Overview

Assets Under Management: $282 million
Headquarters: HOUSTON, TX
High-Net-Worth Clients: 59
Average Client Assets: $4 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $500,000 1.50%
$500,001 $2,500,000 1.25%
$2,500,001 $5,000,000 1.00%
$5,000,001 and above 0.85%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,750 1.38%
$5 million $57,500 1.15%
$10 million $100,000 1.00%
$50 million $440,000 0.88%
$100 million $865,000 0.86%

Clients

Number of High-Net-Worth Clients: 59
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 77.99
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 679
Discretionary Accounts: 679

Regulatory Filings

CRD Number: 159293
Last Filing Date: 2025-02-04 00:00:00
Website: https://postoakprivatewealth.com

Form ADV Documents

Additional Brochure: ADV PART 2A (2025-10-01)

View Document Text
F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Office Address: 1200 Smith St., Suite 610 Houston, TX 77002 Phone: (281) 580-2100 Website: www.postoakprivatewealth.com Email: rwyrick@postoakprivatewealth.com October 1, 2025 This brochure provides information about the qualifications and business practices of Post Oak Private Wealth Advisors . Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at (281) 580-2100. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. A D D I T I O N A L I N F O R M A T I O N A B O U T P O S T O A K P R I V A T E W E A L T H A D V I S O R S ( C R D # 1 5 9 2 9 3 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V i Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update This update is in accordance with the required annual update for Registered Investment Advisors. Since the last update on February 4, 2025, the following changes have occurred:  We no longer offer estate planning assistance services through Wealth.com. All references to this service have been removed from this ADV.  We are now wholly owned by Post Oak Private Wealth Holdings, LLC.  We now also offer Fidelity Brokerage Services as an approved custodian.  As part of our discretionary management services, we now also offer Multi-Asset Class Portfolios. Additional information about the fees and services can be found in Item 4 & Item 5 below. This Firm Brochure being delivered is the complete brochure for the Firm. ii Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Firm Description ............................................................................................................................................................... 1 Types of Advisory Services ........................................................................................................................................... 1 Client Tailored Services and Client Imposed Restrictions ............................................................................... 3 Wrap Fee Programs ......................................................................................................................................................... 3 Client Assets under Management .............................................................................................................................. 3 Item 5: Fees and Compensation ....................................................................................................... 3 Method of Compensation and Fee Schedule .......................................................................................................... 3 Client Payment of Fees ................................................................................................................................................... 6 Additional Client Fees Charged ................................................................................................................................... 6 Prepayment of Client Fees ............................................................................................................................................ 6 External Compensation for the Sale of Securities to Clients ........................................................................... 6 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 6 Sharing of Capital Gains ................................................................................................................................................. 6 Item 7: Types of Clients ....................................................................................................................... 7 Description .......................................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7 Methods of Analysis ......................................................................................................................................................... 7 Investment Strategy ........................................................................................................................................................ 7 Security Specific Material Risks .................................................................................................................................. 7 Item 9: Disciplinary Information ..................................................................................................... 9 Criminal or Civil Actions ................................................................................................................................................ 9 Administrative Enforcement Proceedings ............................................................................................................. 9 Self- Regulatory Organization Enforcement Proceedings ............................................................................... 9 Item 10: Other Financial Industry Activities and Affiliations ............................................... 9 Broker-Dealer or Representative Registration .................................................................................................... 9 iii Futures or Commodity Registration ......................................................................................................................... 