Overview
- Headquarters
- Gold River, CA
- Total Firm Assets
- $100 million
- Average High-Net-Worth Client Portfolio Size
- $1.6 million
- Stated Minimum Account Size
- $250,000
Fee Disclosure
FORM ADV PARTS 2A & 2B
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $1,000,000 | 1.12% |
| $1,000,001 | $2,000,000 | 1.00% |
| $2,000,001 | $3,000,000 | 0.88% |
| $3,000,001 | $4,000,000 | 0.75% |
| $4,000,001 | $5,000,000 | 0.62% |
| $5,000,001 | and above | 0.50% |
Stated Minimum Annual Fee: $5,000
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $11,875 | 1.19% |
| $5 million | $44,375 | 0.89% |
| $10 million | $69,375 | 0.69% |
| $50 million | $269,375 | 0.54% |
| $100 million | $519,375 | 0.52% |
Clients
- High-Net-Worth Share of Firm Assets
- 72.54%
- Number of High-Net-Worth Clients
- 46
- Total Client Accounts
- 343
- Discretionary Accounts
- 343
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 171082
Primary Brochure: FORM ADV PARTS 2A & 2B (2026-09-01)
View Document Text
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
Item 1: Cover Page
2377 Gold Meadow Way
Gold River, CA 95670
www.threeoakswealth.com
September 1, 2026
This brochure provides information about the qualifications and business practices of
Three Oaks Capital Management, LLC DBA Three Oaks Wealth. If you have any questions
about the contents of this brochure, please contact us at 916-318-4849. The information
in this brochure has not been approved or verified by the Unites States Securities and
Exchange Commission or by any state securities authority. Registration does not imply a
certain level of skill or training. Additional information about Three Oaks Capital
Management, LLC DBA Three Oaks Wealth is also available on the SEC’s website at
www.adviserinfo.sec.gov.
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Form ADV Part 2
Item 2: Material Changes
Since the previous annual filing of this ADV Part 2 for Three Oaks Wealth (filed on March
16, 2026), the following material changes have been made to this version of the Disclosure
Brochure:
• Three Oaks Wealth is now registered with the SEC.
•
•
Item 5 has been updated to disclose that Three Oaks will notify the Client
electronically 30 days in advance of any fee increase. If no objection is made by the
Client within thirty (30) days following delivery of such amendment notice, Adviser
will assume the Client’s inaction constitutes consent.
Item 5 has been updated to disclose that Three Oaks Wealth reserves the right to
assess a late fee of 5% per month on planning fees more than 30 days overdue.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................................. 1
Item 2: Material Changes ..................................................................................................................................... 2
Item 3: Table of Contents .................................................................................................................................... 3
Item 4: Advisory Business ................................................................................................................................... 4
Item 5: Fees and Compensation ....................................................................................................................... 6
Item 6: Performance Based Fees ..................................................................................................................... 8
Item 7: Types of Clients ........................................................................................................................................ 9
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ......................................... 9
Item 9: Disciplinary Information .................................................................................................................... 11
Item 10: Other Financial Industry Activities and Affiliations .......................................................... 11
Item 11: Code of Ethics ..................................................................................................................................... 11
Item 12: Brokerage Practices .......................................................................................................................... 12
Item 13: Review of Accounts .......................................................................................................................... 14
Item 14: Client Referrals and Other Compensation ............................................................................ 14
Item 15: Custody ................................................................................................................................................... 15
Item 16: Investment Discretion ..................................................................................................................... 16
Item 17: Voting Client Securities .................................................................................................................. 16
Item 18: Financial Information ....................................................................................................................... 16
ADV Part 2B: Brochure Supplement for Grant Bledsoe ................................................................... 17
ADV Part 2B: Brochure Supplement for Bethany Ely ........................................................................ 21
ADV Part 2B: Brochure Supplement for Karmjit Bath ....................................................................... 23
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Form ADV Part 2
Item 4: Advisory Business
A. Three Oaks Capital Management, LLC DBA Three Oaks Wealth, (“Three Oaks”) is an
independent registered investment adviser firm established in April 2014. Three Oaks
provides financial planning, investment management, retirement plan services, and
pension consulting services to a variety of entities. Three Oaks is solely owned by
Grant Bledsoe, CFA, CFP®. Three Oaks has and maintains a written business
continuity plan, which is available upon request.
