OPTAS, LLC

Disclosure Brochure March 28, 2025 Item 1. Cover Page 210 Barton Springs Road, Suite 415 Austin, TX 78704 (888) 284-7139 www.optascapital.com This brochure provides information about the qualifications and business practices of Optas, LLC (hereinafter “Optas” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. 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 the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.  Disclosure Brochure Optas Item 2. Material Changes In this Item, Optas is required to discuss any material changes that have been made to the brochure since the last annual amendment dated March 27, 2024. • Estate Planning descriptions were added into Items 4 and 5. Page | 2  Disclosure Brochure Optas Item 3. Table of Contents Item 1. Cover Page ............................................................................................................................................................................ 1 Item 2. Material Changes ................................................................................................................................................................... 2 Item 3. Table of Contents .................................................................................................................................................................. 3 Item 4. Advisory Business ................................................................................................................................................................. 4 Item 5. Fees and Compensation ......................................................................................................................................................... 8 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................................... 11 Item 7. Types of Clients .................................................................................................................................................................. 11 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................................ 12 Item 9. Disciplinary Information ..................................................................................................................................................... 22 Item 10. Other Financial Industry Activities and Affiliations .......................................................................................................... 22 Item 11. Code of Ethics ................................................................................................................................................................... 23 Item 12. Brokerage Practices ........................................................................................................................................................... 24 Item 13. Review of Accounts .......................................................................................................................................................... 27 Item 14. Client Referrals and Other Compensation ......................................................................................................................... 27 Item 15. Custody ............................................................................................................................................................................. 27 Item 16. Investment Discretion ........................................................................................................................................................ 28 Item 17. Voting Client Securities .................................................................................................................................................... 29 Item 18. Financial Information ........................................................................................................................................................ 29 Page | 3  Disclosure Brochure Optas Item 4. Advisory Business Optas offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Optas rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Optas setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). Optas has been registered as an investment adviser since 2019 and is owned by Frederick M. Glasser Jr. and Meghan Railey. As of December 31, 2024, Optas reports $741,352,124 in discretionary assets under management. While this brochure generally describes the business of Optas, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Optas’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services The Firm provides a variety of standalone financial planning and consulting services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass Investment Planning, Compensation Consulting, Equity Compensation Planning and/or Consulting, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning. While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of the Firm’s Comprehensive Portfolio Management services (described in more detail below). Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. The Firm provides clients with a summary of their financial situation, and observations for financial planning Page | 4  Disclosure Brochure Optas engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. In performing these services, Optas is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Optas recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Optas or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Optas under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Optas’s recommendations and/or services. Investment Management and Comprehensive Portfolio Management Services Optas manages client investment portfolios on a discretionary basis. The Firm can be engaged to provide standalone Investment Management services, as well as Comprehensive Portfolio Management services. The Comprehensive Portfolio Management services include financial planning and consulting services with the Firm conducting client meetings to understand the current financial situation, existing resources, financial goals, and tolerance for risk. Optas primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. The Firm can also recommend other investments, including privately placed securities in more limited circumstances. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Optas to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Optas directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. Page | 5  Disclosure Brochure Optas Optas tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Optas consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Optas if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Optas determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Consulting Services The Firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • • Establishing an Investment Policy Statement – The Firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. Investment Options – The Firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. • • Asset Allocation and Portfolio Construction – The Firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. Investment Monitoring – The Firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – The Firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, the Firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Page | 6  Disclosure Brochure Optas Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and the Firm accepts appointment to provide services to such accounts, the Firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Use of Independent Managers As mentioned above, Optas selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Optas evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Optas also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Optas continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Optas seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Tax Preparation and Filing Services We offer tax preparation and filing services for our Clients to assist with the filing of federal and state tax returns for individuals and businesses. Optas does not provide any investment advice as part of this service. We may ask for an explanation or clarification of some items, but we will not audit or otherwise verify Client data. The Client is responsible for the completeness and accuracy of information used to prepare the returns. Our responsibility is to prepare the returns in accordance with applicable tax laws. Fees associated with this service are disclosed in Item 5 of this brochure. Page | 7  Disclosure Brochure Optas Estate Planning Services We offer Estate Planning services to our Clients. Optas does not provide any investment advice as part of this service. In some circumstances, we refer our Clients to unaffiliated third-party Estate Planning attorneys for Estate Planning services. In other circumstances, Optas utilizes estate planning software to facilitate the document drafts for the Client. Fees associated with this service are disclosed in Item 5 of this brochure. Item 5. Fees and Compensation Optas offers services on a fee basis, which includes fixed and/or hourly fees, as well as fees based upon assets under management. Fees are typically due from clients, but the Firm’s services can be paid for in full or in part by a third-party sponsor if agreed upon in writing between the Firm and the sponsor. In addition to advisory fees, a sponsor may pay a flat non-refundable access fee to the Firm in order to secure access to the advisory services. Sponsors will be directly invoiced by the Firm. Third-party advisory fee billing will be outlined in the advisory agreement between the Firm, the client, and the sponsor. Financial Planning and Consulting Fees The Firm charges on an hourly or fixed fee basis for financial planning and consulting services. The fixed fee, or estimated hourly fee, is based on the scope and complexity of the engagement. The maximum hourly rate to be charged will not exceed $500. Fixed fees are customized based on the specific needs of the client, complexity, estimated time, research, and resources required to provide our services, and other factors we deem relevant. Fees will be due either at the time of engagement, as quarterly progress payments, or upon delivery of a financial plan or completed consultation project. Ongoing relationships are charged periodically as described in the Investment Management section, below. The fee-paying arrangements will be detailed in the signed consulting agreement. Advisory fees paid for by a third-party Sponsor will be directly invoiced to the Sponsor. Investment Management Fees Optas offers Investment Management services for an annual fee based on the amount of assets under the Firm’s management. This management fee will not exceed 1.5% (150 basis points). Page | 8  Disclosure Brochure Optas Optas offers Comprehensive Portfolio Management services for an annual fee based on the amount of assets under the Firm’s management or for a fixed fee. This Comprehensive Portfolio Management fee will not exceed an asset-based fee of 2.00% (200 basis points). Annualized fees are billed on a pro-rata basis quarterly in advance based on the value of the account(s) on the last day of the previous quarter. Accounts opened mid-quarter will be charged on a pro-rata basis according to the value of the account on the date that it is funded. Adjustments will be made for daily deposits and withdrawals that exceed $10,000 in a day during the quarter. Any margin debit will be subtracted from the collateral account(s) balance unless the client authorizes the Firm to bill on the gross value of margin account(s) in a separate signed agreement or acknowledgment. The Firm bills on cash unless otherwise agreed. Retirement Plan Consulting Fees Retirement Plan Consulting services clients are billed a fee based on the percentage of plan assets under management or advisement. The fee is based on the scope and complexity of the engagement. Fees based on a percentage of managed Plan assets will not exceed 1.00% (100 basis points). The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. Tax Preparation and Filing Fees Tax preparation and filing fees are separate and in addition to advisory or planning fees charged by Optas. At times, Optas may waive these separate fees on a client-by-client basis. Estate