9 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 9 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 10 Code of Ethics Description ......................................................................................................................................... 10 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 10 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 10 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 11 Item 12: Brokerage Practices ......................................................................................................... 11 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 11 Aggregating Securities Transactions for Client Accounts ............................................................................. 12 Item 13: Review of Accounts ........................................................................................................... 12 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 12 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 12 Content of Client Provided Reports and Frequency ........................................................................................ 12 Item 14: Client Referrals and Other Compensation ................................................................ 13 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 13 Advisory Firm Payments for Client Referrals .................................................................................................... 13 Item 15: Custody .................................................................................................................................. 13 Account Statements ...................................................................................................................................................... 13 Item 16: Investment Discretion ..................................................................................................... 13 Discretionary Authority for Trading...................................................................................................................... 13 Item 17: Voting Client Securities ................................................................................................... 14 Proxy Votes ...................................................................................................................................................................... 14 Item 18: Financial Information ...................................................................................................... 14 Balance Sheet .................................................................................................................................................................. 14 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 14 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 14 iv Item 4: Advisory Business Firm Description RMW Advisors, LLC dba Post Oak Private Wealth Advisors (“we”, “us”) is a Texas limited liability company formed in October 2011. It was subsequently registered as a Texas investment adviser. In July 2019, the firm was registered with the SEC. Post Oake Private Wealth Holdings, LLC is the sole (100%) owner of the RMW Advisors, LLC dba Post Oak Private Wealth Advisors. Robert Wyrick continues to serve as managing member through LegacyCo. Types of Advisory Services PORTFOLIO MANAGEMENT We offer discretionary and non-discretionary management on individualized portfolios for our clients. We work with each client to formulate an individualized portfolio based upon his/her objectives, time frame, risk parameters and other investment considerations. We use marketable securities that may include bonds, common stock (equities), options and treasury bonds. (Additional information about securities used their risks can be found under Item 8.) Our investment philosophy is to use principals of value, safety and quality to seek investment options globally. We place heavy emphasis on risk control, believing that avoiding losses allows appreciation potential of equities to be realized. Discretionary When the Client provides us discretionary authority the Client will sign a limited trading authorization or equivalent. We will have the authority to execute transactions in the account without seeking Client approval on each transaction. Non-Discretionary When the Client elects to use us on a non-discretionary basis, we will determine the securities to be bought or sold and the amount of the securities to be bought or sold. However, we will obtain prior Client approval on each and every transaction before executing any transaction.Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Multi-Asset Class Portfolios Some advisors with Post Oak Private Wealth Advisors may offer multi-asset class portfolios. These portfolios are comprised of ETFs and mutual fund holdings and are approved through our proprietary research. While each individual investment is analyzed on a stand-alone basis, we view risk for the multi-asset class portfolios on a portfolio level and assess each investment's risk in that context as client portfolios are constructed. Client portfolios may deviate considerably from our neutral strategic position as we seek to capture opportunities and reduce risk arising from asset class mispricing. Proprietary due diligence is conducted on every fund used in client portfolios. The process begins with a quantitative assessment of performance and consistency criteria, including past relative and absolute investment returns, style drift, drawdowns and volatility. Qualitative screening begins with a preliminary assessment of the management team, its strategy, investment philosophy and process, the repeatability of investment approach, risk management and operations. - 1 - Once a manager is added to our approved list, we institute a regular monitoring process which includes telephone calls, site visits, review of positioning and continued performance analysis. The resulting portfolios reflect our global view, our manager research process, and the investment objectives and risk tolerance of the client. Client portfolios are carefully monitored and adjusted as we alter our view based on changing market conditions. SEI Managed Accounts Solutions Post Oak Private Wealth Advisors offers