Business Description Bull Oak Capital is a San Diego, California based registered investment adviser. As a registered investment adviser, we are held to the highest standard of client care – a fiduciary standard. As a fiduciary, we always put our client’s interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities and all transactions are sent to our qualified custodian which executes, compares, allocates, clears, and settles them. Our custodian also maintains our clients’ accounts and may grant clients access to them. We provide investment advisory and financial planning services to individuals and high-net-worth individuals. A. Description of the Advisory Firm Bull Oak Capital LLC (hereinafter “Bull Oak”) is a Limited Liability Company organized in the State of California. The firm was formed in January 2014 and the principal owner is Ryan Anthony Hughes. B. Types of Advisory Services Bull Oak Capital offers personalized investment advisory services to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Advisory services including financial planning, consulting, selection of sub-advisers, and portfolio management services, may be offered to clients on an all-inclusive or individual basis, as part of an annual retainer program. The process typically begins with an initial consultation during which the various services provided by Bull Oak Capital are explained. If it is the desire of the client to use the firm’s services, Bull Oak Capital and the client will determine the scope of the services to be provided. Financial Planning and Consulting Services Financial planning services will typically involve providing a variety of services, principally advisory in nature, to clients regarding the management of their financial resources based upon an analysis of their individual needs. Bull Oak will offer complimentary tax planning, tax preparation, and estate planning services through third party services and software systems. Bull Oak will also conduct a complimentary initial consultation. After the initial consultation, if the client decides to engage Bull Oak for financial planning services, pertinent information about the client’s financial circumstances and objectives are collected and such information will be reviewed and analyzed. A written financial plan – designed to achieve the clients' stated financial goals and objectives – will be produced and presented to the client. The primary objective of this process is to allow Bull Oak to assist the client in developing a strategy for the successful management of income, assets, and liabilities in meeting the client’s financial goals and objectives. Clients should be aware that different financial planning software uses different financial planning methodologies, and the financial plan will describe the specific methodologies used for the particular plan and should be carefully considered in evaluating the results presented to the client. The analysis contained in the financial plan is conducted using Elements, Right Capital, Holistiplan, and other financial planning software systems. The outputs generated by the software utilize third-party proprietary formulas and are based on economic assumptions and forecasts approved by Bull Oak. In addition, clients’ financial plans may include a

Monte Carlo simulation. Monte Carlo simulations are used to show how variances in rates of return each year can affect results. Results using Monte Carlo simulations indicate the likelihood that an event may occur as well as the likelihood that it may not occur. Bull Oak may change the software, third- party provider, or the methodologies it uses when creating your financial plan. Your financial plan will provide details on the software and methodologies used. Portfolio Management Services Bull Oak offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Bull Oak creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Bull Oak evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Bull Oak will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Bull Oak seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Bull Oak’s economic, investment, or other financial interests. To meet its fiduciary obligations, Bull Oak attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Bull Oak’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Bull Oak’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments Bull Oak generally limits its investment advice to ETFs. However, it may also include equities, mutual funds, fixed income securities, ETPs, and treasury inflation protected/inflation-linked bonds. Bull Oak may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Bull Oak offers the same suite of services to all of its clients. However, specific client investment strategies 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). Clients may not impose restrictions in investing on certain securities or types of securities in accordance with their values or beliefs. 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 other administrative fees. Bull Oak does not participate in any wrap fee programs. E. Assets Under Management As of December 31, 2022, Bull Oak managed $121,586,357 in total assets, all of which were on a discretionary basis.