OLDFATHER FINANCIAL SERVICES

LOGO GOES HERE Form ADV Part 2A Brochure 2033 Central Avenue Kearney, NE 68847 www.oldfatherfinancial.com (308) 237- 4571 Date of Brochure: December 15, 2025 The purpose of this brochure is to disclose to you what we do and who we are at OFS Enterprise LLC dba Oldfather Financial Services (herein OFS). Knowing these elements will allow you to use the services we offer far more effectively. If you have any questions about the contents of this brochure, please do not hesitate to contact us at the telephone number or email address listed above or our website www.oldfatherfinancial.com. OFS is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involves risk, including the possible loss of principal. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC), or by any state securities authority. Additional information about OFS is also available on the Internet at www.adviserinfo.sec.gov. You can view OFS's information on this website by searching for "Oldfather Financial Services". 1  Item 2 Summary of Material Changes Oldfather Financial Services is pleased to provide its clients with this Brochure which is the firm's Form ADV Part 2A & Part 2B. This Brochure contains important information about the business practices of the Advisor as well as a description of potential conflicts of interest relating to the firm's advisory business that could affect a client's account with the Advisor. Since our last annual update amendment filed on February 7, 2025, we have made the following material changes: Item 4 Advisory Business: We amended this item to reflect the change in ownership from Bill Oldfather to Troy Brockmeier. We added Private Market securities to the list of investments we may recommended to certain accredited investors. Item 5 Fees and Compensation: We added a disclosure related to private market investments' internal fees. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss: We added risks related to private market investments. 2  Item 3 Table of Contents Item 1 Cover Page Date of Brochure: December 15, 2025 Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Item 20 Additional Information Page 1 Page 1 Page 3 Page 4 Page 9 Page 12 Page 12 Page 13 Page 21 Page 21 Page 22 Page 23 Page 26 Page 26 Page 27 Page 29 Page 29 Page 30 Page 30 Page 30 3  Item 4 Advisory Business Description of Firm Oldfather Financial Services is a registered investment adviser primarily based in Kearney, NE. We are organized as a limited liability company under the laws of the State of Nebraska. We have been providing investment advisory services since 04/01/1992. We are primarily owned by Troy Brockmeier. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Oldfather Financial Services and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Investment Management Services Our firm provides continuous advice to a Client regarding the investment of Client funds based on the individual needs of the Client. Through personal discussions in which goals and objectives based on a Client's particular circumstances are established, we develop an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation targets. We will also review and discuss a Client's prior investment history, as well as family composition and background. Account supervision is guided by the stated objectives of the Client (e.g., Fixed Income, Aggressive, Capital Appreciation, Moderate, Growth & Income, Balanced, or Conservative), as well as risk tolerance and tax considerations. We primarily advise our Clients regarding investments in stocks, bonds, mutual funds, ETFs, U.S. government and municipal securities, and cash and cash equivalents. We may also provide advice regarding investments held in Client's portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the Client's request. Additionally, for accredited investors, we may also provide advice regarding private placements. When we provide investment management services, clients grant us limited authority to buy and sell securities on a discretionary and non-discretionary basis. More information on our trading authority is explained in Item 16 of this Brochure. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Once the plan is in place we monitor it for you. Monitoring includes reviewing performance and controlling adherence to your objectives. We will then make any changes necessary to keep you on track. Events that could trigger changes in your account(s) include changes in market or economic conditions, changes in your situation, changes in your selected investments or better investments that may become available. We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. 4  We may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Financial Planning Services Financial planning involves an evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values, and withdrawal plans. The key defining aspect of financial planning is that through the financial planning process, all questions, information, and analysis will be considered as they affect and are affected by the entire financial and life situation of the Client. In general, financial planning will address some or all of the following areas of concern. The Client and OFS will work together to select specific areas to cover. These areas may include, but are not limited to, the following: • Business Planning: We provide consulting services for Clients who currently operate their own business, are considering starting a business, or are planning for an exit from their current business. Under this type of engagement, we work with you to assess your current situation, identify your objectives, and develop a plan aimed at achieving your goals. • Cash Flow and Debt Management: We will conduct a review of your income and expenses to determine your current surplus or deficit along with advice on prioritizing how any surplus should be used or how to reduce expenses if they exceed your income. Advice may also be provided on which debts to pay off first based on factors such as the interest rate of the debt and any income tax ramifications. We may also recommend what we believe to be an appropriate cash reserve that should be considered for emergencies and other financial goals, along with a review of accounts (such as money market funds) for such reserves, plus strategies to save desired amounts. • College Savings: Includes projecting the amount that will be needed to achieve college or other post-secondary education funding goals, along with advice on ways for you to save the desired amount. Recommendations as to savings strategies are included, and, if needed, we will review your financial picture as it relates to eligibility for financial aid or the best way to contribute to children and grandchildren (if appropriate). • Employee Benefits Optimization: We will provide review and analysis as to whether you, as an employee, are taking the maximum advantage possible of your employee benefits. If you are a business owner, we will consider and/or recommend the various benefit programs that can be structured to meet both business and personal retirement goals. 5  • Estate Planning: This usually includes an analysis of your exposure to estate taxes and your current estate plan, which may include whether you have a will, powers of attorney, trusts, and other related documents. Our advice also typically includes ways for you to minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of applicable trusts. We always recommend that you consult with a qualified attorney when you initiate, update, or complete estate planning activities. We may provide you with contact information for attorneys who specialize in estate planning when you wish to hire an attorney for such purposes. From time-to-time, we will participate in meetings or phone calls between you and your attorney with your approval or request. • Financial Goals: We will help clients identify financial goals and develop a plan to reach them. We will identify what you plan to accomplish, what resources you will need to make it happen, how much time you will need to reach the goal, and how much you should budget for your goal. • Investment Analysis: This may involve developing an asset allocation strategy to meet client's financial goals and risk tolerance, providing information on investment vehicles and strategies, reviewing employee stock options, as