discretionary management services through a program sponsored by SEI Investments Management Corp (SIMC). SIMC has developed a standard managed account solutions (“MAS”), which program includes SEI’s distribution focused strategies, an integrated managed account solutions providing a tax overlay service (“Tax Management”) and a Goals Based Investing managed account solutions, consisting of MAS and Tax Management portfolios invested in accordance with SEI’s goals-based investment solutions and, may, in the future, develop additional managed account solutions (collectively, the “Managed Account Solutions”). Under this program, SIMC acts as a co- investment advisor to the Investor, along with Post Oak Private Wealth Advisors, pursuant to a tri-party investment management agreement executed among SIMC, Post Oak Private Wealth Advisors and each Investor investing assets into the Managed Account Solutions (the “Tri-party Agreement”). For each Managed Account Solutions, SIMC is responsible for developing managed account portfolios designed to be invested in accordance with a stated investment objective (the “Managed Account Portfolios”). For each Managed Account Portfolio, other than the Managed Account Portfolios implementing distribution-focused strategies (the “DFS Portfolios”), SIMC is solely responsible for screening, reviewing and selecting the various money managers and/or individual mutual funds and Other Assets available for selection by Advisors and their Investors designed to meet the specific Managed Account Portfolio’s stated investment objective or goal. For each DFS Portfolio, SIMC is responsible for selecting the SEI Funds and/or Other Assets underlying each DFS Portfolio and actively managing each Investor Account invested in a DFS Portfolio in accordance with the portfolio’s investment objectives. SEI Mutual Fund Models Program and SEI Funds Post Oak Private Wealth Advisors offers discretionary management services through a program sponsored by SEI Investments Management Corp (SIMC). SIMC has developed various model mutual fund asset allocation portfolios (the "Mutual Fund Models") designed to be invested in accordance with a stated investment objective or goal (the "Mutual Fund Models Program"). SIMC currently develops its Mutual Fund Models through two underlying programs, described in various SEI literature as either SEI's Institutional Mutual Fund models or SEI's Goals Based Investing models and, may in the future, develop additional mutual fund model programs. Each Mutual Fund Model's underlying portfolio allocation is generally comprised exclusively of mutual funds in the SEI family of funds ("SEI Funds"), which are each advised by SIMC. Pursuant to the Mutual Fund Models Program, SEI will make available its various Mutual Fund Models to Post Oak Private Wealth Advisors who, in turn, may assist Investors in determining into which Mutual Fund Models to invest their assets. - 2 - FINANCIAL PLANNING Financial Planning services typically focus on one or more specific areas such as financial and cash management, risk management, financial issues relating to divorce or death of a family member, insurance planning, estate planning, tax issues, retirement planning, educational funding, goal setting, or other needs identified by the client or by our review of the client’s financial circumstances. Through discussion with the client and/or questionnaires, we will collect pertinent data; identify goals, objectives, financial concerns and potential solutions. We will present the client with a written analysis. Following the conclusion of the consulting services, we may make recommendations regarding implementation of the financial strategies discussed. Clients are not obligated to follow any recommendations we may make or to implement any recommendations through us. SEMINARS AND WORKSHOPS Post Oak Private Wealth Advisors holds seminars and workshops to educate the public on different types of investments and the different services they offer. The seminars are educational in nature and no specific investment or tax advice is given. Client Tailored Services and Client Imposed Restrictions Our services are individualized to each client. However, we generally do not allow clients to place restrictions on the types of securities held in their accounts. Wrap Fee Programs Post Oak Private Wealth Advisors does not sponsor any wrap fee programs. Client Assets under Management As of December 31, 2024, we manage $282,025,465 in client assets on a discretionary basis and $0 on a non-discretionary basis. Item 5: Fees and Compensation Method of Compensation and Fee Schedule PORTFOLIO MANAGEMENT SERVICES Post Oak Private Wealth Advisors offers direct asset management services to advisory Clients. Standard Fee Schedule: Post Oak Private Wealth Advisors charges an annual investment advisory fee based on the total assets under management as follows: Custodian Reported Value of Account Management Fee Up to $500,000 $500,000 to $ 2,500,000 $2,500,000 to $5,000,000 $5,000,000 + 1.50% 1.25% 1.00% 0.85% Your management fee is negotiable based on account size, services offered and individual client circumstances. The management fee is calculated and collected monthly in arrears. At the conclusion of the last day of each month, we download the value of your account from its custodian. We use this value to calculate our management fee, based on the annual rate, divided by 365 and then multiplied by the number of days in the month We then debit our management fee from your account. - 3 - Multi-Asset Class Portfolios Post Oak Private Wealth Advisors offers a tiered fee schedule for clients whose assets are in a multi-asset class portfolio. Custodian Reported Value of Account Management Fee On the first $1,000,000 On the next $4,000,000 On the next $5,000,000 Amounts over $10,000,000 1.00% 0.75% 0.55% 0.35% The annual management fee is a tiered fee. A tiered fee means the applicable rate will be applied to the balance on the last day of the billing period in each applicable range of account value and based on the number of days in that given month. For example, an account with a month end value of $1,300,000 will be charged 1.00% annually