Planning Fees Estate Planning fees are separate and in addition to advisory or planning fees charged by Optas. At times, Optas may waive these separate fees on a client-by-client basis. When the Client engages with an unaffiliated, third-party attorney, fees are paid by the Client directly to the attorney. Fee Discretion Optas will, at its sole discretion, determine fees based upon certain client criteria, such as anticipated client earning capacity, anticipated client assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship(s), account retention, pro bono activities, or competitive purposes. Page | 9  Disclosure Brochure Optas Additional Fees and Expenses Independent Manager fees will vary based upon the program offering of the chosen Independent Manager. The fee to be charged will be disclosed in a separate advisory agreement signed by the client, either between the client and the Independent Manager or between the client and Optas. The Independent Manager’s fee billing practices will be detailed in their disclosure brochure provided to the client. In addition to the advisory fees paid to Optas, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include transaction fees for trades executed by their chosen custodian, either based on a percentage of the dollar amount of assets in the account(s) or via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the chosen custodian. Clients may also pay holdings charges imposed by the chosen custodian for certain investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses), mutual fund sales loads, 12b-1 fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark- ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. The Firm does not receive any portion of these fees. Direct Fee Debit Clients provide Optas and Independent Managers with the authority to directly debit their accounts for payment of investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Optas. In rare cases, the Firm will agree to directly invoice clients. Advisory fees paid for by a third-party Sponsor will be directly invoiced to the Sponsor. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account Page | 10  Disclosure Brochure Optas assets on notice to Optas, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. Optas may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Termination Either party may terminate an Asset Management and/or Comprehensive Portfolio Management Agreement by providing written notice to the other party. Upon notice of termination, the Firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance. Financial Planning & Consulting clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice to the Firm. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by the Firm. Either party to a Retirement Plan Consulting Agreement may terminate at any time by providing written notice to the other party. Full refunds will only be made in cases where cancellation occurs within five (5) business days of signing an agreement. After five (5) business days from initial signing, either party must provide the other party 30 days written notice to terminate billing. Billing will terminate thirty (30) days after receipt of termination notice. Clients will be charged on a pro-rata basis, which takes into account work completed by the Firm on behalf of the client. Clients will incur charges for bona fide advisory services rendered up to the point of termination (determined as thirty (30) days from receipt of said written notice) and such fees will be due and payable. Item 6. Performance-Based Fees and Side-by-Side Management Optas does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients Optas offers services to individuals, high net worth individuals, trusts, estates, charitable organizations, corporations and other business entities, and pension and profit sharing plans. Page | 11  Disclosure Brochure Optas Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Optas uses the following methods of analysis in formulating investment advice and/or managing client assets: Charting: In this type of technical analysis, the Firm reviews charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Cyclical Analysis: Statistical analysis of specific events occurring at a sufficient number of relatively predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical forces drive price movements in the financial markets. Risks include that cycles may invert or disappear and there is no expectation that this type of analysis will pinpoint turning points, instead be used in conjunction with other methods of analysis. Duration Constraints: The Firm adheres to a discipline of generally maintaining duration within a narrow band around benchmark duration in order to limit exposure to market risk. The portfolio management team rebalances client portfolios to their current duration targets on a periodic basis. The risk of constraining duration is that the client may not participate fully in a large rally in bond prices. Fundamental Analysis: The analysis of a business's financial statements (usually to analyze the business's assets, liabilities, and earnings), health, and its competitors and markets. When analyzing a stock, futures contract, or currency using fundamental analysis there are two basic approaches one can use: bottom up analysis and top down analysis. The terms are used to distinguish such analysis from other types of investment analysis, such as quantitative and technical. Fundamental analysis is performed on historical and present data, but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company stock valuation and predict its probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic value of the share. When the objective of the analysis is to determine what stock to buy and at what price, there are two basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all information is reflected already in the price of a security. Technical analysts analyze trends and Page | 12  Disclosure Brochure Optas believe that sentiment changes predate and predict trend changes. Investors' emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also analyze historical trends to predict future price movement. Investors can use one or both of these different but complementary methods for stock picking. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Qualitative Analysis: A securities analysis that uses subjective judgment based on unquantifiable information, such as management expertise, industry cycles, strength of research and development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on numbers that can be found on reports such as balance sheets. The two techniques, however, will often be used together in order to examine a company's operations and evaluate its potential as an investment opportunity. Qualitative analysis deals with intangible, inexact concerns that belong to the social and experiential realm rather than the mathematical one. This approach depends on the kind of intelligence that machines (currently) lack, since things like positive associations with a brand, management trustworthiness, customer satisfaction, competitive advantage and cultural shifts are difficult, arguably impossible, to capture with numerical inputs. A risk in using qualitative analysis is that subjective judgment may prove incorrect. Quantitative Analysis: The use of models, or algorithms, to evaluate assets for investment. The process usually consists of searching vast databases for patterns, such as correlations among liquid assets or price- movement patterns (trend following or mean reversion). The resulting strategies may involve high- frequency trading. The results of the analysis are taken into consideration in the decision to buy or sell securities and in the management of portfolio characteristics. A risk in using quantitative analysis is that the methods or models used may be based on assumptions that prove to be incorrect. Sector Analysis: Sector analysis involves identification and analysis of various industries or economic sectors that are likely to exhibit superior performance. Academic studies indicate that the health of a stock's sector is as important as the performance of the individual stock itself. In other words, even the best stock located in a weak sector will often perform poorly because that sector is out of favor. Each industry has differences in terms of its customer base, market share among firms, industry growth, competition, regulation and business cycles. Learning how the industry operates provides a deeper understanding of a company's financial health. One method of analyzing a company's growth potential is examining whether the amount of customers in the overall market is expected to grow. In some markets, there is zero or negative growth, a factor demanding careful consideration. Additionally, market analysts recommend that investors should monitor sectors that are nearing the bottom of performance rankings for possible signs of an impending turnaround. Page | 13  Disclosure Brochure Optas Technical Analysis: A security analysis methodology for forecasting the direction of prices through the study of past market data, primarily price and volume. A fundamental principle of technical analysis is that a market's price reflects all relevant information, so their analysis looks at the history of a security's trading pattern rather than external drivers such as economic, fundamental and news events. Therefore, price action tends to repeat itself due to investors collectively tending toward patterned behavior – hence technical analysis focuses on identifiable trends and conditions. Technical analysts also widely use market indicators of many sorts, some of which are mathematical transformations of price, often including up and down volume, advance/decline data and other inputs. These indicators are used to help assess whether an asset is trending, and if it is, the probability of its direction and of continuation. Technicians also look for relationships between price/volume indices and market indicators. Technical analysis employs models and trading rules based on price and volume transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of chart patterns. Technical analysis is widely used among traders and financial professionals and is very often used by active day traders, market makers and pit traders. The risk associated with this type of analysis is that analysts use subjective judgment to decide which pattern(s) a particular instrument reflects at a given time and what the interpretation of that pattern should be. Investment Strategies Optas uses the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Asset Allocation: The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each asset in an investment portfolio according to the investor's risk tolerance, goals and investment time frame. Asset allocation is based on the principle that different assets perform differently in different market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for return are often derived in the same way. An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value, dividend, growth, or sector-specific [or a Page | 14  Disclosure Brochure Optas "blend" of any two or more of the preceding]; large-cap versus mid-cap, small-cap or micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally: investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-term; domestic, foreign, emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks. Other alternative assets that may be considered include: commodities: precious metals, nonferrous metals, agriculture, energy, others.; Commercial or residential real estate (also REITs); Collectibles such as art, coins, or stamps; insurance products (annuity, life settlements, catastrophe bonds, personal life insurance products, etc.); derivatives such as long-short or market neutral strategies, options, collateralized debt, and futures; foreign currency; venture capital; private equity; distressed securities; and/or digital assets including, but not limited to, so-called “virtual currencies”, “coins”, “tokens” and public or private funds investing in digital assets. There are several types of asset allocation strategies based on investment goals, risk tolerance, time frames and diversification. The most common forms of asset allocation