B. Financial Planning
Three Oaks offers comprehensive financial planning services focused on helping
clients organize and optimize their finances. Upon engagement clients are asked to
submit personal financial information via questionnaire, interviews, and meetings. This
information is then consolidated in a centralized location and a personalized financial
plan is created, complete with a step-by-step implementation guide. While financial
plans incorporate all areas clients wish to address, common topics include:
• Equity and fixed income investing
• Asset allocation
• Cash flow & budgeting
• Debt management
• Retirement planning
• Estate planning
• Divorce settlement planning
• Wealth transfers between generations and to charitable organizations
• College savings
• Tax planning
• Entrepreneurship & business planning
After the initial financial plan is complete, subsequent implementation meetings occur
several times per year depending on client needs. Together we review progress made
in executing the financial plan and make changes over time as necessary. In between
meetings clients have unlimited access to their adviser over the phone, email, and in
person in the event of an emergency.
Investment Management
Investment management services are offered to clients with at least $250,000. This
minimum may be waived at the discretion of the adviser. Custom portfolios are
constructed based on each client’s unique circumstances, and may be invested in
individual securities, ETFs, mutual funds, alternative, or other investments. Goals and
objectives for each client are determined through personal discussions. We then
develop a personalized investment strategy and asset allocation target and create and
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Form ADV Part 2
manage a portfolio based on this strategy and plan. Individual objectives, time
horizons, risk tolerance, liquidity needs, and tax impact are all considered in this
process.
Retirement Plan & Pension Consulting Services
Three Oaks Capital offers retirement plan and pension consulting services to
businesses & other organizations, helping to manage their corporate retirement plans,
improve participant outcomes, and make smart decisions aligned with the
organization’s long-term objectives. Retirement plan services are offered to corporate
qualified and unqualified retirement plans, their sponsors, and their participants.
Three Oaks may provide a number of services to retirement plan clients:
• Act as a 3(21) fiduciary or 3(38) investment manager as defined in the
Employee Retirement Income Security Act (ERISA)
Investment policy statements
Investment recommendations & performance monitoring
Investment management
Individual investment guidance and/or advice
• Plan design
•
•
• Selection of Qualified Default Investment Alternatives (QDIAs)
•
• Fiduciary monitoring
• Education services to plan committee
• Participant education
•
• Plan benchmarking & search support
• Custom services based on sponsor needs
Educational Seminars / Speaking Engagements
We may provide seminars for groups seeking general advice on investments and other
areas of personal finance. These seminars are purely educational in nature and do not
involve the sale of any investment products. Information presented will not be based
on any individual’s need, nor does Three Oaks provide individualized investment advice
to attendees during these seminars. Topics covered during educational seminars will
be determined by the Client and Three Oaks.
C. All financial planning, investment management, wealth management, and retirement
plan & pension consulting services are tailored to the individual needs of each client.
Three Oaks gathers client data at the onset of each new relationship, and uses that
data to build custom financial strategies, recommendations, portfolios, and retirement
plans based on clients’ needs and objectives. Clients may impose restrictions on
investing in certain securities or certain types of securities.
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D. A wrap fee is a comprehensive charge to clients as remuneration for a bundle of
services. Commonly these services include investment management, planning, advice,
research, or commissions. Three Oaks does not participate in wrap programs.
E. As of June 19, 2026, Three Oaks manages $100,005,394 in discretionary assets and
$0 in non-discretionary assets.
Item 5: Fees and Compensation
A. Three Oaks assesses fees based on the services provided.
Financial Planning
Fees for financial planning services depend on the complexity of the client’s situation
and typically range from $5,000 to $45,000 per year. This fee is paid either quarterly
or monthly, at the discretion of the client, and is collected in advance. Under no
circumstances will Three Oaks Capital accept prepayment of more than $1,200 in fees
six or more months in advance.
Alternatively, clients seeking hourly project work are billed at the rate of $150 - $500
per hour, depending on the level & scope of work, and professional rendering the
services.
Quarterly, monthly, and hourly fee minimums may be waived at the discretion of Three
Oaks. All financial planning fees are negotiable.
Three Oaks will notify the Client electronically 30 days in advance of any fee increase.
If no objection is made by the Client within thirty (30) days following delivery of such
amendment notice, Adviser will assume the Client’s inaction constitutes consent.
Three Oaks Wealth reserves the right to assess a late fee of 5% per month on payments
more than 30 days overdue.
Investment Management
Investment management fees are based on the amount of assets managed, are charged
quarterly, and collected in advance. All fees are based on account market values on
the last day of the prior quarter.
Fees are normally deducted directly from clients’ accounts at the custodian and
reflected both on the custodian’s monthly statements and on invoices provided by
Three Oaks. Fees may also be billed directly to clients upon request and are negotiable.