on the first $1,000,000 and 0.75% annually on the next $300,000. The management fee is exclusive of brokerage commissions, transaction fees, and other related costs and expenses that are incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our management fee and we do not receive any portion of these commissions, fees, and costs. For more information about our recommended brokerage practice please see Item 12.A. A client may terminate the Investment Management Agreement for any reason at any time and, within the first five (5) business days after signing the contract, without any cost or penalty. Thereafter, the contract may be terminated at any time by giving ten (10) days written notice. Upon termination, fees will be prorated for the number of days that services were rendered on the Account’s valuation as of the termination date. The written notice of termination must be sent to Post Oak Private Wealth Advisors, 1200 Smith St., Suite 610, Houston, TX 77002. Upon our receipt of written notice of termination, the client will be charged a prorated amount of the management fee based on the number of days services were provided during the termination month. For example, if there are 30 days in a month and the service was cancelled 15 days into the month, the client will be charge 50% of the monthly management fee. (15 divided by 30 equals 50%) SEI Managed Account Solutions For the SEI Managed Account Solutions program Post Oak Private Wealth Advisors charges an annual investment advisory fee based on the total assets under management as follows: Assets Under Management Up to $1,000,000 $1,000,001 to $2,000,000 $2,000,001 to $3,000,000 $3,000,001 to $4,000,000 $4,000,001 to $5,000,000 Over $5,000,000 Post Oak Private Wealth Advisors Annual Fee 1.00% 0.90% 0.80% 0.70% 0.60% 0.50% Post Oak Private Wealth Advisors Quarterly Fee 0.250% 0.225% 0.200% 0.175% 0.150% 0.125% The annual fee may be negotiable. - 4 - Post Oak Private Wealth Advisors receives compensation as a result of a Client’s participation in SIMC’s programs. For assisting Clients in selecting appropriate Mutual Fund Models, Managed Account Portfolios or Custom Portfolios in accordance with the terms of Post Oak Private Wealth Advisor’s advisory agreement and, if applicable Triparty Agreement, with such Clients and providing on-going account services, Post Oak Private Wealth Advisors will receive a fee payable from the Client’s Account assets. Post Oak Private Wealth Advisor’s fee will be calculated quarterly on the Client’s Account balance and payable quarterly in arrears net of any income, withholding or other taxes. Post Oak Private Wealth Advisor’s fee is separate from and in addition to SIMC’s Investment Management Fee described below. Post Oak Private Wealth Advisor’s fee and SIMC’s Investment Management fee will be deducted by SEI directly from the Client’s account. Post Oak Private Wealth Advisors does not have the ability to directly deduct their advisory fee from the client account. In addition to the fees charged by Post Oak Private Wealth Advisors above, SEI charges the following annual fees: No Platform Fee SEI Fees ranging from 0.55 – 1.15% SEI Sponsored Programs - SIMC Sub-Advised Program SEI Mutual Funds, SEI Managed Account Solutions, SEI Sub-Advised Program Custom High Net Worth Solutions Third Party Assets - Mutual Fund Models Program Non-Transaction Fee (NTF) Mutual Funds No Platform Fee Transaction Fee (TF) Mutual Funds and 20 basis points all other securities, including equities, The platform fee is subject to a $1,000 per year, per account, maximum fixed income and ETFs Post Oak Private Wealth Advisors Managed - Custody-only Program Custom portfolio No Platform Fee Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation. For accounts closed mid-quarter, Post Oak Private Wealth Advisors will be entitled to a pro rata fee for the days service was provided in the final quarter. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. FINANCIAL PLANNING AND CONSULTING Post Oak Private Wealth Advisors charges a fixed fee of no more than $5,000 for financial planning. Prior to the planning process the Client will be provided an estimated plan fee. Services are completed and delivered inside of thirty (30) days contingent upon timely delivery of all required documentation. Fees for financial plans are due upon delivery of the completed plan. Client may cancel within five (5) business days of signing Agreement with no obligation and without penalty. If the Client cancels after five (5) business days, any unpaid earned fees will be due to Post Oak Private Wealth Advisors. Post Oak Private Wealth Advisors reserves the right to waive the fee should the Client implement the plan through Post Oak Private Wealth Advisors. SEMINARS AND WORKSHOPS Post Oak Private Wealth Advisors does not charge a fee for attendance to these seminars. - 5 - Client Payment of Fees Investment management fees are debited monthly in arrears, meaning that we debit you after the billing period. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Fees for financial plans are due upon delivery of the completed plan. Post Oak Private Wealth Advisors, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with Clients, etc.). If a client is utilizing a TPM, they pay the TPM’s investment advisory fees. Prior to signing an investment advisory agreement, the method of payment will be disclosed in the TPM’s Form ADV Part 2. Additional Client Fees Charged Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. For more details on the brokerage practices, see Item 12 of this brochure. Prepayment of Client Fees Post Oak Private Wealth Advisors does not require any prepayment of fees. If the Client cancels after five (5) business days, any unearned fees will be refunded to the Client, or any unpaid earned fees will be due to Post Oak Private Wealth Advisors. External Compensation for the Sale of Securities to Clients Investment Advisor Representatives of Post Oak Private Wealth Advisors receive external compensation sales of investment related products such as insurance as licensed insurance agents. From time to time, they will offer clients services from those activities. Less than 1% of their compensation is from external compensation. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As an insurance agent, Investment Advisor Representatives do not charge advisory fees for the services offered through insurance carriers. This conflict is mitigated by disclosures, procedures, and Post Oak Private Wealth Advisors’ fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another insurance agent of their choosing. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or provide side by side management. - 6 - Item 7: Types of Clients Description We offer our services to individuals, institutions, pension and profit-sharing plans, trusts, estates, and corporations or other business entities. We require a minimum account size of $50,000 for our portfolio management services. We may aggregate related accounts in the same household to meet account minimums. Also account minimums may be negotiated, reduced or waived at our discretion. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We use various methods of security analysis to help us manage client investment account(s). These may include one or more of the following: Fundamental Analysis - Fundamental analysis is a technique that attempts to determine a security’s value by focusing on underlying factors that affect a company's actual business and its future prospects. The analysis is performed on historical and present data. On a broader scope, one can perform fundamental analysis on industries or the economy as a whole. The term refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. Technical Analysis - Technical Analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. We use various sources of information to help us manage your investment account(s). These include:  Financial newspapers and magazines  Research materials prepared by others  Corporate rating services  Annual reports, company financial statements, prospectuses and filings with the Securities and Exchange Commission  Company press releases  Financial news media, including televised and Web-based  Contact with investment company representatives Investment Strategy We use several types of securities in our clients’ accounts. These securities may include, but are not limited to, the following: Bonds and other corporate debt instruments; Exchange Traded Funds; Mutual Funds such as Large Cap Growth, Large Cap Value, Mid Cap Growth, Mid Cap Value, Small Cap Growth, Index, Leveraged, Inverse and Small Cap Value; Government Debt instruments including Treasury Bills and Municipal securities; Stocks; Preferred Stock; High Yield Debt; Domestic Fixed Income; Options; Money Market Funds and Cash. Security Specific Material Risks All investments bear different types and degrees of risk and investing in securities involves risk of loss that clients should be prepared to bear. While we use investment strategies that are designed to provide appropriate investment diversification, some investments have significantly greater risks than others. Obtaining higher rates of return - 7 - on investments entails accepting higher levels of risk. Recommended investment strategies seek to balance risks and rewards to achieve investment objectives. A client needs to ask questions about risks he/she does not understand; we would be pleased to discuss them. We strive to render our best judgment on behalf of our clients. Still, we cannot assure or guarantee clients that investments will be profitable or ensure that no losses will occur in an investment portfolio. Past performance is an important consideration with respect to any investment or investment adviser but is not a reliable predictor of future performance. We continuously strive to provide outstanding long-term investment performance, but many economic and market variables beyond its control can affect the performance of an investment portfolio. An investment could lose money over short or even long periods. A client should expect his/her account value and returns to fluctuate within a wide range, like the fluctuations of the overall stock and bond markets. A client’s account performance could be hurt by:  Stock market risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising stock prices and periods of falling stock prices.  Interest rate risk: The chance that bond prices overall will decline because of rising interest rates.  Manager risk: The chance that the proportions allocated to the various securities will cause the client’s account to underperform relevant to benchmarks or other accounts with a similar investment objective.  International investing risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid than investments in U.S. securities, and may lose value because of adverse political, social or economic developments overseas or due to changes in the exchange rates between foreign currencies and the U.S. dollar. In addition, foreign investments are subject to settlement practices, as well as regulatory and financial reporting standards, which differ from those of the U.S.  Active management fees risk: Active management strategies that involve frequent trading generate higher transaction costs that diminish the fund's return. In addition, the short-term capital gains resulting from frequent trades often have an unfavorable income tax impact when such funds are held in a taxable account.  Leveraged and inverse fund risks: A number of factors may hinder a leveraged or inverse fund’s ability to achieve correlation with its benchmark index, including fees, expenses, transaction costs, use of margin or other leveraged investment techniques, index rebalancing, and other factors described in the prospectus. The effects of leverage and compounding, however, are the two primary reasons why the return of an index over the specified rebalancing period does not translate into the return of a leveraged or inverse fund held for longer than the rebalancing period (and remember, a leveraged or inverse fund does not typically attempt to track an index over any period longer than the rebalancing period, which is most commonly one day). Compounding and leverage are likely to have a significant effect on long- term performance, whether positive or negative. This is one reason why a leveraged or inverse fund that closely tracks the daily performance of an index will not necessarily track the long-term performance of that index. When held for longer - 8 - than one day, a leveraged or inverse fund that seeks to achieve a multiple of the daily return of a benchmark index can even have negative performance over a period in which the benchmark index achieved positive returns. This divergence tends to be particularly pronounced in volatile markets but can also occur in relatively "flat" markets.  