parties. The Independent Manager[s] will implement the selected investment strategies based on their investment mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject to the acceptance of these third parties. The Client, prior to entering into an agreement with an Independent Manager, will be provided with the Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those parties. OakTrust does not receive any compensation from these Independent Managers or Investment Platforms, other than OakTrust’s investment advisory fee described in Item 5 below. Financial Planning Services OakTrust will typically provide a variety of financial planning services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan based on the Client’s financial goals and objectives. This planning may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, estate planning, charitable planning, education savings, corporate and personal tax planning, debt analysis, insurance analysis and other areas of a Client’s financial situation. A financial plan developed for the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. OakTrust may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 5  recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging OakTrust to provide investment advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: • Establishing an Investment Strategy – OakTrust, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. • Asset Allocation – OakTrust will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. • Portfolio Construction – OakTrust will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – OakTrust will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs OakTrust typically include the securities transaction fees together with investment advisory fees to provide the Client with a single, bundled fee structure. This combination of fees is typically referred to as a “Wrap Fee Program”. OakTrust customizes its investment management services for Clients. This Wrap Fee Program Brochure is included as Appendix 1 to this Disclosure Brochure solely to discuss the fees and potential conflicts associated with a bundled fee. Please see Appendix 1, which is always included with this Disclosure Brochure. E. Assets Under Management As of December 31, 2025, OakTrust manages $285,034,723 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor that detail the responsibilities of the parties. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.25% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by OakTrust will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Use of Independent Managers – As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 6  breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually. Financial Planning Services OakTrust offers financial planning services either on an hourly or fixed fee basis. Hourly engagements range from $100 to $500 per hour. Fixed fee engagements range from $500 to $15,000. Fees may be negotiable based on the on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Custodian and deducted from the Client’s account[s]. The Client shall instruct the Custodian to automatically deduct the investment advisory fee from the Client’s account[s] for each billing period and pay the investment advisory fee[s] to the Advisor. The Custodian will utilize the fee rate, as defined in the advisory agreement, to indicate the fee to be deducted from the Client’s account[s] at the respective quarter-end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with OakTrust at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting the Custodian to pay OakTrust by direct deduction from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Client account[s] with assets implemented through an Independent Manager, the Client’s overall fees will often include OakTrust’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Manager[s], as applicable. The Custodian will assume responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s]. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees and/or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s], as well as any applicable regulatory fees. OakTrust may include securities transactions costs as part of its overall investment advisory fee through the OakTrust Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. In addition, all fees paid to OakTrust for investment advisory services or part of the OakTrust Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of OakTrust, but would not receive the services provided by OakTrust which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by OakTrust to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 7  D. Advance Payment of Fees and Termination Investment Management Services OakTrust is compensated for its services in advance of the quarter in which investment management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers – In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and those Independent Manager[s]. OakTrust will assist the Client with the termination and transition as appropriate. Financial Planning Services OakTrust requires an advance deposit as described above. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. E. Compensation for Sales of Securities OakTrust does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Advisory Persons of OakTrust are also registered representatives of LPL Financial LLC ("LPL Financial"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative of LPL Financial, an Advisory Person will implement securities transactions under LPL Financial and not through OakTrust. In such instances, an Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an Advisory Person in one’s capacity as a registered representative is separate and in addition to OakTrust’s advisory fees. This practice presents a conflict of interest because an Advisory Person who is a registered representative has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. OakTrust mitigates this conflict in two ways. First, Clients always have the right to choose whether or not to purchase securities products through one of our Advisory Persons. Second, OakTrust will not charge an ongoing investment advisory fee on any assets implemented in the separate capacity of one of our Advisory Persons. Please see Item 10 – Other Financial Industry Activities and Affiliations. Advisory Persons are also licensed as independent insurance professionals. As an independent insurance professional, an Advisory Person will earn commission-based compensation for selling insurance products, including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are separate and in addition to OakTrust's advisory fees. This practice presents a conflict of interest because a person providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to recommend insurance products to Clients for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance products through an Advisory Person. Please see Item 10 – Other Financial Industry Activities and Affiliations. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 8  Item 6 – Performance-Based Fees and Side-By-Side Management OakTrust does not charge performance-based fees for its investment advisory services. The fees charged by OakTrust are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. OakTrust does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients OakTrust offers investment advisory services to individuals, high net worth individuals, trusts, and estates. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. OakTrust generally does not impose a minimum size for establishing a relationship. However, certain independent managers may impose minimums for their investment strategies. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis OakTrust primarily employs fundamental, technical and cyclical analysis in developing investment strategies for its Clients. Research and analysis from OakTrust are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that OakTrust will be able to accurately predict such a reoccurrence. Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro (entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the particular company that OakTrust is recommending. The risks with cyclical analysis are similar to those of technical analysis. OakTrust may also base its investments around the modern portfolio theory as a formal investment selection process. This theory 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 assets. As noted above, OakTrust generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. OakTrust will typically hold all or a portion of a security for more than a year, but may hold OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 9  for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, OakTrust may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. OakTrust will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 10  repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving OakTrust or any of its management persons. OakTrust values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 170827. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5.E, Advisory Persons are also registered representatives of LPL Financial. In one’s separate capacity as a registered representative, an Advisory Persons will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by the Advisor or an Advisory Person. Neither the Advisor nor an Advisory Person will earn any investment advisory fees in connection with any services implemented in an Advisory Person’s separate capacity as a registered representative. Insurance Agency Affiliations As noted in Item 5.E, Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person's role with the Advisor. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. An Advisory Person is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics OakTrust has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with the Advisor (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. OakTrust and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of OakTrust’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (203) 563-0044 or via email at info@oaktrustllc.com. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 11  B. Personal Trading with Material Interest OakTrust allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. OakTrust does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. OakTrust does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients OakTrust allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that OakTrust recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, OakTrust must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by OakTrust requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While OakTrust allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will OakTrust, or any Supervised Person of OakTrust, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] OakTrust does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize OakTrust to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, OakTrust does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where OakTrust does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by OakTrust. As its Advisory Persons are also registered representatives of LPL Financial, OakTrust and its Advisory Persons are limited in the Custodian in which they can recommend to Clients. Typically, OakTrust will recommend that Clients establish their accounts at LPL Financial, where OakTrust has access to LPL Financial’s systems, back office support, research and other benefits. While OakTrust receives these economic benefits from LPL Financial, we believe LPL Financial provides quality execution and related services for our Clients at competitive prices. Price is not the sole factor OakTrust considers in evaluating best execution and the recommendation of the Custodian. OakTrust also considers the quality of the brokerage services provided by LPL Financial, including the firm's reputation, execution capabilities, commission rates, and responsiveness to our Clients and our firm. Clients are free to use any broker-dealer/custodian they choose when implementing financial planning recommendations. For investment advisory services, OakTrust would be required to obtain permission to use a broker-dealer or Custodian other than LPL Financial due to the oversight role LPL Financial assumes over the Advisory Persons. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodian whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 12  other services. OakTrust does not participate in soft dollar programs sponsored or offered by any broker- dealer/custodian. However, the Advisor does receive certain economic benefits from LPL Financial. Please see Item 14 below. 2. Brokerage Referrals - OakTrust does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where OakTrust will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). OakTrust will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. OakTrust will execute its transactions through the Custodian as directed by the Client. OakTrust may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Thomas J. Papa, Chief Compliance Officer of OakTrust. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify OakTrust if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by OakTrust OakTrust may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, OakTrust may receive non-compensated referrals of new Clients from various third-parties. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 13  Participation in Institutional Advisor Platform OakTrust has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. B. Compensation for Client Referrals The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion OakTrust generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by OakTrust. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by OakTrust will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities OakTrust does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither OakTrust, nor its management, have any adverse financial situations that would reasonably impair the ability of OakTrust to meet all obligations to its Clients. Neither OakTrust, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. OakTrust is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 14  OakTrust Wealth Advisors, LLC Form ADV Part 2A Appendix 1 (“Wrap Fee Program Brochure”) Effective: February 6, 2026 This Form ADV 2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices of OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”) when offering services where securities transaction fees are combined with investment advisory fees into a single fee (a “Wrap Fee Program”). If you have any questions about the content of this Wrap Fee Program Brochure, please contact the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com. OakTrust is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about OakTrust to assist you in determining whether to retain the Advisor. Additional information about OakTrust and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 170827. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 15  Item 2 – Material Changes Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program sponsored by the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on February 28, 2025. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete OakTrust Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of OakTrust. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 170827. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................. 15 Item 2 – Material Changes ................................................................................................................................... 16 Item 3 – Table of Contents .................................................................................................................................. 16 Item 4 – Services Fees and Compensation ....................................................................................................... 17 Item 5 – Account Requirements and Types of Clients ..................................................................................... 18 Item 6 – Portfolio Manager Selection and Evaluation ...................................................................................... 18 Item 7 – Client Information Provided to Portfolio Managers ........................................................................... 19 Item 8 – Client Contact with Portfolio Managers .............................................................................................. 19 Item 9 – Additional Information .......................................................................................................................... 19 OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 16  Item 4 – Services Fees and Compensation A. Services OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”) provides customized investment management services to individuals, high net worth individuals, trusts, and estates (each referred to as a “Client”). The OakTrust Wrap Fee Program (the “Wrap Fee Program”) is an investment advisory program sponsored by OakTrust whereby OakTrust includes normal securities transaction fees with its investment advisory fees to provide Clients with a single overall fee. The OakTrust Wrap Fee Program Brochure is provided as a supplement to OakTrust’s Form ADV 2A (“Disclosure Brochure”). Clients may be offered a fee structure that includes, as a single fee, the securities transaction costs for trading in Client accounts along with the investment advisory fees earned by OakTrust. The securities regulations often refer to such a structure as a wrap fee program. While traditional wrap fee programs are often rigid, pre- packaged investment programs, OakTrust customizes its investment strategies individually for its Clients. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of securities transaction fees into the single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back to the Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on OakTrust’s investment philosophy and related services. B. Program Costs Advisory services provided by OakTrust are offered in a wrap fee structure whereby normal securities transaction costs are included in the overall investment advisory fee paid to OakTrust. As the level of trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transactions costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity in the Client’s account[s]. A Wrap Fee Program structure has a conflict of interest as the Advisor may have an incentive to limit the number of trades placed in the Client’s account[s] or to select investments with no transaction fee (“NTF”). The Advisor reviews Client accounts periodically to evaluate the level of trading and the underlying investments, and to validate that accounts are being managed in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are charged at an annual rate of up to 1.25% depending on several factors, including the overall the size of the relationship and the complexity of the services to be provided. Fees are based on the market value of assets under management at the end of the prior calendar quarter. The investment advisory fee in the first quarter of service is prorated from the inception date of the Client’s account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by OakTrust will be independently valued by the Custodian. OakTrust will conduct periodic reviews of the Custodian’s valuations. The Advisor may also implement all or a portion of a Client’s investment portfolio utilizing one or more unaffiliated money managers or investment platforms (collectively “Independent Managers”). To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00% annually OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 17  Clients will incur certain fees and/or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s], as well as any applicable regulatory fees, which are not included as part of the Wrap Fee Program. All fees paid to OakTrust for investment advisory services are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee as a shareholder in a fund. Additionally, account activity fees, such as electronic funds and wire