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The following fee schedule applies to clients enrolled in both investment management
and automated investment management services:
Assets Under Management
First $500,000
Amount over $500,000
Amount over $1,000,000
Amount over $2,000,000
Amount over $3,000,000
Amount over $4,000,000
Amount over $5,000,000
Fee
1.250%
1.125%
1.000%
0.875%
0.75%
0.625%
0.5%
The minimum quarterly fee is $1,250, which may be waived at the discretion of Three
Oaks Capital. Given this minimum fee, clients with account balances less than
$400,000 may incur fees greater than the 1.25% listed above. For example, an account
with a $300,000 value that is charged the minimum quarterly fee of $1,250 would be
paying an annualized fee of 1.67% ($1,250 * 4 / $300,000). Fees for partial quarters
are prorated, based on the number of days the account was open.
Three Oaks will notify the Client electronically 30 days in advance of any fee increase.
If no objection is made by the Client within thirty (30) days following delivery of such
amendment notice, Adviser will assume the Client’s inaction constitutes consent.
Retirement Plan & Pension Consulting Services
Fees for retirement plan & pension consulting services depend on the scope of the
scope and complexity of services provided. One-time projects are assessed a flat fee,
varying from $500 - $25,000, or billed at an hourly rate of $250. Ongoing services are
assessed either a flat annual fee, or a percentage of the clients’ total retirement plan
assets ranging from 0.15% to 1.25%. Both one-time projects and ongoing service fees
are negotiable. One-time Retirement Plan & Pension Consulting Services typically
require a $500 initial deposit, at the discretion of the adviser, with the balance being
charged upon completion of the project. Ongoing services are billed in advance.
Educational Seminars / Speaking Engagements
Seminars and speaking engagements are offered to organizations and the public on a
variety of financial topics. Fees range from $0 to $10,000 per seminar or from $0 to
$500 per participant. The fee range is based on the content, amount of research
conducted, the number of hours of preparation needed, and the number of attendees.
Three Oaks collects the fee in advance. Advisor offers its services in a virtual or in-
person setting. Should the event require travel arrangements, both parties must agree
to the terms of travel (i.e. cost, distance, hotel arrangements) at the start of the
engagement.
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B. Fees for investment management and retirement plan & pension consulting services
based on managed assets are deducted directly from clients’ accounts but may be billed
to clients directly upon request. Fees for financial planning and retirement plan &
pension consulting services not dependent on managed assets may be paid by check
or ACH transfer. Fees for educational seminars and speaking engagements are payable
via credit card using a third-party payment processor.
C. Additional Fees and Expenses
Three Oaks does not provide custody services, and fees for investment management,
financial planning, and retirement plan services do not include fees charged by
custodians or third parties. These fees may include:
• Advisory or administrative fees charged by mutual funds or exchange traded
funds (ETFs)
• Commissions
• Wire-transfer fees
• Odd-lot differentials
• Custodial Fees
• Exchange Fees
• Transaction Fees
• Termination Fees
• Deferred Sales Charges
D. Clients are billed in advance for all financial planning, investment management, wealth
management and some ongoing retirement plan & pension consulting services.
Ongoing financial planning fees are billed on a monthly or quarterly basis based on
client preference. The flat fee for one time & hourly retirement plan & pension
consulting services and student debt plans is billed upon completion of the respective
project and may require a $500 deposit subject to adviser discretion.
If a contract is terminated before the end of a billing period, Three Oaks will refund the
pro-rated portion of all pre-paid fees upon request.
E. No principal or supervised person at Three Oaks accepts compensation for the sale of
securities or other investment products. Three Oaks is a fee-only firm, meaning our
only remuneration comes directly from our clients only.
Item 6: Performance Based Fees
Three Oaks does not charge any performance-based fees and does not engage in side-
by-side management.
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Form ADV Part 2
Item 7: Types of Clients
Three Oaks provides services to individuals, families, trusts, estates, pension and
profit-sharing plans, company retirement plans, corporations, and other business
entities.
Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis
Three Oaks’ investment philosophy is based on contemporary academic research,
including Modern Portfolio Theory (MPT) and the efficiency of capital markets around
the world. Modern Portfolio Theory states that there is a spectrum of risk and return
on which different investment securities and asset classes lie. Some asset classes tend
to exhibit lower returns and lower risk of loss, while others offer higher returns with a
higher risk of loss. Modern Portfolio Theory accounts for these risk and return
characteristics, in addition to how each asset classes performs with one another. By
diversifying investment portfolios and integrating asset classes, MPT states that
investors can reap the benefits of higher risk adjusted returns.
Market efficiency refers to the degree to which security prices reflect publicly available
information. Three Oaks believes that market efficiency varies both by asset class and
regional economic development. This philosophy, along with Modern Portfolio
Theory, is applied broadly across client portfolios.
Three Oaks combines a top-down strategic asset allocation with bottom-up security
and fund analysis. Three Oaks generates capital market expectations by evaluating
macroeconomic factors, quantitative models, and third-party research. These
expectations are then used in tandem with clients’ risk / return profiles and financial
plans to build a strategic asset allocation.