Options Risk: Like other securities - including stocks, bonds, and mutual funds - options carry no guarantees, and a person must be aware that it is possible to lose all of the principal he/she invests and sometimes more. As an option holder, a person risks the entire amount of the premium he/she paid pay. But as an options writer, a person takes on a much higher level of risk. For example, if a person writes an uncovered call, he/she faces unlimited potential loss, since there is no cap on how high a stock price can rise. However, since initial options investments usually require less capital than equivalent stock positions, a potential cash loss as an options investor are usually smaller than if someone bought the underlying stock or sold the stock short. The exception to this general rule occurs when an option is used to provide leverage: Percentage returns are often high, but it is important to remember that percentage losses can be high as well. Item 9: Disciplinary Information Criminal or Civil Actions Post Oak Private Wealth Advisors and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings Post Oak Private Wealth Advisors and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings Post Oak Private Wealth Advisors and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Post Oak Private Wealth Advisors or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Post Oak Private Wealth Advisors is not registered as a broker-dealer and no affiliated representatives of Post Oak Private Wealth Advisors are registered representatives of a broker-dealer. Futures or Commodity Registration Neither Post Oak Private Wealth Advisors nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Managing Member Robert Wyrick has a financial affiliated business as an insurance agent with RMW Advisors, LLC dba Post Oak Private Wealth Advisors. Approximately 5% of his time is spent on this activity. He may offer Clients services from this activity. As an insurance agent, he may receive separate yet typical compensation. - 9 - This practice represents a conflict of interest because it gives an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Post Oak Private Wealth Advisors has co-advisory arrangements through SEI’s Managed Account Solutions program. Our fee is separate and in addition to the SEI’s fee. This information can be found in Items 4 & 5. We will ensure that SEI is properly registered or exempt from registration in the client’s state of residence prior to making any recommendations. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description Our Code of Ethics establishes ideals for ethical conduct upon fundamental principles of openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Our Code of Ethics covers all supervised persons, and it describes its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons must acknowledge the terms of the Code of Ethics annually, or as amended. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest We do not have a material interest in any securities. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our owner, Mr. Wyrick, may, from time to time, buy or sell for his own accounts securities that are the same as, similar to, or different than those that his clients purchase or sell. Differences can arise due to variations in personal goals, investment horizons, risk tolerance, and the timing of purchases and sales. The securities traded are typically broadly traded, large scale securities (not penny stocks) and/or mutual funds in which proprietary trades will not affect market prices. Nonetheless, client transactions will precede those orders placed for any proprietary trades. Mr. Wyrick is aware of his fiduciary duty to his clients and the prohibitions against the use of any insider information. We keep records of all associates’ proprietary trading activities and make them available to regulators to review on the premises. Whenever we deem that there may appear to be a conflict of interest, we will inform affected clients of the holdings involved prior to placing any orders. It is our policy that we will not affect any principal or agency cross securities transactions for client accounts. We will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any - 10 - security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker- dealer or has an affiliated broker-dealer. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest Post Oak Private Wealth Advisors does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Post Oak Private Wealth Advisors with copies of their brokerage statements. The Chief Compliance Officer of Post Oak Private Wealth Advisors is Robert Wyrick. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions Post Oak Private Wealth Advisors may recommend the use of a particular broker-dealer such as Charles Schwab & Co., Inc., (“Schwab”) and Fidelity Brokerage Services (“Fidelity”), both registered broker-dealers, members FINRA/SPIC as approved custodians. We are independently owned and operated and not affiliated with either brokerage firm. Schwab or Fidelity will hold the Clients’ assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that the Client use Schwab and/or Fidelity as the custodian/broker, the client will decide whether to do so and open an account with Schwab and/or Fidelity by entering into an account agreement directly with them. We do not open the account for you; however, we can assist the Client in doing so. If the Client does not wish to place their assets with Schwab or Fidelity, then we cannot manage the account.  