well as assisting you in establishing your own investment account at a selected broker/dealer or custodian. The strategies and types of investments we may recommend are further discussed in Item 8 of this brochure. • Retirement Planning: Our retirement planning services typically include projections of your likelihood of achieving your financial goals, typically focusing on financial independence as the primary objective. For situations where projections show less than the desired results, we may make recommendations, including those that may impact the original projections by adjusting certain variables (e.g., working longer, saving more, spending less, taking more risk with investments). If you are near retirement or already retired, advice may be given on appropriate distribution strategies to minimize the likelihood of running out of money or having to adversely alter spending during your retirement years. • Risk Management: A risk management review includes an analysis of your exposure to major risks that could have a significant adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or the need for long-term care planning. Advice may be provided on ways to minimize such risks and about weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of not purchasing insurance ("self-insuring"). • Tax Planning Strategies: Advice may include ways to minimize current and future income taxes as a part of your overall financial planning picture. For example, we may make recommendations on which type of account(s) or specific investments should be owned based in part on their "tax efficiency," with the consideration that there is always a possibility of future changes to federal, state or local tax laws and rates that may impact your situation. We recommend that you consult with a qualified tax professional before initiating any tax planning strategy, and we may provide you with contact information for accountants or attorneys who specialize in this area if you wish to hire someone for such purposes. We will participate in meetings or phone calls between you and your tax professional with your approval. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. 6  You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm. Retirement Plan Consulting Services OFS also provides retirement plan consulting services to assist businesses with administration of their defined benefit and defined contribution retirement plans. In these engagements, we may provide discretionary management services, non-discretionary management services, or non-management advisory/consulting services, depending on the needs of the plan. In a discretionary management engagement, OFS would be responsible for making decisions and acting upon those decisions on behalf of the plan. In a non-discretionary management engagement, OFS would be responsible for making changes for a plan upon a client's approval. In an advisory/consulting engagement, OFS would serve in an advisory capacity where the client retains control for implementation of all recommendations and other actions. Our primary goal is to assist our clients in designing, implementing, and maintaining retirement plans that meet their specific needs. Our services are tailored to cater to a wide range of clients, from small businesses to large corporations, offering services to both defined contribution and defined benefit plans. Our retirement plan consulting services include, but are not limited to, the following: • Participant Education and Engagement: We believe that informed participants are crucial for the success of a retirement plan. Hence, we provide educational sessions and materials to help participants understand their retirement savings options, the importance of contributing to their retirement, and how to manage their investments. • Benchmarking Services: Advisory Representatives will provide Client with comparisons of Plan data (e.g., regarding fees, services, participant enrollment and contributions) to data from the Plan's prior years and/or a benchmark group of similar plans. • Fee Analysis: Advisory Representatives will assist client in identifying the fees and other costs borne by the Plan for, as specified by client, investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. • Vendor Management and Selection: We assist in the selection and management of plan vendors, ensuring that they provide quality services at competitive prices. This includes negotiating terms with vendors, monitoring their performance, and ensuring they meet service expectations. Our retirement plan consulting services are designed to be flexible, accommodating the unique needs and circumstances of each client. We pride ourselves on our commitment to providing high-quality, personalized service, aimed at helping our clients achieve successful retirement outcomes for their employees. For a more detailed description of the non-fiduciary services provided, the ERISA plan client should refer to the investment advisory agreement. Client Tailored Services and Client Imposed Restrictions We tailor the delivery of our services to meet the individual needs of our clients. We consult with clients initially and on an ongoing basis, through the duration of their engagement with us, to determine risk tolerance, time horizon and other factors that may impact the Clients' investment and/or planning needs. 7  Clients are able to specify, within reason, any restrictions they would like to place as it pertains to individual securities and/or sectors that will be traded in their accounts. All such requests must be provided to OFS in writing and signed by the client. OFS will notify clients if they are unable to accommodate any requests. From time to time, OFS recommends third-party professionals such as attorneys, accountants, tax advisors, insurance agents, or other financial professionals. Clients are never obligated to utilize any third-party professional we recommend. OFS is not affiliated with nor does OFS receive any compensation from third-party professionals we may recommend. Wrap Accounts We do not offer wrap fee programs. Types of Investments We primarily offer advice on ETFs and Mutual Funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. 8  Assets We Manage As of December 1, 2025 Oldfather Financial Services managed total assets of $529,663,221 on a discretionary basis for our clients and $11,846,249 on a non-discretionary basis. Item 5 Fees and Compensation Oldfather Financial Services is a purely fee-only firm. We receive no cash compensation from anyone but our client. We receive no compensation from the sale of any securities or investment products. We receive no commissions, fees, markups, service fees, awards or prizes for recommending any individual product. You should note that similar investment advisory services may or may not be available from other registered investment advisors for similar or lower fees. We do receive brokerage services from Charles Schwab. See Item #12. Below is a brief description of our fees, however, you should review your executed Advisory Contract for more detailed information regarding the exact fees you will be paying. No increase to the agreed- upon advisory fees outlined in the Advisory Contract shall occur without prior client consent. Investment Management Services Our investment management fees are negotiable and as a result, clients with similar assets may have different fee schedules and pay different fees. Fees are paid in advance either monthly, quarterly, semiannually or annually. Our fees are based on a percentage of assets under management. OFS charges an annualized management fee that ranges up to 1.50%. Fees are based on the aggregate amount of all household assets held under management. Fees are also based on the client's financial situation, assets under management, and complexity of services offered. Percentage of asset fees are based on the account value at the beginning of the billing period. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. We may also negotiate a flat fee or a constant dollar annual retainer with the client in advance. This fee is based on the account size, the types of assets it contains, and the amount of supervision and other work required. We have no minimum account size. We retain the discretion to negotiate alternative fees on a client-by client basis. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy. 9  We encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian call our main office number located on the cover page of this brochure. You may terminate the portfolio management agreement upon 30 days written notice. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees. Financial Planning Services OFS charges either a fixed or hourly fee for Financial Planning Services. Fixed fee rates range between $500 to $10,000. Our hourly rate is $250. The fee range is dependent upon variables including the specific needs of the Client, complexity, estimated time, research, and resources required to provide services to you, among other factors we deem relevant. Fees are negotiable and the final agreed upon fee and timing in which we collect our fee will be outlined in your Advisory Contract. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we will notify you and request that you approve the additional fee. We also offer advice on single subject financial planning/general consulting services at the same hourly rate. We will not require payment of a fee more than six months in advance and in excess of $1,200. At our discretion, we may offset our financial planning fees to the extent you implement the financial plan through our Investment Management Service. You may terminate the financial planning agreement upon written notice to our firm. If you have pre- paid financial planning fees that we have not year earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning agreement. Retirement Plan Services Fees charged for retirement plan services may be charged in advance or in arrears depending on the service provided. Fees may be fixed or asset based (not to exceed 1.50% annually), and are negotiable depending on the complexity of the service. Fee levels (whether fixed or asset based) are primarily based on actual services to be provided. Fees may be deducted directly from client accounts on a quarterly basis, or clients may elect to alternatively pay fees by check or wire transfer. Services may be terminated at any time by either party with 30 days written notice to the other party, and fees will be prorated accordingly. Billing and Payment of Fees Fees for Investment Management Advisory fees may be deducted from one of your accounts or if you have more than one account the fee can be billed to each account. This is our preferred billing methodology and we request that you provide instructions to your account custodian to allow us to debit our fees. Your other option is that we 10  can bill you directly for our services. Fees are normally due in advance on a quarterly basis but may be paid more or less frequently if desired. You have the option of paying the whole annual fee in advance, but we do not accept payments of more than $1,200 six months or more in advance. The Custodian will send client statements at least quarterly, showing all activity in the account including the advisory fee, if it is deducted from the account. Advisory fees are billed and due in advance. Your Investment Advisory Agreement with us may be cancelled at any time, by either party, for any reason upon receipt of prior written notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. Any refund will be effective on the day the termination notice is received. The refund will be calculated by taking the number of days in the prepaid period, then dividing that by the amount of the total fee for the period. Then multiply that daily amount by the number of days left in the prepaid period. If a client terminates the Investment Advisory Agreement within 21 days of signing the agreement, OFS Enterprise LLC dba Oldfather Financial Services will refund 100% of any prepaid advisory fees. As of the effective date of termination of our investment management services, we will have no obligation or authority to recommend or take any action with regard to your previously managed assets. You will bear sole responsibility to work with your custodian for proper liquidation and/or management of your assets upon termination. Any un-used pre-paid Financial planning fees will be refunded if client no longer desires the work to be done. Our fees of $250 an hour will be charged for work already done and the balance will be refunded. Fees for Financial Planning Services We will provide an estimate of the charges for Financial Planning services within your Advisory Contract. In limited circumstances, the total cost or time required may exceed the initial estimate. If this occurs, we will notify you in advance and request your approval for any additional fees before continuing with the services. Financial Planning fees may be paid either in advance, in arrears, or over intervals such as quarterly or monthly, depending on the terms outlined in your Advisory Contract. If fees are paid in advance, we will not require prepayment of more than $1,200 for services to be delivered more than six months in advance. Fees paid in arrears will be invoiced upon completion of the agreed-upon services or periodically, as specified in the Advisory Contract. At our discretion, Financial Planning fees may be reduced, waived, or charged in addition to Investment Management fees, depending on the extent to which you implement your financial plan through our Investment Management services. In the event the Financial Planning agreement is terminated before services are fully completed, any unearned fees that were prepaid will be refunded on a prorated basis. If fees are billed in arrears, you will be responsible for a prorated amount based on the services performed up to the date of termination. Any outstanding amounts will be due immediately upon termination. Fees for Financial Planning Services Our fees do not cover costs of servicing a qualified retirement plan. Third parties charge these fees under separate agreements with the plan or plan sponsor. Other Types of Fees and Expenses As part of our services, we may recommend or invest in mutual funds, exchange-traded funds (ETFs), variable annuities, and other securities. The fees you pay to our firm for investment advisory services are separate from the fees and expenses charged by mutual funds, ETFs, or annuities, as described in their prospectuses. These fees typically include a management fee and other fund-related expenses. 11  For accredited investors, we may recommend a private market offering. The fees charged by these funds are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the particular investment. You may also incur transaction charges, brokerage fees, and other costs when purchasing or selling securities. These charges are generally imposed by the broker-dealer or custodian executing your transactions and are distinct from the advisory fees charged by our firm. We do not receive or share in any portion of these third-party fees. To fully understand the total costs you may incur, we encourage you to review all applicable fees and expenses, including those charged by mutual funds, ETFs, broker-dealers, custodians, and our firm. For further details on our brokerage practices, please refer to the Brokerage Practices section of this brochure. Sale of Securities or Other Investment Products Oldfather Financial Services and its supervised persons do not accept compensation for the sale of securities or other investment products including asset-based sales charges or service fees from the sale of mutual funds. Other Compensation Received Oldfather Financial Services receives no cash compensation from anyone but our client. We receive no compensation from the sale of any securities or investment products. We receive no commissions, asset-based fees, markups, service fees, awards or prizes from anyone including brokers or mutual fund companies. We do receive non-monetary services from Charles Schwab. See Item #12. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- based fees. Our fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We provide financial planning and investment management services to individuals, high net-worth individuals, pension and profit-sharing plans, trusts, foundations, endowments, charitable organizations, and corporations or other businesses not listed above. Private placements are only recommended to accredited investors. We do not have a minimum account size requirement. 