Based on each client’s asset allocation, ETFs, mutual funds, individual securities, and
options contracts are selected based on bottom-up quantitative screening and
modeling, microeconomic analysis, and analyst research. In selecting ETFs and mutual
funds, Three Oaks evaluates all performance net of fees. As such, funds with higher
relative loads and expense ratios are only purchased when their returns clearly justify
the additional costs.
B. Investment Strategies
All client portfolios and asset allocations are customized for each client’s unique needs.
While each client’s individual circumstances and asset allocation may be different,
most will typically resemble one of the following strategies:
• Capital Preservation
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Form ADV Part 2
• Conservative
• Balanced
•
Income
• Growth
• Aggressive Growth
Beyond client specific portfolio strategy, Three Oaks attempts to limit risk by:
• Minimizing trading and investment costs
• Broadly diversifying between stocks, bonds, and other asset classes
•
Investing in diversified exchange traded funds (ETFs) and mutual funds
• Designing strategic asset allocations focused on long term performance
• Favoring highly rated corporate and government bonds
• Favoring tax efficient ETFs and mutual funds
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
Regardless of our investment philosophy and strategy employed, investors face the
following risks:
•
•
• Market Risk: Certain events taking place around the world may negatively
affect securities prices, including changes in the macro-economic landscape,
overall market structure and behavior, political and social regimes, or natural
disasters.
Interest Rate Risk: Changes in interest rates may affect the value of any
security. Such changes include the absolute level of interest rates, the shape of
the yield curve, or spreads between securities.
Inflation Risk: Asset appreciation may not outpace the purchasing power lost
due to inflation.
• Currency Risk: Foreign currencies may fluctuate relative to the U.S. dollar.
Foreign securities may fluctuate accordingly.
• Credit Risk: Changes in the financial strength of the issuer may affect its ability
to make timely interest payments and repay principal. The degree of credit risk
may be reflected in its credit rating.
• Duration Risk: Fixed income securities with longer maturities are more sensitive
to interest rate changes than those with shorter maturities.
• Reinvestment Risk: Proceeds from maturing fixed income securities may not be
able to secure similar interest rates due to changes in capital market conditions.
• Liquidity Risk: Certain securities or markets may lack liquidity from time to time.
This can hinder prices obtained in purchases and sales, and therefore portfolio
performance.
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• Business Risk: Individual companies or industries are exposed to specific risks.
These risks can inhibit profitability, and therefore asset and portfolio
performance.
Item 9: Disciplinary Information
Registered investment advisers are required to disclose any material facts regarding
legal or disciplinary proceedings related to our business or integrity. Three Oaks has
no legal or disciplinary items to report, nor has Grant Bledsoe been the subject to any
criminal or civil actions, administrative proceedings, or self-regulatory organization
(SRO) proceedings.
Item 10: Other Financial Industry Activities and Affiliations
A. No principal or supervised person of Three Oaks Capital is registered with or has an
application pending to register as a broker-dealer or representative of a broker-dealer,
or other company that would create a conflict of interest.
B. No principal or supervised person of Three Oaks is registered with or has an application
pending to register as a futures commission merchant, commodity pool operator, a
commodity trading adviser, or as an associated person of the foregoing entities.
C. Three Oaks Wealth representatives may provide tax preparation services through
Three Oaks Tax, Inc. and may refer clients to Three Oaks Tax Inc. to receive tax
preparation services. Clients of Three Oaks Wealth are never under any obligation to
utilize Three Oaks Tax, Inc. for tax preparation services. The tax preparation fee for
services rendered at Three Oaks Tax, Inc. may be waived.
D. No principal or supervised person of Three Oaks receives compensation directly or
indirectly from other investment advisers or investment managers we may recommend
during the course of business.
Item 11: Code of Ethics
A. Three Oaks bases its operations on acting in our clients’ best interest and promoting
the integrity of the financial markets at all times. As such, Three Oaks has adopted a
code of ethics based governing the conduct of all principals, employees, and associated
persons. The code includes provisions concerning:
Integrity of Capital Markets
Investment Analysis, Recommendations, and Actions
• Professionalism
•
• Duties to Clients
•
• Conflicts of Interest
• Personal Securities Transactions & Trading Restrictions
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Form ADV Part 2
Three Oaks code of ethics is available upon request.
B. No principal or supervised person of Three Oaks recommends or transacts in securities
in which they or a related person has a material conflict of interest.
C. Principals and supervised persons of Three Oaks may personally buy or sell securities
that are the same as, similar to, or different from those recommended & bought or sold
in client accounts. A recommendation made to one client may be different than a
recommendation made for another client, due to different objectives and tolerances
for risk. At no time will our firm or any related party receive preferential treatment
over clients.
