ROYAL OAK FINANCIAL GROUP

Royal Oak Financial Group Firm Brochure - Form ADV Part 2 A This brochure provides information about the qualifications and business practices of Royal Oak Financial Group. If you have any questions about the contents of this brochure, please contact us at (614) 842-6090 or by email at: matt@royaloakfinancialgroup.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Royal Oak Financial Group is also available on the SEC’s website at www.adviserinfo.sec.gov . Royal Oak Financial Group’s CRD number is: 166391 5858 High St. Worthington, Ohio, 43085 (614) 842-6090 matt@royaloakfinancialgroup.com www.royaloakfinancialgroup.com Registration does not imply a certain level of skill or training. Version Date: 02/16/2026 Item 2: Material Changes  Royal Oak Financial Group has updated its custody disclosure to reflect that it is deemed to have custody under Rule 206(4)-2 of the Investment Advisers Act of 1940 and is subject to an annual surprise examination by an independent public accountant. Form ADV 2A Version: 2/16/2026  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes........................................................................................................................................................................................... i Item 3: Table of Contents .......................................................................................................................................................................................... ii Item 4: Advisory Business .........................................................................................................................................................................................1 A. Description of the Advisory Firm...................................................................................................................................................................1 B. Types of Advisory Services..............................................................................................................................................................................1 Investment Supervisory Services ...................................................................................................................................................................1 Financial Planning............................................................................................................................................................................................1 Services Limited to Specific Types of Investments ......................................................................................................................................2 C. Client Tailored Services and Client Imposed Restrictions ..........................................................................................................................2 D. Wrap Fee Programs..........................................................................................................................................................................................2 E. Amounts Under Management.........................................................................................................................................................................2 Item 5: Fees and Compensation................................................................................................................................................................................3 A. Fee Schedule......................................................................................................................................................................................................3 Investment Supervisory Services Fees...........................................................................................................................................................3 Financial Planning Fees ...................................................................................................................................................................................3 Hourly Fees .......................................................................................................................................................................................................3 B. Payment of Fees.................................................................................................................................................................................................4 Payment of Investment Supervisory Fees .....................................................................................................................................................4 Payment of Financial Planning Fees ..............................................................................................................................................................4 C. Clients Are Responsible For Third Party Fees ..............................................................................................................................................4 D. Prepayment of Fees ..........................................................................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients........................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................5 Item 7: Types of Clients .............................................................................................................................................................................................5 Minimum Account Size...................................................................................................................................................................................5 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ...........................................................................................5 A. Methods of Analysis and Investment Strategies..................................................................................................................................5 Methods of Analysis ........................................................................................................................................................................................5 Charting analysis..............................................................................................................................................................................................5 Fundamental analysis ......................................................................................................................................................................................5 Technical analysis.............................................................................................................................................................................................5 Cyclical analysis ...............................................................................................................................................................................................5 Investment Strategies.......................................................................................................................................................................................5 B. Material Risks Involved ..........................................................................................................................................................................6 ii Form ADV 2A Version: 2/16/2026 Methods of Analysis ........................................................................................................................................................................................6 Fundamental analysis ......................................................................................................................................................................................6  Technical analysis.............................................................................................................................................................................................6 Cyclical analysis ...............................................................................................................................................................................................6 Investment Strategies.......................................................................................................................................................................................6 C. Risks of Specific Securities Utilized .......................................................................................................................................................6 Item 9: Disciplinary Information ..............................................................................................................................................................................8 A. Criminal or Civil Actions ........................................................................................................................................................................8 B. Administrative Proceedings ...................................................................................................................................................................8 C. Self-regulatory Organization (SRO) Proceedings ................................................................................................................................8 Item 10: Other Financial Industry Activities and Affiliations...............................................................................................................................8 A. Registration as a Broker/Dealer or Broker/Dealer Representative ..................................................................................................8 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor...................8 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests..............................................8 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ....................................9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading......................................................................9 A. Code of Ethics...........................................................................................................................................................................................9 B. Recommendations Involving Material Financial Interests ...............................................................................................................10 C. Investing Personal Money in the Same Securities as Clients............................................................................................................10 D. Trading Securities At/Around the Same Time as Clients’ Securities .............................................................................................10 Item 12: Brokerage Practices....................................................................................................................................................................................10 A. Factors Used to Select Custodians and/or Broker/Dealers .............................................................................................................10 1. Research and Other Soft-Dollar Benefits ........................................................................................................................................11 2. Brokerage for Client Referrals .........................................................................................................................................................11 3. Clients Directing Which Broker/Dealer/Custodian to Use ........................................................................................................11 B. Aggregating (Block) Trading for Multiple Client Accounts .............................................................................................................11 Item 13: Reviews of Accounts .................................................................................................................................................................................11 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews...............................................................................11 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts............................................................................................12 C. Content and Frequency of Regular Reports Provided to Clients.....................................................................................................12 Item 14: Client Referrals and Other Compensation .............................................................................................................................................12 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ......12 B. Compensation to Non – Advisory Personnel for Client Referrals...................................................................................................12 Item 15: Custody.......................................................................................................................................................................................................12 Item 16: Investment Discretion ...............................................................................................................................................................................12 Item 17: Voting Client Securities (Proxy Voting)..................................................................................................................................................13 Item 18: Financial Information................................................................................................................................................................................13 A. Balance Sheet ..........................................................................................................................................................................................13 iii Form ADV 2A Version: 2/16/2026 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ...............................13 C. Bankruptcy Petitions in Previous Ten Years ......................................................................................................................................13 iv Form ADV 2A Version: 2/16/2026 Item 4: Advisory Business  A. Description of the Advisory Firm Royal Oak Financial Group is a Limited Liability Company organized in the state of Ohio. The entity was formed in April of 2004, and has been in business since February 2013. The principal owner is Matthew Martin Jehn. Royal Oak Financial Group is an SEC-registered investment adviser operating under the fiduciary standard. B. Types of Advisory Services Royal Oak Financial Group (hereinafter “ROFG”) offers the following services to advisory clients: Investment Supervisory Services ROFG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ROFG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring ROFG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. These services are based on hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. 1 Form ADV 2A Version: 2/16/2026 Services Limited to Specific Types of Investments ROFG generally limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, insurance products including annuities, and government securities. ROFG may use other securities as well to  help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ROFG offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ROFG from properly servicing the client account, or if the restrictions would require ROFG to deviate from its standard suite of services, ROFG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. ROFG does not participate in any wrap fee programs. E. Amounts Under Management ROFG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $366,039,317 $0.00 February 2026 2 Form ADV 2A Version: 2/16/2026 Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees  Total Assets Annual Fee All Assets .50% - 2.00% These fees are negotiable depending upon the needs of the client and complexity of the situation, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid quarterly in arrears, and clients may terminate their contracts with one day written notice. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Refunds are given on a prorated basis, based on the number of days remaining in a quarter at the point of termination. Fees that are collected in arrears will be refunded based on the prorated amount of work completed up to the day of termination within the quarter terminated. The fee refunded will be the balance of the fees collected in arrears minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Financial Planning Fees Hourly Fees Depending upon the complexity of the situation and the needs of the client, the hourly fee for these services is $300. The fees are negotiable and the final fee schedule will be attached as Exhibit II of the Financial Planning Agreement. Fees are paid in arrears upon completion. Because fees are charged in arrears, no refund is necessary. Clients may terminate their contracts without penalty within five business days of signing the advisory contract. 3 Form ADV 2A Version: 2/16/2026 B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in arrears.  Advisory fees may also be invoiced and billed directly to the client quarterly in arrears. Clients may select the method in which they are billed. Payment of Financial Planning Fees Hourly Financial Planning fees are paid via check or credit card in arrears upon completion. Because fees are charged in arrears, no refund is necessary. C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by ROFG. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees ROFG collects fees in arrears. Fees that are collected in arrears will be refunded based on the prorated amount of work completed at the point of termination and the total days during the billing period. Fees will be returned within fourteen days to the client via mailed check. The fee refunded will be the balance of the fees collected in arrears minus the daily rate* times the number of days in the quarter up to and including the day of termination. (*The daily rate is calculated by dividing the quarterly AUM fee by the number of days in the termination quarter). E. Outside Compensation For the Sale of Securities to Clients ROFG as a licensed insurance agency, receives commissions for the sale of insurance products. Clients should be aware that accepting commission or other compensation and involves a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. ROFG always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to purchase such services or products through any representative of ROFG in such individual’s outside capacities. 4 Form ADV 2A Version: 2/16/2026 Item 6: Performance-Based Fees and Side-By-Side Management ROFG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client.  Item 7: Types of Clients ROFG generally provides investment advice and/or management supervisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals Minimum Account Size There is no account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis ROFG’s methods of analysis include charting analysis, fundamental analysis, technical analysis, and cyclical analysis. Charting analysis involves the use of patterns in performance charts. ROFG uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. 