12  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Equity Analysis OFS relies on an investment philosophy that is based on established academic research, such as Modern Portfolio Theory and the Fama-French Three-Factor Model, and established discoveries in behavioral finance. Modern Portfolio Theory says that it is not enough to look at the expected risk and return of one particular asset class. By investing in more than one asset class, an investor can reap the benefits of diversification—chief among them, a reduction in the risk level of the portfolio. Modern Portfolio Theory quantifies the benefits of diversification, also known as "not putting all your eggs in one basket." The Fama-French Three-Factor Model, through research, found that over long periods of time, value stocks outperform growth stocks and, similarly, small cap stocks tend to outperform large cap stocks. Therefore, by analyzing these factors it becomes easier to evaluate the potential portfolio performance. The OFS investment philosophy is based on the following basic principles: Develop highly diversified portfolios that feature a broad range of asset classes and market sectors. Use predominantly market-based investments, not manager-based investments. Hold the investments for long periods of time. Periodically reallocate investments as conditions warrant. Strategically rebalance as needed. This approach, of course, cannot ensure investment success or prevent loss in a declining market. Investing in securities involves risk of loss. Past performance of any investment or method of investing is no guarantee of future results. Security analysis methods we use most for individual securities include fundamental analysis and value investing. We attempt to measure the intrinsic value of securities and markets by examining related economic, financial and other qualitative and quantitative factors. The value of a business is not always reflected in its stock price. The end goal of fundamental analysis is to produce a value that an investor can compare to a security's current price to figure out if the security is over or under priced and whether it should be bought or sold. Another analytic method we use is cyclical analysis which is a method of evaluating investments by determining how sensitive they are to the business cycle. Different investments perform differently depending upon whether the economy is doing well or is in a cyclical downturn. The main sources of information for analysis include but are not limited to financial newspapers, magazines, research materials prepared by others including annual reports, prospectuses, SEC filings and conference calls. Reporting services used include but are not limited to Bloomberg, Morningstar, S&P and Value Line. We strive to mitigate risk by properly positioning our client's account(s) in the appropriate main asset classes including stocks, bonds and cash. We may from time to time use other alternative asset classes. We further attempt to reduce risk by diversifying investments within each of these asset classes. 13  We have seven different model portfolios that we place our investors in that attempt to match their investments with their risk and return profile. FIXED INCOME This is typically considered among the most conservative risk profile. 100% of the investments will be bonds. No stocks. It emphasizes income and preservation of principal. The investments used may be taxable or tax free depending on the client and the type of account. AGGRESSIVE This is the most aggressive risk profile. This portfolio has a target of 100% stocks with general limits or 80 to 100% stocks and up to 20% bonds allowed. It emphasizes growth over a long period of time not to be less than 7 years. CAPITAL APPRECIATION This is also an aggressive risk profile. It has a target of 80% stocks and 20% bonds with general limits of 70 to 80% stocks and 30 to 50% bonds. It emphasizes long term growth with less volatility and less return than the Aggressive portfolio. MODERATE This is more moderate risk portfolio. It has a target of 70% stocks and 30% bonds with general limits of 50 to 70% stocks and 30 to 50% bonds. It still emphasizes long term growth with less volatility than the Capital Appreciation portfolio. GROWTH and INCOME This is slightly above the middle of the risk return profile. The Growth and Income portfolio has a target of 60% stocks and 40% bonds with general limits of 45 to 60% stocks and 40 to 55% bonds. This portfolio is for those who are slightly more aggressive than the middle risk profile. BALANCED This is in the middle of the risk return profile. The Balanced portfolio has a target of 50% stocks and 50% bonds with general limits of 35 to 50% stocks and 50 to 65% bonds. This is a good portfolio for those close to retirement or those who are actually retired and drawing income from their investments. CONSERVATIVE In our view, this is the most conservative portfolio that contains stocks. The target is 35% stocks and 65% bonds but may go as low as 0% in stocks and as high as 100% in bonds. This is for more risk adverse investors who still need exposure to the stock market for growth but lean toward preservation of their original investment. These maximum stock allocations are designed to keep investment objectives in line with the actual portfolios. The above allocations apply to all of the client's investment accounts when aggregated and are designed as a limit to risk, not as a specific allocation to be maintained at all times. 14  Because of the nature of markets these seven portfolios are guidelines. The actual percentage of stocks may be lower in some cases much lower than the target of the risk category. Factors such as short term needs for liquidity or plans for a market downturn may be reasons for a lower stock allocation. In other instances, the percentage of stocks may be higher than the target due to extremely high market situations or other factors. We use many kinds of securities for portfolios including, but not limited to individual stocks and bonds, no-load mutual funds, load-waived mutual fundsand exchange traded funds. Our Methods of Analysis and Investment Strategies We use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Fixed Income Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets, in conjunction with a core and satellite approach: • Fundamental analysis. We accept that treasuries, US government guaranteed/collateralized debt and federal agencies are exempt from credit risk. GNMA, FNMA & FHLB mortgage backed debt fits in this category as well. Corporate debt and asset back securities must be exchange listed and or highly liquid. Municipal revenue bonds must display consistent debt service coverage. Municipal general obligation bonds must display modest debt to assessed valuations. The underlying securities in all fixed income mutual funds must meet the same criterion as the individual securities OFS purchases, or employ esoteric investment styles not easily addressed by individual securities (high yield, foreign, alternative assets etc.). Mutual funds are expected to display a track record that validates the fund manager's ability to add value. • Yield Curve Analysis. We analyze the prevailing interest rates in all asset classes and maturities. Yield curves can be steep, flat, inverted, parabolic, etc. We analyze the liquidity requirements of each portfolio and ladder fixed income accordingly. As a result, our fixed income portfolios can be equally laddered, dumbbell laddered, long in duration, short in duration, etc. • ‐ Asset Class Analysis. The relationship of treasury, agency, corporate and municipal yields is always in a state of flux. Market conditions can dislocate the traditional relationship of all asset classes. OFS monitors all these relationships and looks for opportunities to use approved securities in non traditional roles. This analysis can generate extension, contraction and yield pickup swaps. A risk in using this type of quantitative analysis occurs when that the asset class models being used and the assumptions based on them prove to be incorrect. • Risks for All Forms of Analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. To that end, we combine fundamental and quantitative analysis whenever possible. However, there is always a risk that our analysis may be compromised by inaccurate or misleading information. 