D. Principals and supervised persons of Three Oaks may also invest in securities at the
same time, before, or after clients. In an effort to reduce or eliminate certain conflicts
of interest involving the firm or personal trading, our policy may require that we restrict
or prohibit associates’ transactions in specific securities transactions. Any exceptions
or trading pre-clearance must be approved by our Chief Compliance Officer in advance
of the transaction in an account, and we maintain the required personal securities
transaction records per regulation.
Item 12: Brokerage Practices
A. Best Execution
Three Oaks is required by its fiduciary responsibility to seek and obtain best execution
for its clients. Execution refers to the overall costs and benefits associated with client
transactions and trades. Best execution is the execution of client transactions in a
manner that is most beneficial to the client in terms of total cost. Best execution is
viewed from the perspective of clients’ total portfolio and can change given unique
circumstances.
Soft Dollar Practices
Soft dollars are any benefits received from brokers in exchange for client brokerage.
These benefits often come in the form of investment research and other materials that
aid the investment process. Soft dollars are the property of the client. In practice,
Three Oaks may receive soft dollars from brokerage firms.
Schwab Advisor Services™ (formerly called Schwab Institutional) is Schwab’s business
serving independent investment advisory firms like us. Through Schwab Advisor
Services, CS&Co. provides us and our clients, both those enrolled in the Program and
our clients not enrolled in the Program, with access to its institutional brokerage
services— trading, custody, reporting, and related services—many of which are not
typically available to CS&Co. retail customers. CS&Co. also makes available various
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Form ADV Part 2
support services. Some of those services help us manage or administer our clients’
accounts, while others help us manage and grow our business. CS&Co.’s support
services described below are generally available on an unsolicited basis (we don’t have
to request them) and at no charge to us. The availability to us of CS&Co.’s products
and services is not based on us giving particular investment advice, such as buying
particular securities for our clients. Here is a more detailed description of CS&Co.’s
support services:
CS&Co.’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might
not otherwise have access or that would require a significantly higher minimum initial
investment by our clients. CS&Co.’s services described in this paragraph generally
benefit the client and the client’s account. CS&Co. also makes available to us other
products and services that benefit us but may not directly benefit the client or its
account. These products and services assist us in managing and administering our
clients’ accounts. They include investment research, both Schwab’s own and that of
third parties. We may use this research to service all or some substantial number of
our clients’ accounts, including accounts not maintained at CS&Co.
In addition to investment research, CS&Co. also makes available software and other
technology that:
• Provide access to client account data (such as duplicate trade confirmations and
account statements);
• Facilitate trade execution and allocate aggregated trade orders for multiple
client accounts;
• Provide pricing and other market data;
• Facilitate payment of our fees from our clients’ accounts; and
• Assist with back-office functions, recordkeeping, and client reporting.
CS&Co. also offers other services intended to help us manage and further develop our
business enterprise. These services include:
• Educational conferences and events;
• Technology, compliance, legal, and business consulting;
• Publications and conferences on practice management and business succession;
and
• Access to employee benefits providers, human capital consultants, and
insurance providers.
CS&Co. may provide some of these services itself. In other cases, it will arrange for
third-party vendors to provide the services to us. CS&Co. may also discount or waive
its fees for some of these services or pay all or a part of a third party’s fees. CS&Co.
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may also provide us with other benefits such as occasional business entertainment of
our personnel.
Client Directed Brokerage
Three Oaks does permit direction of brokerage from clients. Clients must be aware
that by directing their brokerage they may not be achieving best execution, as
commissions and other costs may be higher and prices obtained may not be as
favorable. Three Oaks requires clients to acknowledge this in writing when directing
their brokerage.
The availability of services from CS&Co. benefits us because we do not have to
produce or purchase them. We don’t have to pay for these services, and they are not
contingent upon us committing any specific amount of business to CS&Co. in trading
commissions or assets in custody.
Considering our arrangements with Schwab, we may have an incentive to recommend
that our clients maintain their accounts with CS&Co. based on our interest in receiving
Schwab’s services that benefit our business rather than based on the client’s interest
in receiving the best value in custody services and the most favorable execution of
transactions. This is a potential conflict of interest. We believe, however, that our
selection of CS&Co. as custodian and broker is in the best interests of our clients. It is
primarily supported by the scope, quality, and price of CS&Co.’s services and not
Schwab’s services that benefit only us. We have adopted policies and procedures
designed to ensure that our use of Schwab’s services is appropriate for each of our
clients.
Item 13: Review of Accounts
A. Accounts are reviewed at minimum quarterly by client account representatives.
B. Additional reviews and/or rebalancing may be triggered by tax considerations, market
conditions, large deposits/withdrawals, or other unique client situations.