are: strategic, dynamic, tactical, and core- satellite. • Strategic Asset Allocation: The primary goal of a strategic asset allocation is to create an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Generally speaking, strategic asset allocation strategies are agnostic to economic environments, i.e., they do not change their allocation postures relative to changing market or economic conditions. • Dynamic Asset Allocation: Dynamic asset allocation is similar to strategic asset allocation in that portfolios are built by allocating to an asset mix that seeks to provide the optimal balance between expected risk and return for a long-term investment horizon. Like strategic allocation strategies, dynamic strategies largely retain exposure to their original asset classes; however, unlike strategic strategies, dynamic asset allocation portfolios will adjust their postures over time relative to changes in the economic environment. • Tactical Asset Allocation: Tactical asset allocation is a strategy in which an investor takes a more active approach that tries to position a portfolio into those assets, sectors, or individual stocks that show the most potential for perceived gains. While an original asset mix is formulated much like strategic and dynamic portfolio, tactical strategies are often traded more actively and are free to move entirely in and out of their core asset classes Page | 15  Disclosure Brochure Optas • Core-Satellite Asset Allocation: Core-Satellite allocation strategies generally contain a 'core' strategic element making up the most significant portion of the portfolio, while applying a dynamic or tactical 'satellite' strategy that makes up a smaller part of the portfolio. In this way, core-satellite allocation strategies are a hybrid of the strategic and dynamic/tactical allocation strategies mentioned above. Fixed Income: Fixed income is a type of investing or budgeting style for which real return rates or periodic income is received at regular intervals and at reasonably predictable levels. Fixed-income investors are typically retired individuals who rely on their investments to provide a regular, stable income stream. This demographic tends to invest heavily in fixed-income investments because of the reliable returns they offer. Fixed-income investors who live on set amounts of periodically paid income face the risk of inflation eroding their spending power. Some examples of fixed-income investments include treasuries, money market instruments, corporate bonds, asset-backed securities, municipal bonds and international bonds. The primary risk associated with fixed-income investments is the borrower defaulting on his payment. Other considerations include exchange rate risk for international bonds and interest rate risk for longer- dated securities. The most common type of fixed-income security is a bond. Bonds are issued by federal governments, local municipalities and major corporations. Fixed-income securities are recommended for investors seeking a diverse portfolio; however, the percentage of the portfolio dedicated to fixed income depends on your own personal investment style. There is also an opportunity to diversify the fixed-income component of a portfolio. Riskier fixed-income products, such as junk bonds and longer-dated products, should comprise a lower percentage of your overall portfolio. The interest payment on fixed-income securities is considered regular income and is determined based on the creditworthiness of the borrower and current market rates. In general, bonds and fixed- income securities with longer-dated maturities pay a higher rate, also referred to as the coupon rate, because they are considered riskier. The longer the security is on the market, the more time it has to lose its value and/or default. At the end of the bond term, or at bond maturity, the borrower returns the amount borrowed, also referred to as the principal or par value. Long-Term Purchases: The Firm may buy securities for client accounts and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that the Firm could miss out on potential short-term gains that could have been profitable to the client’s account, or it’s possible that the security’s value may decline sharply before the Firm makes a decision to sell. Margin Transactions: The Firm may purchase stocks, mutual funds, and/or other securities for client portfolios with money borrowed from that client’s brokerage account. This allows clients to Page | 16  Disclosure Brochure Optas purchase more stock than they would be able to with their available cash, and allows the Firm to purchase stock without selling other holdings. In practice, the Firm typically utilizes margin loans for outside liquidity. Margin accounts, transactions, and loans are risky and not necessarily appropriate for every client. The potential risks associated with these transactions are: (i) a client can lose more funds than are deposited into the margin account; (ii) the forced sale of securities or other assets in the client’s account; (iii) the sale of securities or other assets without contacting the client; and (iv) the client may not be entitled to choose which securities or other assets in their account(s) are liquidated or sold to meet a margin call. Pursuant to the execution of a signed agreement or acknowledgment form, the Firm may bill on the gross value of the client’s portfolio that includes margin positions. Billing on the gross value of a margin account presents a conflict of interest because the Firm would receive more compensation than if it billed on the net value of a margin account. In order to help mitigate this conflict of interest, the Firm notifies clients of the conflict, discusses the specific risks associated with margin transactions, and requires clients to sign a separate agreement or acknowledgment form authorizing the billing arrangement. In addition, the Firm will only bill on the gross value of a margin account for clients who meet the definition of an accredited or qualifying investor. Options: An option is a financial derivative that represents a contract sold by one party (the option writer) to another party (the option