15  Technical Analysis - involves studying past price patterns, trends and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify us immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Cash Management In managing the cash maintained in your account, we utilize the sole exclusive cash vehicle (money market) made available by the custodian. There may be other cash management options away from the custodian available to you with higher yields or safer underlying investments. 16  Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive, but should be considered carefully by a prospective client before retaining our services. Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all. Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many types of fixed income investments to decline. Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time that the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired, or are nearing retirement. Recommendation of Particular Types of Securities We primarily recommend ETF, and Mutual Funds. However, we may advise on other types of investments as appropriate for you since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible 17  to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than you expected to earn, you may end up needing more cash. A final risk you are taking with money market funds has to do with inflation. Because money market funds are considered to be safer than other investments like stocks, long-term average returns on money market funds tends to be less than long term average returns on riskier investments. Over long periods of time, inflation can eat away at your returns. Certificates of Deposit: Certificates of deposit ("CD") are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company ("FDIC") up to a certain amount. However, because the returns are generally low, there is risk that inflation outpaces the return of the CD. Certain CDs are traded in the market place and not purchased directly from a banking institution. In addition to trading risk, when CDs are purchased at a premium, the premium is not covered by the FDIC. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, 18  risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Variable Annuities: A variable annuity is a form of insurance where the seller or issuer (typically an insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular- payment annuity). The payment stream from the issuer to the annuitant has an unknown duration based principally upon the date of death of the annuitant. At this point, the contract will terminate and the remainder of the funds accumulated forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable annuities, pay amounts that vary according to the performance of a specified set of investments, typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales charges or surrender charges for withdrawals within a specified period. Variable annuities may impose a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and expense risk charges; administrative fees; underlying fund expenses; and charges for special features, all of which can reduce the return. Earnings in a variable annuity do not provide all the tax advantages of 401(k)s and other before-tax retirement plans. Once the investor starts withdrawing money from their variable annuity, earnings are taxed at the ordinary income rate, rather than at the lower capital gains rates applied to other non-tax-deferred vehicles which are held for more than one year. Proceeds of most variable annuities do not receive a "step-up" in cost basis when the owner dies like stocks, bonds and mutual funds do. Some variable annuities offer "bonus credits." These are usually not free. In order to fund them, insurance companies typically impose mortality and expense charges and surrender charge periods. In an exchange of an existing annuity for a new annuity (so-called 1035 exchanges), the new variable annuity may have a lower contract value and a smaller death benefit; may impose new surrender charges or increase the period of time for which the surrender charge applies; may have higher annual fees; and provide another commission for the broker. Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip 19  into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Private Market Securities Private market securities, which can include private equity, private debt, real estate partnerships, or other non-publicly traded investments, are generally considered higher-risk and less liquid than publicly traded securities. Because these investments are not registered with the Securities and Exchange Commission ("SEC"), they are typically available only to investors who meet certain financial or accreditation standards. The valuation of private market securities can be complex, and there may be limited or no secondary market available, meaning that investors may be unable to sell their interests quickly or at an expected price. These securities also carry risks related to the management of the underlying investment, the performance of the private businesses or assets involved, and the potential for the loss of principal. In exchange for accepting these risks and illiquidity, investors may have the opportunity to earn higher long-term returns relative to traditional public market investments. A more detailed description of the risks associated with each particular investment strategy is included in the Offering Documents of the respective Fund, a copy of which is provided to prospective Fund Investors and should be carefully reviewed prior to investing in the Funds. Options Contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks pertaining to options buyers are: • Risk of losing your entire investment in a relatively short period of time. • The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). • European style options which do not have secondary markets on which to sell the options prior to expiration can only realize its value upon expiration. • Specific exercise provisions of a specific option contract may create risks. • Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks pertaining to options sellers are: 20  • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk substantial losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. • Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how the leverage in options can work against the option trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. • Call options can be exercised outside of market hours such that effective remedy actions cannot be performed by the writer of those options. • Writers of stock options are obligated under the options that they sold even if a trading market is not available or that they are unable to perform a closing transaction. • The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: • The complexity of some option strategies is a significant risk on its own. • Option trading exchanges or markets and option contracts themselves are open to changes at all times. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. • Risk of erroneous reporting of exercise value. • • Risks that are not specific to options trading include market risk, sector risk and individual stock risk. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks Item 9 Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of OFS or the integrity of OFS's management. We have no legal or disciplinary events for a client or prospective client to consider. Item 10 Other Financial Industry Activities and Affiliations We have not provided information on other financial industry activities and affiliations because we do not have any relationship or arrangement that is material to our advisory business or to our clients with any of the types of entities listed below. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker; 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund); 21  3. other investment adviser or financial planner; 4. futures commission merchant, commodity pool operator, or commodity trading adviser; 5. banking or thrift institution; 6. accountant or accounting firm; 7. lawyer or law firm; 8. insurance company or agency; 9. pension consultant; 10.real estate broker or dealer; and/or 11.sponsor or syndicator of limited partnerships. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading OFS has adopted a Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, which applies to all supervised persons of the firm and describes our firm's high standard of business conduct and fiduciary duty to clients. Our Code of Ethics and other ethical rules and guidelines are designed to prevent prohibited acts and eliminate potential conflicts of interests and demonstrate our commitment to our fiduciary duties to our clients. Prohibitions against over-reaching, self-dealing, insider trading and the appearance of actual conflicts of interest are set forth in these ethics rules. The ethics rules forbid any officer or employee from trading, either personally or on the behalf of others, on material non-public information or communicating material non-public information to others in violation of the law. The ethics rules provide that covered persons must obtain advanced approval for certain personal securities transactions including transactions for the accounts of spouses, minor children and family members sharing the covered person's household. In addition, the ethics rules set forth restrictions on the receipt of gifts, outside employment, maintenance of brokerage accounts, and other matters by our employees. A copy of our Code of Ethics is available upon request. As a fiduciary, our firm has a duty of utmost good faith to act solely in the best interests of each Client. Our Clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The firm also adheres to the Code of Ethics and Professional Responsibility adopted by the CFP® Board of Standards Inc., andaccepts the obligation not only to comply with the mandates and requirements of all applicable laws and regulations but also to take responsibility to act in an ethical and professionally responsible manner in all professional services and activities. From time to time, we may recommend to clients that they buy or sell stocks, bonds, mutual funds, ETF's, or other securities that the firm, employees or the relatives of employees may also own. All related persons are governed by investment restrictions, prohibitions and requirements established by our Policies and Procedures and Code of Ethics. These Policies and Procedures and Code of Ethics are intended to ensure that the interests of our clients come first. All of the securities we purchase for clients and related persons and relatives of the firm are securities that are publicly traded in high volumes and the affected trades are for relatively low dollar volumes when compared to the entire market. These trades would have no noticeable effect on market prices for the affected securities. Participation or Interest in Client Transactions Neither our firm nor any persons associated with our firm has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. 22  Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). Refer to the Brokerage Practices section in this brochure for information on our aggregated trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices Factors Considered in Recommending Brokers Our goal is to fulfill our fiduciary obligation when we choose where we place our client's trades. Client trades can be directed to many different venues and we must choose how and where these trades will be directed. Everything possible will be done to obtain the best possible outcome for our clients. The factors we consider in selecting a custodian for your account(s) include; investment choices offered, financial stability, commission rates, integrity of custodian, quality of back office service, timely and favorable execution of trades, availability of securities and investment products and the quality of client reporting. We currently recommend Charles Schwab Co., Inc. (Schwab) for custody of our client separate accounts. We set up and administer your account for you and you give us discretionary authority to trade in the account on your behalf. Schwab is a discount broker. Schwab charges commissions and collects fees from client accounts and the client pays us a fee for managing their accounts. We receive no commissions or other cash payments from Schwab. The only fees we receive come directly from our client. We are not affiliated with Schwab and we may recommend any custodian we feel is qualified. Although we recommend Schwab, it is the client's decision as to who they would like to custody their assets. If a client chooses another custodian it may increase their overall cost. Schwab provides us with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. Schwab Institutional also makes available to us other products and services that benefit us but may not directly benefit our clients' accounts. Schwab's products and services that assist us in managing and administering clients' accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitates trade execution; (iii) provides research, pricing and other market data; (iv) facilitates payment of our fees from client accounts; and (v) assists with back office functions, recordkeeping and client reporting. Schwab also provides market research and 23  practice management information. These are standard services offered by many custodians. Because we use Schwab, Oldfather Financial Services does not have to produce or pay for these services. These services qualify for the safe harbor in section 28(e) of the Securities and Exchange Act of 1934. Oldfather Financial Services may have an incentive to select or recommend a broker/custodian based on our interest in receiving services rather than on our client's receiving favorable execution. Clients may pay commissions (markups or markdowns) higher than those charged by other broker dealers in return for services. Any of these services received are used to service all client accounts and are not allocated to specific accounts. Services received in the last year include research, pricing and other market data, facilitating payment of our fees from client accounts, and assisting with back office functions, recordkeeping, client reporting. We also received practice management research and information. Clients may direct us to use another broker/dealer or custodian for separate account managed accounts if they wish. Fees and costs may be higher or lower than Schwab. Research and Other Soft Dollar Benefits In selecting or recommending a broker-dealer, we will consider the value of research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and our firm. Receipt of these additional brokerage products and services are considered to have been paid for with "soft dollars." Because such services could be considered to provide a benefit to our firm, we have a conflict of interest in directing your brokerage business. We could receive benefits by selecting a particular broker-dealer to execute your transactions, and the transaction compensation charged by that broker-dealer might not be the lowest compensation we might otherwise be able to negotiate. Products and services that we may receive from broker-dealers may consist of research data and analyses, financial publications, recommendations, or other information about particular companies and industries (through research reports and otherwise), and other products or services (e.g., software and data bases) that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Consistent with applicable rules, brokerage products and services consist primarily of computer services and software that permit our firm to effect securities transactions and perform functions incidental to transaction execution. We use such products and services in our general investment decision making, not just for those accounts for which commissions may be considered to have been used to pay for the products or services. The test for determining whether a service, product or benefit obtained from or at the expense of a broker constitutes "research" under this definition is whether the service, product, or benefit assists our firm in investment decision-making for discretionary client accounts. Services, products, or benefits that do not assist in investment decision-making for discretionary client accounts do not qualify as "research." Also, services, products or benefits that are used in part for investment decision-making for discretionary client accounts and in part for other purposes (such as accounting, corporate administration, recordkeeping, performance attribution analysis, client reporting, or investment decision-making for the firm's own investment accounts) constitute "research" only to the extent that they are used in investment decision-making for discretionary client accounts. Before placing orders with a particular broker-dealer, we determine that the commissions to be paid are reasonable in relation to the value of all the brokerage and research products and services provided by that broker-dealer. In some cases, the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts charged by another broker-dealer that did not provide research services or products. 