C. All clients receive quarterly statements and performance summaries from Three Oaks
Capital. In addition, clients may receive periodic updates addressing capital market
conditions and investment research.
Item 14: Client Referrals and Other Compensation
A. We receive an economic benefit from Schwab in the form of the support products and
services it makes available to us. These products and services, how they benefit us, and
the related conflicts of interest are described above under Item 12 Brokerage Practices.
They do not include client referrals. The availability to us of Schwab’s products and
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services is not based on us giving particular investment advice, such as buying
particular securities for our clients.
B. Three Oaks may occasionally compensate third party solicitors in exchange for client
referrals. Currently we have an arrangement with Wealthramp, Inc., whereby we
compensate them for referring clients, pursuant to Rule 206(4)-3 of the Advisers Act.
All clients referred in this manner receive notification of this relationship prior to
engaging us. Our financial arrangement is specified in this notification.
Item 15: Custody
All client accounts are held in custody by qualified banks or broker/dealers. In most
client arrangements, Three Oaks is permitted to debit advisory fees directly from client
accounts. This may be interpreted as having custody of client funds. Any custody of
client funds and/or securities is solely a consequence of the firm’s authority to make
withdrawals from client accounts to pay advisory fees. Three Oaks obtains written
authorization from clients prior to deducting advisory fees held with qualified
custodians. Statements of fee amounts to be deducted from client accounts are sent
to both qualified custodians and clients prior to each fee being deducted.
Three Oaks is not owned by or associated with any qualified custodian. The account
agreements clients sign with qualified custodians are separate and independent from
those signed with Three Oaks.
Clients will receive account statements directly from qualified custodians on at least a
quarterly basis. It is highly recommended that clients carefully review the statements
provided by custodians, in addition to the statements provided by Three Oaks.
Three Oaks can establish standing letter of instructions or other similar asset transfer
authorization arrangements (“SLOA”) with qualified custodians in order for us to
disburse funds to accounts as specifically designated by the client. With a SLOA a client
can typically authorize first-party and/or third-party transfers. If transfers are third
party, Three Oaks adheres to the following 7 safeguards:
1. The client provides an instruction to the qualified custodian, in writing, that
includes the client’s signature, the third party’s name, and either the third party’s
address or the third party’s account number at a custodian to which the transfer
should be directed.
2. The client authorizes Three Oaks, in writing, either on the qualified custodian’s
form or separately, to direct transfers to the third party either on a specified
schedule or from time to time.
3. The client’s qualified custodian performs appropriate verification of the
instruction, such as a signature review or other method to verify the client’s
authorization and provides a transfer of funds notice to the client promptly after
each transfer.
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4. The client has the ability to terminate or change the instruction to the client’s
qualified custodian.
5. Three Oaks has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party
contained in the client’s instruction.
6. Three Oaks maintains records showing that the third party is not a related party
of Three Oaks Wealth or located at the same address as Three Oaks.
7. The client’s qualified custodian sends the client, in writing, an initial notice
confirming the instruction and an annual notice reconfirming the instruction.
Item 16: Investment Discretion
Three Oaks receives discretionary authority from investment management clients, as
well as some retirement plan & pension consulting services clients. This authority
allows Three Oaks to determine securities to be bought and sold for a client’s account,
the amount of securities to be bought or sold for a client’s account, and the broker or
dealer to be used for a purchase or sale of securities for a client’s account. All
investment decisions are consistent with clients’ risk and return objectives, along with
other client specific limitations as noted in their investment policy statement.
Three Oaks may act in a non-discretionary capacity for some retirement plan & pension
consulting services or other engagements. In such engagements, Three Oaks will
obtain client permission prior to effecting securities transactions in client accounts.
Item 17: Voting Client Securities
Three Oaks does not vote proxies on behalf of clients. Clients retain the responsibility
of receiving and voting proxies as they see fit.
Item 18: Financial Information
A. Three Oaks Capital does not require or solicit prepayment of more than $1,200 in fees
per client.
B. Registered investment advisers are required to disclose financial information that may
inhibit their ability to act in a fiduciary capacity or meet their contractual commitments
to clients.
16
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
ADV Part 2B: Brochure Supplement for Grant Bledsoe
Item 1: Cover Page
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
2377 Gold Meadow Way
Gold River, CA 95670
916-318-4849
September 1, 2026
Grant Bledsoe
President & Chief Compliance Officer
This brochure supplement provides information about Grant Bledsoe that supplements
the Three Oaks Capital Management, LLC DBA Three Oaks Wealth (“Three Oaks”)
brochure. You should have received a copy of that brochure. A copy of that brochure
precedes this supplement. Please contact Grant Bledsoe if the Three Oaks brochure is
not included with this supplement, or if you have any questions about the contents of this
supplement.