transfers fees, certificate delivery fees, markups and markdowns, bid-ask spreads, selling concessions, and other miscellaneous fees and expenses as outlined in the account opening paperwork executed with the Custodian, are generally charged to the Client. Finally, securities transaction fees for client-directed trades may be charged back to the Client. The Advisor does not control nor share in any of these third party fees. Clients are encouraged to review all fees charged by the fund[s], third parties and Summit Financial to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses of the Disclosure Brochure. D. Compensation OakTrust is the sponsor and portfolio manager of this Wrap Fee Program. OakTrust receives investment advisory fees paid by Clients for investment advisory services covered under this Wrap Fee Program. Item 5 – Account Requirements and Types of Clients OakTrust offers investment advisory services to individuals, high net worth individuals, trusts and estates. Please see Item 7 – Types of Clients of the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection OakTrust serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. The Advisor also serves as the sponsor in conjunction with Independent Managers for the Wrap Fee Program. The Advisor may recommend that a Client utilize an Independent Manager for all or a portion of a Client’s investment portfolio. The Advisor will assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will also perform initial and ongoing oversight and due diligence over the selected Independent Managers to ensure the Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. Related Persons OakTrust personnel or affiliates serve as portfolio manager[s] for services under this Wrap Fee Program. OakTrust only manages this wrap fee program. OakTrust does not act as portfolio manager for any third-party wrap fee programs. Supervised Persons OakTrust Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4 Advisory Services of the Disclosure Brochure. Performance-Based Fees OakTrust does not charge performance-based fees for its investment advisory services. The fees charged by OakTrust are as described in Item 5 – Fees and Compensation of the Disclosure Brochure and are not based upon the capital appreciation of the funds or securities held by any Client. OakTrust does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 18  Methods of Analysis OakTrust primarily employs fundamental, technical and cyclical analysis in developing investment strategies for its Clients. Please see Item 8.A – Methods of Analysis of the Disclosure Brochure for details on the research and analysis methods employed by the Advisor. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. OakTrust will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B of the Disclosure Brochure. Proxy Voting OakTrust does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. OakTrust will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 7 – Client Information Provided to Portfolio Managers Clients participating in the Wrap Fee Program generally grant OakTrust the authority to discuss certain non- public information with Independent Managers engaged to manage their account[s]. Depending upon the specific arrangement, the Advisor is authorized to disclose various personal information including, without limitation: names, phone numbers, addresses, social security numbers, driver’s license, tax identification numbers and account numbers. OakTrust may also share certain information related to its Clients’ financial positions and investment objectives in an effort to ensure that the Independent Managers’ investment decisions remain aligned with its Clients’ best interests. This information is communicated on an initial and ongoing basis, or as otherwise necessary to the management of its Clients’ portfolios. Please also see the OakTrust Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers There are no restrictions on Clients’ ability to correspond with OakTrust. Clients can generally contact the Independent Managers managing their portfolios through OakTrust by providing the Advisor with written request and identification of the questions or issues to be discussed with the Independent Managers. After receiving the Client’s written request, OakTrust, at its sole discretion, may contact the Independent Managers for the Client or arrange for the Independent Managers and the Client to communicate directly. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations Disciplinary Information There are no legal, regulatory or disciplinary events involving OakTrust or any of its management persons. OakTrust values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider with whom the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 170827. Other Financial Activities and Affiliations Broker-Dealer Affiliation - Advisory Persons of OakTrust are also registered representatives of LPL Financial LLC (“LPL Financial”). In an Advisory Person’s separate capacity as a registered representative, an Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of OakTrust. Neither OakTrust nor an Advisory Person will earn any investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Under supervision by OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 19  LPL Financial, LPL Financial may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see our Privacy Policy, which is included with this Disclosure Brochure. Insurance Agency Affiliations – Advisory Persons of OakTrust serve as licensed insurance professionals. Implementations of insurance recommendations are separate and apart from an Advisory Person’s role with OakTrust. As an insurance professional, an Advisory Person will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. An Advisory Person is not required to offer the products of any particular insurance company. Clients are under no obligation to implement any recommendations made the Advisor or an Advisory Persons. B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Code of Ethics OakTrust has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all Supervised Persons of OakTrust. The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. OakTrust and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of OakTrust Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code of Ethics, please contact the Advisor at 203-563-0044. Personal Trading and Conflicts of Interest OakTrust allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities OakTrust recommends (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, OakTrust must disclose to Clients and mitigate through policies and procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. At no time, will OakTrust or any Supervised Person of OakTrust, transact in any security to the detriment of any Client. Please see Item 11 – Code of Ethics of the Disclosure Brochure for additional disclosures. Review of Accounts Securities in Client accounts are monitored on a regular and continuous basis by the Chief Compliance Officer of OakTrust. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. Financial planning engagements for ongoing planning support are reviewed at least annually, as per the terms of the financial planning agreement. The Client is encouraged to notify OakTrust if changes occur in his/her personal financial situation that might adversely affect his/her investment plan. Additional reviews may be triggered by material market, economic or political events. Other Compensation Advisory Persons of OakTrust may also be registered representatives of LPL Financial and/or licensed insurance professionals. For information on the conflicts of interest this presents, and how the Advisor addresses these conflicts, please refer to Item 10 – Other Financial Industry Activities and Affiliations of the Disclosure Brochure. Participation in Institutional Advisor Platform OakTrust has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 20  Financial: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. Compensation for Client Referrals Certain Clients may be referred to OakTrust by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, OakTrust will compensate the Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by OakTrust, and shall not result in any additional charge to the Client. Financial Information Neither OakTrust, nor its management, have any adverse financial situations that would reasonably impair the ability of OakTrust to meet all obligations to its Clients. OakTrust is not required to deliver a balance sheet along with this Disclosure Brochure, as OakTrust does not collect fees of $1,200 or more for services to be performed six months or more in advance. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 21  Form ADV Part 2B – Brochure Supplement for Thomas J. Papa Managing Partner and Chief Compliance Officer Effective: February 6, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Thomas J. Papa (CRD# 3222264) in addition to the information contained in the OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”, CRD# 170827) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the OakTrust Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com. Additional information about Mr. Papa is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3222264. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 22  Item 2 – Educational Background and Business Experience Thomas J. Papa, born in 1966, is the Managing Partner and Chief Compliance Officer of OakTrust. Mr. Papa earned a Bachelors in Accounting from Saint John's University in 1988. Additional information regarding Mr. Papa’s employment history is included below. Employment History: Managing Partner and Chief Compliance Officer, OakTrust Wealth Advisors, LLC Registered Representative, LPL Financial LLC Investment Advisor Representative, LPL Financial LLC Vice President, Goldman, Sachs & Co. Director, Cowen & Co. 03/2014 to Present 02/2003 to Present 09/2005 to 10/2015 11/1999 to 02/2003 06/1994 to 10/1999 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Papa. Mr. Papa has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Papa. Securities laws require an advisor to disclose any instances where the advisor or its Advisory Persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Papa. However, the Advisor does encourage you to independently view the background of Mr. Papa on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 3222264. Item 4 – Other Business Activities Broker-Dealer Affiliation Mr. Papa is also a registered representative of LPL Financial LLC (“LPL Financial”). LPL Financial is a registered broker-dealer (CRD# 6413), member FINRA, SIPC. In Mr. Papa’s separate capacity as a registered representative, Mr. Papa will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Papa. Neither the Advisor nor Mr. Papa will earn any investment advisory fees in connection with any products or services implemented in Mr. Papa’s separate capacity as a registered representative. Insurance Agency Affiliations Mr. Papa is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Papa’s role with OakTrust. As an insurance professional, Mr. Papa will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Papa is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Papa or the Advisor. Travel Agent Mr. Papa is also a Travel Agent for Travel by Helen, LLC. Mr. Papa, in his separate capacity, may be compensated for this activity. Mr. Papa spends less than 10% of his time at this activity. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 23  Item 5 – Additional Compensation Mr. Papa has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Papa serves as the Managing Partner and Chief Compliance Officer of OakTrust. Mr. Papa can be reached at (203) 563-0044. OakTrust has implemented a Code of Ethics, an internal compliance document, that guides each Supervised Person in meeting their fiduciary obligations to Clients of OakTrust. Further, OakTrust is subject to regulatory oversight by various agencies. These agencies require registration by OakTrust and its Supervised Persons. As a registered entity, OakTrust is subject to examinations by regulators, which may be announced or unannounced. OakTrust is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 24  Form ADV Part 2B – Brochure Supplement for Nicholas Zizzadoro, ChFC®, CLU®, CPA, PFS Managing Partner Effective: February 6, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Nicholas Zizzadoro, ChFC®, CLU®, CPA, PFS (CRD# 2909444) in addition to the information contained in the OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”, CRD# 170827) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the OakTrust Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (203) 563-0044 or by email at info@oaktrustllc.com. Additional information about Mr. Zizzadoro is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2909444. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 25  Item 2 – Educational Background and Business Experience Nicholas Zizzadoro, ChFC®, CLU®, CPA, PFS, born in 1971, is a Managing Partner of OakTrust. Mr. Zizzadoro earned a BBA in Accounting from Hofstra University in 1993. Additional information regarding Mr. Zizzadoro’s employment history is included below. Employment History: Managing Partner, OakTrust Wealth Advisors, LLC Registered Representative, LPL Financial LLC Investment Advisor Representative, LPL Financial LLC 03/2014 to Present 09/2001 to Present 07/2005 to 11/2015 Chartered Financial Consultant® (ChFC®) The Chartered Financial Consultant® (ChFC®) program prepares you to meet the advanced financial planning needs of individuals, professionals and small business owners. You'll gain a sustainable advantage in this competitive field with in-depth coverage of the key financial planning disciplines, including insurance, income taxation, retirement planning, investments and estate planning. The ChFC® requires three years of full-time, relevant business experience, nine two-hour course specific proctored exams, and 30 hours of continuing education every two years. Holders of the ChFC® designation must adhere to The American College’s Code of Ethics. Program Objectives: • Function as an ethical, competent and articulate practitioner in the field of financial planning • Demonstrate mastery of the core financial planning knowledge required of a CERTIFIED FINANCIAL PLANNERTM by passing the CFP® certification exam • Utilize the intellectual tools and framework needed to maintain relevant and current financial planning knowledge and strategies. • Apply financial planning theory and techniques through the development of case studies and solutions • Apply in-depth knowledge in a holistic manner from a variety of disciplines; namely, estate planning, retirement planning or non-qualified deferred compensation. The Chartered Life Underwriter (“CLU®”) The Chartered Life Underwriter® (CLU®) is a designation of insurance expertise, helping gain a significant advantage in a competitive market. This course of study helps by providing in-depth knowledge on the insurance needs of individuals, business owners and professional clients. Program Learning Objectives: • Provide guidance to clients on types and amounts of life insurance needed • Make recommendations on aspects of risk management, including personal and business uses of a variety of insurance solutions • Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries • Assist clients in making decisions about estate planning, including proper holding of assets and title to assets, as well as the implications of various wills and trust arrangements on financial, retirement and succession planning issues • Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients Certified Public Accountant (“CPA”) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 26  over a three-year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. The vast majority of state boards of accountancy have adopted the AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own. Personal Financial Specialist (“PFS”) The PFS credential demonstrates that an individual has met the minimum education, experience and testing required of a CPA in addition to a minimum level of expertise in personal financial planning. To attain the PFS credential, a candidate must hold an unrevoked CPA license, fulfill 3,000 hours of personal financial planning business experience, complete 80 hours of personal financial planning CPE credits, pass a comprehensive financial planning exam and be an active member of the AICPA. A PFS credential holder is required to adhere to AICPA’s Code of Professional Conduct, and is encouraged to follow AICPA’s Statement on Responsibilities in Financial Planning Practice. To maintain their PFS credential, the recipient must complete 60 hours of financial planning CPE credits every three years. The PFS credential is administered through the AICPA. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Zizzadoro. Mr. Zizzadoro has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Zizzadoro. Securities laws require an advisor to disclose any instances where the advisor or its Advisory Persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Zizzadoro. However, the Advisor does encourage you to independently view the background of Mr. Zizzadoro on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2909444. Item 4 – Other Business Activities Broker-Dealer Affiliation Mr. Zizzadoro is also a registered representative of LPL Financial LLC (“LPL Financial”). LPL Financial is a registered broker-dealer (CRD# 6413), member FINRA, SIPC. In Mr. Zizzadoro’s separate capacity as a registered representative, Mr. Zizzadoro will receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Zizzadoro. Neither the Advisor nor Mr. Zizzadoro will earn any investment advisory fees in connection with any products or services implemented in Mr. Zizzadoro’s separate capacity as a registered representative. Insurance Agency Affiliations Mr. Zizzadoro is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Zizzadoro’s role with OakTrust. As an insurance professional, Mr. Zizzadoro will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Zizzadoro is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Zizzadoro or the Advisor. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 27  Item 5 – Additional Compensation Mr. Zizzadoro has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Zizzadoro serves as a Managing Partner of OakTrust and is supervised by Thomas Papa, the Chief Compliance Officer. Mr. Papa can be reached at (203) 563-0044. OakTrust has implemented a Code of Ethics, an internal compliance document, that guides each Supervised Person in meeting their fiduciary obligations to Clients of OakTrust. Further, OakTrust is subject to regulatory oversight by various agencies. These agencies require registration by OakTrust and its Supervised Persons. As a registered entity, OakTrust is subject to examinations by regulators, which may be announced or unannounced. OakTrust is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 28  Privacy Policy Effective: February 6, 2026 Our Commitment to You OakTrust Wealth Advisors, LLC (“OakTrust” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. OakTrust (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. OakTrust does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 29  How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. OakTrust shares Client information with LPL Financial LLC (“LPL Financial”) due to the oversight PCS has over certain supervised persons of the Advisor. You may also contact us at any time for a copy of the LPL Financial Privacy Policy. Marketing Purposes OakTrust does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where OakTrust or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. Information About Former Clients OakTrust does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations Massachusetts In response to a Massachusetts law, clients must “opt-in” to share non-public, personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (203) 563-0044 or via email at info@oaktrustllc.com. OakTrust Wealth Advisors, LLC 49 Saddle Ridge Road, Wilton, CT 06897 Phone: (203) 563-0044 | Fax: (203) 549-0800 www.oaktrustllc.com Page 30