Directed Brokerage In circumstances where a Client directs Post Oak Private Wealth Advisors to use a certain broker-dealer, Post Oak Private Wealth Advisors still has a fiduciary duty to its Clients. The following may apply with Directed Brokerage: Post Oak Private Wealth Advisors inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among Clients and conflicts of interest arising from brokerage firm referrals. The firm may be unable to achieve most favorable execution of client transactions, and this practice may cost clients more money.  Best Execution Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best - 11 - execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees.  Soft Dollar Arrangements “Soft dollars” are defined as a form of payment investment firms can use to pay for goods and services such as news subscriptions or research. When an investment firm gives its business to a particular brokerage firm, the brokerage firm in return can agree to use some of its revenue to pay for these types of services. We do not receive soft dollar benefits through Charles Schwab & Co. Inc or Fidelity Brokerage Services.  Brokerage for Client Referrals We do not receive client referrals or any other incentive from any custodian or any third party. Aggregating Securities Transactions for Client Accounts Generally, we will aggregate orders with respect to the same security purchased for different clients. When orders are aggregated, each participating account receives the average share price for the transaction and bears a proportionate share of all transaction costs, based upon each account’s participation in the transaction, subject to our discretion depending on factual or market conditions. Clients participating in block trading may include proprietary or related accounts. Such accounts are treated as client accounts and are neither given preferential nor inferior treatment versus other client accounts. Allocations of orders among client accounts must be made in a fair and equitable manner. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Mr. Wyrick reviews the general holdings of the firm’s portfolios on a bi-weekly basis. In addition to these reviews, Mr. Wyrick meets with clients on an annual basis to discuss and review their accounts. Financial plans generated are updated as requested by the Client and pursuant to a new or amended agreement, Post Oak Private Wealth Advisors suggests updating at least annually. Review of Client Accounts on Non-Periodic Basis Additional reviews are conducted periodically depending on market conditions, economic or political events, or by changes in a client’s financial situation (such as retirement, termination of employment, physical move or inheritance). Content of Client Provided Reports and Frequency Clients receive quarterly statements from their custodian. We urge clients to carefully review such statements. In addition to the quarterly statements from the account custodians, each client receives online access to his or her account through Charles Schwab website, which contains account holdings and balance information. - 12 - Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Post Oak Private Wealth Advisors receives a portion of the annual management fees collected by the TPM(s) to whom Post Oak Private Wealth Advisors refers Clients. This situation creates a conflict of interest because Post Oak Private Wealth Advisors and/or its Investment Advisor Representative have an incentive to decide what TPMs to use because of the higher solicitor fees to be received by Post Oak Private Wealth Advisors. However, when referring Clients to a TPM, the Client’s best interest will be the main determining factor of Post Oak Private Wealth Advisors. Post Oak Private Wealth Advisors may receive a non-economic benefit from Schwab in the form of support products and services they make available to us and other independent advisors whose clients maintain their accounts at Schwab. The availability to us from Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for the Client. Advisory Firm Payments for Client Referrals We do not pay for client referrals or use solicitors. Item 15: Custody Account Statements All client funds, securities and accounts are held at third-party custodians. We do not take possession of a client’s securities. However, the client will be asked to authorize us with the ability to deduct fees directly from the client’s account. This authorization will be to deduct our management fee only. A client may object to the deduction of our fees from the Account by notifying us at the address or telephone number shown on each billing invoice or by notifying client’s custodian. The client’s custodian shall also send a quarterly statement indicating the amount of fees withdrawn from the client’s Account. Clients should receive quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. We urge clients to carefully review such statements. Item 16: Investment Discretion Discretionary Authority for Trading If applicable, Client will authorize us discretionary authority, via the advisory agreement, to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. If applicable, Client will authorize us discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. If, however, consent for discretion is not given, we will obtain prior Client approval before executing each transaction. We allow Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to us in writing. The Client approves the custodian to be used and the commission rates paid to the custodian. We do not receive any portion of the transaction fees or commissions paid by the Client to the custodian. - 13 - Item 17: Voting Client Securities Proxy Votes Post Oak Private Wealth Advisors does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, Post Oak Private Wealth Advisors will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Post Oak Private Wealth Advisors does not serve as a custodian for Client funds or securities and Post Oak Private Wealth Advisors does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients Post Oak Private Wealth Advisors has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years Post Oak Private Wealth Advisors has not had any bankruptcy petitions in the last ten years. - 14 -