holder, or option buyer). The contract offers the buyer the right, but not the obligation, to buy or sell a security or other financial asset at an agreed-upon price (the strike price) during a certain period of time or on a specific date (exercise date). Options are extremely versatile securities. Traders use options to speculate, which is a relatively risky practice, while hedgers use options to reduce the risk of holding an asset. In terms of speculation, option buyers and writers have conflicting views regarding the outlook on the performance of a: • Call Option: Call options give the option to buy at certain price, so the buyer would want the stock to go up. Conversely, the option writer needs to provide the underlying shares in the event that the stock's market price exceeds the strike due to the contractual obligation. An option writer who sells a call option believes that the underlying stock's price will drop relative to the option's strike price during the life of the option, as that is how he will reap maximum profit. This is exactly the opposite outlook of the option buyer. The buyer believes that the underlying stock will rise; if this happens, the buyer will be able to acquire the stock for a lower price and then sell it for a profit. However, if the underlying stock does not close above the strike price on the expiration date, the option buyer would lose the premium paid for the call option. • Put Option: Put options give the option to sell at a certain price, so the buyer would want the stock to go down. The opposite is true for put option writers. For example, a put option buyer is bearish on the underlying stock and believes its market price will fall below the Page | 17  Disclosure Brochure Optas specified strike price on or before a specified date. On the other hand, an option writer who sells a put option believes the underlying stock's price will increase about a specified price on or before the expiration date. If the underlying stock's price closes above the specified strike price on the expiration date, the put option writer's maximum profit is achieved. Conversely, a put option holder would only benefit from a fall in the underlying stock's price below the strike price. If the underlying stock's price falls below the strike price, the put option writer is obligated to purchase shares of the underlying stock at the strike price. The potential risks associated with these transactions are that: (i) all options expire (the closer the option gets to expiration, the quicker the premium in the option deteriorates); and (ii) prices can move very quickly (depending on factors such as time until expiration and the relationship of the stock price to the option’s strike price, small movements in a stock can translate into big movements in the underlying options). Short Sales: A short sale is a transaction in which an investor sells borrowed securities in anticipation of a price decline and is required to return an equal number of shares at some point in the future. These transactions have a number of risks that make it highly unsuitable for the novice investor. This strategy has a slanted payoff ratio in that the maximum gain (which would occur if the shorted stock was to plunge to zero) is limited, but the maximum loss is theoretically infinite (since stocks can in theory go up infinitely in price). The following risks should be considered: • In addition to trading commissions paid to the broker-dealer, other costs with short selling include that of borrowing the security to short it, as well as interest payable on the margin account that holds the shorted security. • The short seller is responsible for making dividend payments on the shorted stock to the entity from whom the stock has been borrowed. • Stocks with very high short interest may occasionally surge in price. This usually happens when there is a positive development in the stock, which forces short sellers to buy the shares back to close their short positions. Heavily shorted stocks are also susceptible to “buy-ins,” which occur when a broker closes out short positions in a difficult-to-borrow stock whose lenders are demanding it back. • Regulators may impose bans on short sales in a specific sector or even in the broad market to avoid panic and unwarranted selling pressure. Such actions can cause a spike in stock prices, forcing the short seller to cover short positions at huge losses. • Unlike the “buy-and-hold” investor who can afford to wait for an investment to work out, the short seller does not have the luxury of time because of the many costs and risks associated with short selling. Timing is everything when it comes to shorting. Page | 18  Disclosure Brochure Optas • Short selling should only be undertaken by experienced traders who have the discipline to cut a losing short position, rather than add to it hoping that it will eventually work out. Short-Term Purchases: When utilizing this strategy, the Firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). The Firm does this in an attempt to take advantage of conditions that the Firm believes will soon result in a price swing in the securities the Firm purchases. Third-Party Money Manager Analysis: The analysis of the experience, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. Analysis is completed by monitoring the manager’s underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of the due-diligence process, the manager’s compliance and business enterprise risks are surveyed and reviewed. A risk of investing with a third-party manager who has been successful in the past is that they may not be able to replicate that success in the future. In addition, as our firm does not control the underlying investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as the Firm does not control the manager’s daily business and compliance operations, the Firm may be unaware of the lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. Digital Asset Securities: The term “digital asset” refers to an asset that is issued and/or transferred using distributed ledger or blockchain technology, including, but not limited to, so-called “virtual currencies”, “coins”, and “tokens”. Risks related to digital asset trading venues and execution or settlement facilities may include security breaches, fraud, insolvency, market manipulation, and quality of market surveillance. The complexity of the products and technology underlying digital assets pose potential risks including technical, legal, market, and operational risks, price volatility, illiquidity, valuation methodology, related- party transactions, and conflicts of interest. Risk of Loss Certain risks were discussed above when describing the investment strategies used by the Firm. The following list of additional risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Page | 19  Disclosure Brochure Optas Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Optas’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that Optas will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper and/or government backed debt instruments. Ultimately, the Firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that the Firm may debit advisory fees for services. Equity-Related Securities and Instruments The Firm may take long and short positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Page | 20  Disclosure Brochure Optas Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund- level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are taken if the investor sells their position before a certain amount of time. Use of Private Collective Investment Vehicles Optas recommends that certain clients invest in privately placed securities, including collective investment vehicles (e.g., private funds, hedge funds, etc.). This will include Qualified Opportunity Zone funds. The managers of these vehicles have broad discretion in selecting the investments. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and/or other documents explaining such risks prior to investing. Page | 21  Disclosure Brochure Optas Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Inflation Risk Inflation risk involves the concern that in the future, investments or proceeds from investments will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Liquidity Risk Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, clients may experience the risk that their investment or assets within their investment may not be able to be liquidated quickly, thus, extending the period of time by which they may receive the proceeds from their investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Item 9. Disciplinary Information Optas has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. Licensed Insurance Agents Frederick M Glasser Jr is a licensed insurance agent for record keeping purposes. He does not accept any compensation or commissions from insurance products or sales. Page | 22  Disclosure Brochure Optas Item 11. Code of Ethics Optas has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Optas’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non- public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of Optas’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Optas to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure. Page | 23  Disclosure Brochure Optas Item 12. Brokerage Practices Factors Used to Select Custodians Optas does not have any affiliation with any custodian we recommend. Specific custodian recommendations are made to the Client based on their need for such services. We recommend custodians based on the reputation and services provided by the firm. In recommending custodians, we have an obligation to seek the “best execution” of transactions in Client accounts. The determinative factor in the analysis of best execution is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the custodian’s services. The factors we consider when evaluating a custodian for best execution include, without limitation, the custodian’s: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody); • Capability to execute, clear, and settle trades (buy and sell securities for your account); • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.); • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.); • Availability of investment research and tools that assist us in making investment decisions; • Quality of services; • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices; • Reputation, financial strength, security and stability; • Prior service to us and our clients. With this in consideration, our firm recommends National Financial Services, LLC, and Fidelity Brokerage Services, LLC (together with all affiliates, “Fidelity”) and Charles Schwab & Co., Inc (“Schwab”), independent and unaffiliated SEC registered broker-dealer firms and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). Research and Other Soft-Dollar Benefits We do not have any soft-dollar arrangements with custodians whereby soft-dollar credits, used to purchase products and services, are earned directly in proportion to the amount of commissions paid by a Client. However, as a result of being on their institutional platform, Fidelity and Schwab provide us with certain services that benefit us. Page | 24  Disclosure Brochure Optas The Custodians and Brokers We Use (Fidelity and Schwab) Optas has an arrangement with National Financial Services, LLC, and Fidelity Brokerage Services, LLC (together with all affiliates, “Fidelity”) through which Fidelity provides Optas with their “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like Optas in conducting business and in serving the best interests of their clients, but that may benefit Optas. Optas has an arrangement with Schwab Advisor Services through which Schwab provides Optas with their “platform” services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like Optas in conducting business and in serving the best interests of their clients, but that may benefit Optas. Fidelity’s and Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The benefits received by the Advisor or its personnel do not depend on the number of brokerage transactions directed to Fidelity or Schwab. As part of its fiduciary duties to Clients, Optas at all times must put the interests of its Clients first. Clients should be aware, however, that the receipt of Custodian benefits by the Advisor or its related persons in and of itself creates a potential conflict of interest and may indirectly influence the Advisor’s choice of Fidelity or Schwab for custody and brokerage services. This conflict of interest is mitigated as the Advisor regularly reviews the factors used to select custodians to ensure our recommendation is appropriate. Following is a more detailed description of Fidelity and Schwab’s support services: 1. SERVICES THAT BENEFIT YOU. Fidelity and Schwab provide access to a range of investment products, execution of securities transactions, and custody of client assets through affiliated Broker Dealers. Also, Fidelity and Schwab provide discount brokerage rates that are may be lower than retail investor rates. Fidelity or Schwab services described in this paragraph generally benefit you and your account. 