24  We do not exclude a broker-dealer from receiving business simply because the broker-dealer does not provide our firm with soft dollar research products and services. However, we may not be willing to pay the same commission to such broker-dealer as we would have paid had the broker-dealer provided such products and services. The products and services we receive from broker-dealers will generally be used in servicing all of our clients' accounts. Our use of these products and services will not be limited to the accounts that paid commissions to the broker-dealer for such products and services. In addition, we may not allocate soft dollar benefits to your accounts proportionately to the soft dollar credits the accounts generate. As part of our fiduciary duties to you, we endeavor at all times to put your interests first. You should be aware that the receipt of economic benefits by our firm is considered to create a conflict of interest. We have instituted certain procedures governing soft dollar relationships including preparation of a brokerage allocation budget, mandated reporting of soft dollar irregularities, annual evaluation of soft dollar relationships, and an annual review of our brochure to ensure adequate disclosures of conflicts of interest regarding our soft dollar relationships. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products are in addition to any benefits or research we pay for with soft dollars, and may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage In limited circumstances, and at our discretion, some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm from aggregating trades with other client accounts or from effectively negotiating brokerage commissions on your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in comparison to those that we would otherwise obtain for you. Aggregated Trades We combine multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, participating accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, 25  typically in proportion to the size of each client's order. Accounts owned by our firm or persons associated with our firm may participate in aggregated trading with your accounts; however, they will not be given preferential treatment. Mutual Fund Share Classes Mutual funds are sold with different share classes, which carry different cost structures. Each available share class is described in the mutual fund's prospectus. When we purchase, or recommend the purchase of, mutual funds for a client, we select the share class that is deemed to be in the client's best interest, taking into consideration cost, tax implications, and other factors. When the fund is available for purchase at net asset value, we will purchase, or recommend the purchase of, the fund at net asset value. We also review the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. Item 13 Review of Accounts Individual accounts are reviewed at least quarterly by the Investment Advisor Representative. Accounts are reallocated as market or other conditions warrant. Accounts may also be reviewed if there is a change in investment objectives, a substantial change in the markets or the economy, at the maturity of fixed income securities and if cash or other assets are added or withdrawn. Accounts may also be reviewed with the client as requested at any time or on a regular basis either quarterly, semi- annually or annually. Clients are obligated to promptly notify Oldfather Financial Services of any changes in the client's financial status and to ensure that our investment strategies continue to meet the client's changing needs. Clients receive standard account statements monthly from a qualified custodian either by mail or email if there is any activity in the account and quarterly if there is no activity. They receive confirmations of trades within a few days after they occur by mail or email. Financial Planning services may be either one-time, or ongoing. In the case of one-time Financial Planning services, OFS has no duty to monitor or update financial plans. Clients may arrange for or request an update or subsequent reviews of their financial plans or consultations. This requires a new Financial Planning Agreement and an additional fee. While reviews and updates to the financial plan are not part of the contracted services, at your request we will review your financial plan to determine if the investment advice provided is consistent with your investment needs and objectives. We will also update the financial plan at your request. At our sole discretion, reviews and updates may be subject to our then current hourly rate. If you implement the financial planning advice provided by our firm, you will receive trade confirmations and monthly or quarterly statements from relevant custodians. Item 14 Client Referrals and Other Compensation We directly compensate non-employee (outside) consultants, individuals, and/or entities (solicitors) for client referrals. In order to receive a cash referral fee from us, solicitors must comply with the requirements of the jurisdictions in which they operate. If you were referred to us by a solicitor, you should have received a copy of this brochure along with the solicitor's disclosure statement at the time of the referral. If you become a client, the solicitor that referred you to us will receive a one-time, flat referral fee upon your signing our advisory agreement. You will not pay additional fees because of this referral arrangement. Referral fees paid to a solicitor are contingent upon your entering into an 26  advisory agreement with us. Therefore, a solicitor has a financial incentive to recommend us to you for advisory services. This creates a conflict of interest; however, you are not obligated to retain us for advisory services. Comparable services and/or lower fees may be available through other firms. Solicitors that refer business to more than one investment adviser may have a financial incentive to recommend advisers with more favorable compensation arrangements. We request that our solicitors disclose to you whether multiple referral relationships exist and that comparable services may be available from other advisers for lower fees and/or where the Solicitor's compensation is less favorable. OFS may receive client referrals from online referral services that utilize algorithms to match clients seeking fiduciary personal investment management or financial planning services with independent investment advisors. These services are independent of and unaffiliated with OFS and there is no employee relationship between them. These services do not supervise the Advisor and have no responsibility for the Advisor's management of client portfolios or the Advisor's other advice or services. The Advisor pays the online referral service an on-going fee for each successful client referral. This fee paid to the referral service may be a flat annual fee or a percentage of the advisory fee that the referred client pays to the Advisor. The independent and unaffiliated referral service may be paid on a one time per referral basis. OFS will not charge clients referred through the service any fees or costs higher than its standard fee schedule offered to its clients. Information regarding additional or other fees paid directly or indirectly to an online referral service will be provided in a disclosure to the client. Item 15 Custody We do not maintain physical custody of your funds or securities; a qualified custodian, Charles Schwab or another custodian selected by you maintains custody of your assets. We establish relationships with nonaffiliated third-party clearing/custodying broker-dealers (qualified custodians as defined by Rule 206(4)2) who are responsible for taking custody of and maintaining all client funds and securities, as discussed in Item 12. The custodian sends confirmations and account statements directly to clients on at least a quarterly basis. These confirmations and account statements should be reviewed carefully by the client. Oldfather Financial Services may be deemed to have custody of client funds because clients give us authority to deduct fees from their accounts. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. Other outside accounts such as company retirement plans we may watch for you, incorporate into your asset allocation and make recommendations for you but these accounts that are held at other custodians are non-discretionary accounts that we do not have the authority to trade. For these accounts it is your responsibility to make any recommended trades. OFS has no custody or power of attorney over these outside accounts. From time to time and on no regular basis clients may receive statements from Oldfather Financial Services. Clients should compare them to the statements received from various custodians for accuracy. Fees we charge that are deducted directly from your brokerage account will be included in statements provided by the custodian. 27  For private market securities, investors to whom the Fund is offered will receive a private placement memorandum and other offering documents. The fees charged by the Fund are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Fund. Trustee Services Persons associated with our firm may serve as trustees to certain accounts for which we also provide investment advisory services. In all cases, the persons associated with our firm have been appointed trustee as a result of a family or personal relationship with the trust grantor and/or beneficiary and not as a result of employment with our firm. Therefore, we are not deemed to have custody over the advisory accounts for which persons associated with our firm serve as trustee. Wire Transfer and Standing Letter of Authorization Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third party wire transfers has access to the client's assets, and therefore has custody of the client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Held Away Accounts We use a platform provided by Pontera to manage held away assets such as defined contribution plan participant accounts, with discretion. The Pontera platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to or direct use of Client log-in credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from Pontera for using their platform. For certain 401k accounts, plan participants can authorize us to place trades using Pontera. Those clients who do not provide us with such authorization must place any trades in the 401k accounts themselves through their plan provider. A link will be provided to the Client allowing them to connect an account(s) to the platform provided by Pontera. Once a Client account is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account, taking into consideration client 28  investment goals and risk tolerance, and any change in allocations. Client account(s) will be reviewed at least quarterly and allocation changes will be made as we deem necessary. You will receive an email notification every time your account is reviewed. Item 16 Investment Discretion We have discretionary authority to trade securities in client accounts that we manage. This means we make investment decisions and carry them out without getting approval for every trade. We follow the asset allocation approved by our client. See Item #8. As part of the Investment Advisory Agreement and the Custodian account agreement, the client gives us their power of attorney to trade in their account(s) for them. Other outside accounts such as company retirement plans we may watch for you, incorporate into your asset allocation and make recommendations for you but these accounts that are held at other custodians are non-discretionary accounts that we do not have the authority to trade. For these accounts it is your responsibility to make any recommended trades. OFS has no custody or power of attorney over these outside accounts. You have the right to place reasonable restrictions on your accounts. You may also place reasonable restrictions on the discretionary power granted to us so long as the limitations are specifically set forth or included as an attachment to the Investment Advisory Agreement. OFS does not assume market risk on behalf of the client. OFS does not guarantee the performance of the client's account or any specific level of performance. Market values of the securities within the account will fluctuate with market conditions. When the account is liquidated, it may be worth more or less than the original amount invested. OFS does not provide legal or tax advice to clients. Clients are advised to discuss the possible legal or tax consequences of their investment decisions with their legal or tax advisors prior to effecting any transaction. Item 17 Voting Client Securities Oldfather Financial Services will vote proxies for all client accounts; however, you always have the right to vote proxies yourself. You can exercise this right by instructing us not to vote proxies in your account. In accordance with its fiduciary duty to clients and Rule 206(4)6 of the Investment Advisors Act, Oldfather Financial Services has adopted and implemented written policies and procedures governing the voting of client securities. All proxies that Oldfather Financial Services receives will be treated in accordance with these policies and procedures. Oldfather Financial Services has engaged the services of Broadridge's ProxyEdge platform to vote and maintain records of all proxies. The Broadridge open architecture platform allows OFS Enterprise LLC dba Oldfather Financial Services to choose from several different proxy advisory firms to make recommendations on how our firm should vote the proxies. OFS Enterprise LLC dba Oldfather Financial Services has selected Egan Jones as the current advisor. They consider the reputation, experience and competence of a company's management and board of directors when it evaluates an issuer's proxy. 29  Oldfather Financial Services' complete proxy voting policy, procedures, and those of Egan Jones are available for client review. In addition, our complete proxy voting record is available to our clients and only to our clients. Class Action Suits A class action is a procedural device used in litigation to determine the rights of and remedies, if any, for large numbers of people whose cases involve common questions of law and/or fact. Class action suits frequently arise against companies that publicly issue securities, including securities recommended by investment advisers to clients. Oldfather Financial Services has contracted with Broadridge Investor Communications to file Class Actions "Proof of Claim" forms. Clients may choose not to use this service. Item 18 Financial Information Oldfather Financial Services does not receive fees of more than $1200 six months or more in advance and we do not have any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to any client. We have not been the subject of any bankruptcy proceeding. Therefore, we are not required to provide any additional financial statements under this item. Item 19 Requirements for State-Registered Advisers Requirements for this section do not apply or are covered elsewhere in Form ADV Part 2A and 2B. Item 20 Additional Information Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Class Action Lawsuits We will assist you, in conjunction with your legal counsel or other professionals, in filing claims with the claims administrator to participate in any settlement proceeds related to class action settlements involving a security held in your portfolio. We may also work with your legal counsel to determine whether you are eligible to participate in class action litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held in your portfolio. IRA Rollover Considerations As part of our investment advisory services to you, we may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. 30  Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1. Leaving the funds in your employer's (former employer's) plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may also offer financial advice. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10.Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. 31