5 Form ADV 2A Version: 2/16/2026  B. Material Risks Involved - Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Investment Strategies Risk is that markets do not always follow patterns and relying solely on this method may not work long term. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two fold : 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles they are trying to take advantage of. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Form ADV 2A Version: 2/16/2026 C. Risks of Specific Securities Utilized Investment Strategies ROFG primarily utilizes long-term investment strategies focused on diversified equity and fixed income portfolios. Portfolios are constructed based on each client’s investment objectives, time horizon, and risk tolerance as outlined in the client’s Investment Policy Statement. The Firm does not engage in short-term trading, speculative strategies, or uncovered options strategies as part of its advisory services. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds : Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower  investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Equity investment generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss. Treasury Inflation Protected/Inflation Linked Bonds: The Risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Fixed Income is an investment that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. Debt securities carry risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet obligations. Stocks & Exchange Traded Funds (ETF) : Investing in stocks & ETF's carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). REITs have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares. Precious Metal ETFs (Gold, Silver, Palladium Bullion backed “electronic shares” not physical metal): Investing in precious metal ETFs carries the risk of capital loss. Form ADV 2A Version: 2/16/2026 7 Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability and inflation. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information  A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither ROFG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Form ADV 2A Version: 2/16/2026 8 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither ROFG nor its representatives are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests  Matthew Martin Jehn is a licensed insurance agent and accountant. From time to time, he will offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. ROFG always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any representative of ROFG in such individual’s outside capacities. Clients will receive separate product disclosure and commission information at the time of any insurance transaction. Bradley Stephen Senita is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of Royal Oak Financial Group are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. Royal Oak Financial Group addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. Royal Oak Financial Group periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. Royal Oak Financial Group will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by Royal Oak Financial Group’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Grant McIntyre Billings is an accountant. From time to time, he will offer clients advice or products from this activity. Royal Oak Financial Group always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of Royal Oak Financial Group in their capacity as an accountant. Form ADV 2A Version: 2/16/2026 9 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ROFG does not utilize nor select other advisers or third party managers. All assets are managed by ROFG management.  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Procedures and Reporting, Certification of Compliance, We have a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Reporting Regulations, Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests ROFG does not recommend that clients buy or sell any security in which a related person to ROFG or ROFG has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of ROFG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of ROFG to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. ROFG will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold. Form ADV 2A Version: 2/16/2026 10 D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of ROFG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of ROFG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. ROFG will always transact client’s transactions before its own when similar securities are being bought or sold.  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers including but not limited to access to written research, The Custodian will be chosen based on their relatively low transaction fees and access to mutual funds and ETFs. ROFG will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. Custodians/broker dealers will be recommended based on ROFG’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a Client on terms that are the most favorable to the Client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and ROFG may also consider the market expertise and research access provided by the payment of commissions, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of ROFG. ROFG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Royal Oak Financial Group recommends Interactive Brokers LLC (CRD# 36418) and Charles Schwab & Co., Inc. (CRD# 5393) as qualified custodians. Client assets are held in the client’s name at the qualified custodian. Royal Oak Financial Group does not take physical possession of client funds or securities. 1. Research and Other Soft-Dollar Benefits ROFG receives no research, product, or services other than execution from a broker dealer or third-party in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals ROFG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Form ADV 2A Version: 2/16/2026 11 3. Clients Directing Which Broker/Dealer/Custodian to Use While clients may request the use of a particular qualified custodian, Royal Oak Financial Group reserves the right to decline accounts where operational limitations, compliance considerations, or service  constraints would impair the Firm’s ability to effectively manage the account. When clients direct the use of a specific custodian, the Firm may be unable to achieve best execution or aggregate trades, which could result in higher transaction costs or less favorable pricing. B. Aggregating (Block) Trading for Multiple Client Accounts ROFG maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing ROFG the ability to purchase larger blocks resulting in smaller transaction costs to the client. Declining to block trade can cause more expensive trades for clients. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least monthly only by Matthew Martin Jehn, Managing Member. Matthew Martin Jehn is the chief advisor and is instructed to review clients’ accounts with regard to clients’ respective investment policies and risk tolerance levels. All accounts at ROFG are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Matthew Martin Jehn, Managing Member. There is only one level of review and that is the total review conducted to create the financial plan. 12 Form ADV 2A Version: 2/16/2026 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly from the custodian, a written report that details the client’s account including assets held and asset value which will come from the  custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ROFG does not receive any economic benefit, directly or indirectly from any third party for advice rendered to ROFG clients. B. Compensation to Non – Advisory Personnel for Client Referrals ROFG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody Royal Oak Financial Group is deemed to have custody of client assets under Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”). Custody arises because the Firm is authorized to deduct advisory fees directly from certain client accounts and, in certain cases, has authority under client-executed powers of attorney to facilitate third-party transfers at a client’s direction. Client assets are maintained with qualified custodians, including Interactive Brokers LLC. These custodians maintain client accounts in the client’s name and send account statements directly to clients at least quarterly. 13 Form ADV 2A Version: 2/16/2026 Clients should carefully review the account statements received directly from their qualified custodian and compare them to any reports provided by Royal Oak Financial Group. Because the Firm is deemed to have custody, it undergoes an annual surprise examination by an independent public accountant in accordance with the Custody Rule. The independent public accountant verifies client assets and files Form ADV-E with the Securities and Exchange Commission.  Item 16: Investment Discretion Royal Oak Financial Group has discretionary authority to manage client accounts on an ongoing basis pursuant to written client authorization. The scope of this authority is fully disclosed to the client prior to the commencement of the advisory relationship. Clients grant discretionary authority through a discretionary investment management provision in the Investment Advisory Agreement and/or through a limited power of attorney granted to the Firm with the qualified custodian. Item 17: Voting Client Securities (Proxy Voting) ROFG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet ROFG does not require nor solicit prepayment of more than $1200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ROFG nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. 14 Form ADV 2A Version: 2/16/2026 C. Bankruptcy Petitions in Previous Ten Years ROFG has not been the subject of a bankruptcy petition in the last ten years. 15  Form ADV 2A Version: 2/16/2026