2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Fidelity and Schwab also make available to us other products and services that benefit us, but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts, such as software and technology that may: • Assist with back-office functions, recordkeeping, and client reporting of our clients’ accounts. • Provide access to client account data (such as duplicate trade confirmations and account statements). Investment research. • Provide pricing and other market data. • Assist with back-office functions, recordkeeping, and client reporting. • • Access to Fidelity’s or Schwab’s trading desk for Advisors. Page | 25  Disclosure Brochure Optas • Access to block trading. 3. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Fidelity or Schwab, we will be offered other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events. • Consulting on technology, compliance, legal, and business needs. • Publications and conferences on practice management and business succession. • Vendor discounts to purchase business services, such as consulting, marketing and branding, technology support and other similar business services. YOUR BROKERAGE AND CUSTODY COSTS. Fidelity and Schwab may charge brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity and Schwab enable Optas to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Brokerage for Client Referrals Optas does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Special Considerations for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, Optas will request that plan sponsors who direct plan brokerage provide the Firm with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Directed Brokerage The client may direct Optas in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Optas (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or Page | 26  Disclosure Brochure Optas may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Optas may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Trade Aggregation Transactions for each client will be effected independently, unless Optas decides to purchase or sell the same securities for several clients at approximately the same time. Optas may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among Optas’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Optas’s Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Optas does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Page | 27  Disclosure Brochure Optas Item 13. Review of Accounts The Firm’s personnel or financial advisors review accounts on at least an annual basis for Asset Management, Comprehensive Portfolio Management, and Independent Manager clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Optas does not provide written reports to clients, unless requested. Verbal reports to clients take place on at least an annual basis when the Asset Management, Comprehensive Portfolio Management, and Independent Manager clients are contacted. Optas can review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. Financial Planning clients will receive reviews of their written plans according to the agreed upon schedule during the financial planning process. Any updates to the plans/reports will occur upon this same agreed schedule or upon request of the client. Item 14. Client Referrals and Other Compensation The Firm does not currently provide compensation to any third-party solicitors for client referrals. The Firm receives support from Fidelity and Schwab. The support, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody Optas is deemed to have limited custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. Surprise Independent Examination Optas may serve as trustee for client trusts, manage limited liability companies for clients (but not act as managing member), or perform bill paying services. These services result in the Firm having Page | 28  Disclosure Brochure Optas custody over the client’s cash, bank accounts or securities. As such, the Firm is required to engage an independent accounting Firm to perform a surprise annual examination of those assets and accounts over which it maintains custody. Any related opinions issued by an independent accounting Firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website. Optas does not have direct access to client funds as they are maintained with an independent qualified custodian. Standing Letters of Authorization Optas also has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16. Investment Discretion Optas is given the authority to exercise discretion on behalf of clients. Optas is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. Optas is given this authority through a power- of-attorney included in the agreement between Optas and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Optas takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or terminated. Page | 29  Disclosure Brochure Optas Item 17. Voting Client Securities Optas does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Independent Managers selected by the Firm will sometimes vote proxies on behalf of clients. Item 18. Financial Information Optas is not required to disclose any financial information listed in the instructions to Item 18 because: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 30