Additional information about Grant Bledsoe is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
Item 2: Educational Background, Business Experience, and Professional Designations
Grant was a Senior Manager and Trader in the Securities Lending group at Charles
Schwab & Co. from 2007 until 2014 and has also interned at both Smith Barney and
American Express.
Grant was born in 1983. He holds a B.S. in Applied Economics from Ithaca College,
where he graduated cum laude in 2006 with departmental honors, and minored in
Mathematics and Finance. He also holds an MBA (finance concentration, 2007) from
Ithaca College.
Grant is a CFA charter holder, a CERTIFIED FINANCIAL PLANNER™, an Enrolled
Agent, and an Accredited Investment Fiduciary™.
Chartered Financial Analyst Designation:
The CFA charter is a worldwide investment credential administered by the CFA
Institute (www.cfainstitute.org) and has become one of the most globally recognized
and respected investment designations. To become a Charter holder, candidates must
have four years of qualifying work experience, become a member of the CFA Institute,
pledge to adhere to the CFA Institute Code of Ethics and Professional Standards on an
annual basis, and complete the CFA program. The CFA program consists of three
individual six-hour examinations, with each requiring on average 300 hours of
preparatory study.
CERTIFIED FINANCIAL PLANNER™ Designation:
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with
flame design) marks (collectively, the “CFP® marks”) are professional certification
marks granted in the United States by Certified Financial Planner Board of Standards,
Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation
requires financial planners to hold CFP® certification. It is recognized in the United
States and a number of other countries for its (1) high standard of professional
education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than
71,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the
following requirements:
• Education – Complete an advanced college-level course of study addressing the
financial planning subject areas that CFP Board’s studies have determined as
necessary for the competent and professional delivery of financial planning services
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Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
and attain a bachelor’s degree from a regionally accredited United States college or
university (or its equivalent from a foreign university). CFP Board’s financial
planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning,
and estate planning;
• Examination – Pass the comprehensive CFP® Certification Examination. The
examination includes case studies and client scenarios designed to test one’s ability
to correctly diagnose financial planning issues and apply one’s knowledge of
financial planning to real world circumstances;
• Experience – Complete at least three years of full-time financial planning-related
experience (or the equivalent, measured as 2,000 hours per year); and
• Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set
of documents outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and
ethics requirements in order to maintain the right to continue to use the CFP® marks:
• Continuing Education – Complete 30 hours of continuing education hours every
two years, including two hours on the Code of Ethics and other parts of the
Standards of Professional Conduct, to maintain competence and keep up with
developments in the financial planning field; and
• Ethics – Renew an agreement to be bound by the Standards of Professional Conduct.
The Standards prominently require that CFP® professionals provide financial
planning services at a fiduciary standard of care. This means CFP® professionals
must provide financial planning services in the best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements
may be subject to CFP Board’s enforcement process, which could result in suspension
or permanent revocation of their CFP® certification.
Enrolled Agents (EAs):
An Enrolled Agent (EA) is a federally authorized tax practitioner who has earned the
privilege of representing taxpayers before the Internal Revenue Service. The
designation is granted by the U.S. Department of the Treasury and provides the highest
level of credentials awarded directly by the IRS. Enrolled Agents have unlimited
practice rights, meaning they can represent individuals, businesses, estates, and other
taxpayers before the IRS in audits, appeals, and collection matters.
To become an Enrolled Agent, candidates must either pass the IRS Special Enrollment
Examination (SEE) or qualify through prior experience as an IRS employee with relevant
tax expertise. The SEE is a comprehensive three-part exam that covers individual
taxation, business taxation, and IRS representation practices and procedures.
Applicants must also pass a background check conducted by the IRS, which includes a
review of tax compliance.
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Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
Once credentialed, Enrolled Agents are required to maintain their designation through
ongoing professional education. The IRS requires 72 hours of continuing education
every three years, including a minimum of 16 hours per year and at least two hours
focused on ethics. EAs must also adhere to the professional standards outlined in
Treasury Department Circular 230, which governs ethical conduct and practice before
the IRS.
Accredited Investment Fiduciary Designation:
The AIF Designation certifies that the recipient has specialized knowledge of fiduciary
standards of care and their application to the investment management process. To
receive the AIF Designation, the individual must meet prerequisite criteria based on a
combination of education, relevant industry experience, and/or ongoing professional
development, complete a training program, successfully pass a comprehensive, closed-
book final examination under the supervision of a proctor and agree to abide by the
Code of Ethics and Conduct Standards. In order to maintain the AIF Designation, the
individual must annually attest to the Code of Ethics and Conduct Standards and
accrue a minimum of six hours of continuing education. The Designation is
administered by the Center for Fiduciary Studies, the standards-setting body of fi360.
Item 3: Disciplinary Information
Investment Advisers
(RIAs) and
Principals of Registered
Investment Adviser
Representatives (IARs) are required to disclose the facts of any legal or disciplinary events
that are material to a client’s evaluation of their business practices or integrity. Grant
Bledsoe has no events to disclose.
Item 4: Other Business Activities
Grant Bledsoe is also the founder and owner of Three Oaks Tax. He spends approximately
5% of his working hours in this role.
Item 5: Additional Compensation
Grant Bledsoe does not receive any economic benefit from any person, company, or
organization in exchange for providing clients advisory services through Three Oaks
Capital Management, LLC DBA Three Oaks Wealth.
Item 6: Supervision
Grant Bledsoe, as president and Chief Compliance Officer of Three Oaks Wealth, is
responsible for supervision. He may be contacted at the phone number on this brochure
supplement.
20
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
ADV Part 2B: Brochure Supplement for Bethany Ely
Item 1: Cover Page
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
2377 Gold Meadow Way
Gold River, CA 95670
916-318-4849
September 1, 2026
This brochure supplement provides information about Bethany Ely that supplements the
Three Oaks Capital Management, LLC DBA Three Oaks Wealth (“Three Oaks”) brochure.
You should have received a copy of that brochure. A copy of that brochure precedes this
supplement. Please contact Grant Bledsoe if the Three Oaks brochure is not included with
this supplement, or if you have any questions about the contents of this supplement.
Additional information about Bethany Ely is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
Item 2: Educational Background, Business Experience, and Professional Designations
Bethany Ely
Year of Birth: 1978
Education Experience:
• Certificate, Personal Financial Planning Program, UC Irvine, 2021
• M.A., Teaching English to Speakers of Other Languages, CSU Sacramento, 2006
• B.B.A., International Marketing, SUNY Baruch, 2000
Professional Experience:
• Financial Planning Specialist, Trinity Wealth Advisors/Ameriprise, 2022
• Paraplanner, Twin Rivers Wealth Management, 2022
• Extern, Financial Planning Virtual Externship, 2022
• Transaction Coordinator, Witham Real Estate, 2018 – 2023
• Coordinator, Capital Adult Education Regional Consortium, 2016 - 2021
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
Bethany Ely is also an employee of Three Oaks Tax, Inc. She spends less than 5% of her
working hours in this role.
Item 5: Additional Compensation
None
Item 6: Supervision
Bethany Ely is supervised by Grant Bledsoe, President. Grant reviews Bethany’s work
through frequent office & remote interactions as well as activity reviews through our
financial planning and client relationship management systems. Grant can be reached at
916-318-4849.
22
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
ADV Part 2B: Brochure Supplement for Karmjit Bath
Item 1: Cover Page
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
2377 Gold Meadow Way
Gold River, CA 95670
916-318-4849
September 1, 2026
This brochure supplement provides information about Karmjit Bath that supplements the
Three Oaks Capital Management, LLC DBA Three Oaks Wealth (“Three Oaks”) brochure.
You should have received a copy of that brochure. A copy of that brochure precedes this
supplement. Please contact Grant Bledsoe if the Three Oaks brochure is not included with
this supplement, or if you have any questions about the contents of this supplement.
Additional information about Karmjit Bath is available on the SEC’s website at
www.adviserinfo.sec.gov.
23
Three Oaks Capital Management, LLC DBA Three Oaks Wealth
Form ADV Part 2
Item 2: Educational Background, Business Experience, and Professional Designations
Karmjit Bath
Year of Birth: 1999
Education Experience:
• Master’s in Business Administration – California State University Stanislaus (2022)
• Bachelor of Science in Business Administration – California State University
Stanislaus (2020)
Professional Experience:
• 08/2026 – Present: Three Oaks Wealth, Associate Financial Planner
• 04/2025 – 08/2026: MLOA
• 08/2024 – 05/2025: TOR Wealth Advisor, Paraplanner / Financial Analyst
• 05/2023 – 01/2025: Intel Corporation, Financial Analyst
• 05/2022 – 08/2022: Intel Corporation, Financial Analyst Intern
• 06/2020 – 08/2020: G3 Enterprises, Logistics Financial Analyst Intern
• 02/2019 – 08/2019: E&J Gallo Winery, Finance/Accounting Intern
• 08/2016 – 08/2019: Unemployed
Item 3: Disciplinary Information
None.
Item 4: Other Business Activities
None.
Item 5: Additional Compensation
None
Item 6: Supervision
Karmjit Bath is supervised by Grant Bledsoe, President. Grant reviews Karmjit’s work
through frequent office & remote interactions as well as activity reviews through our
financial planning and client relationship management systems. Grant can be reached at
916-318-4849.
24