OAS was incorporated on June 14, 1969 and offers investment advisory services, in accordance with the terms of an
advisory or planning agreement, to individual, small business and institutional clients, including employee benefit plans,
most of which it expects to be derived from its current customer base as a SEC registered broker-dealer and Financial
Industry Regulatory Authority (“FINRA”) member firm or from its parent company, American United Life Insurance
Company (“AUL”), an Indiana insurance company. Those services principally involve suitable financial planning and
discretionary asset management services in accordance with the investment objectives, guidelines, and restrictions
determined and developed by its clients and, in some cases, with the assistance of the Investment Advisor
Representative (“IAR” or “Advisor Representative”). The Firm has a nationwide network of IARs who are typically dually
registered representatives of OAS.
Due to the independent nature of the Firm’s business model, Advisor Representatives are able to structure the services
offered to clients in many different ways, all of which are dependent upon client suitability and investment objectives. For
all the Programs described, the Firm may provide customized investment advisory and administrative services to its
clients, but it does not maintain custody of the individual funds or other assets owned by each client.
Independent Third-Party Investment Advisers
OAS has relationships with multiple Third-Party Asset Management Program (“TAMP”) sponsors. IARs gather information
about the client and then assist in the selection of the TAMP. Additionally, IARs monitor the activity in the account and
meet with the clients to discuss results and update changes in the client’s situation or objectives. OAS receives asset-
based fees for referring clients to the independent investment advisors. A separate Form ADV 2 for the selected TAMP is
required to be provided to the client by the IAR. Clients wishing to obtain more information about the selected TAMP
should consult the Form ADV 2 provided.
Portfolio Choice Program
OAS offers investors a variety of different investment management programs, each particularly suited to individual needs.
These programs are offered through an arrangement with Envestnet Incorporated (“Envestnet”), Sawtooth Solutions, LLC
(“Sawtooth”) and Lockwood Advisors, Inc. (“Lockwood”) collectively referred to herein as “Account Managers”. The
Account Managers are registered investment advisors who offer investment advisory and investment management
programs to the Firm’s clients. Each program listed below has its own official disclosure document, Appendix 1, that
describes all fees and services. For additional information, please refer to Appendix 1.
Envestnet and Lockwood Discretionary Management Programs
OAS sponsors and offers to its clients Discretionary Management Programs through an agreement
between OAS and Account Managers. OAS performs the introducing brokerage services and its Advisor
Representatives do not have discretionary investment authority in the accounts under this program. The
Account Managers have discretionary authority to supervise and direct all monies contributed by the
client, but they must act in accordance with the client’s investor profile, which includes, but is not limited,
to the consideration of liquidity needs, risk tolerance, and account objectives. Separate disclosure
statements for the Account Managers are provided to the client by OAS.
Discretionary Management Programs at Envestnet and Lockwood are wrap fee programs, whereby the
management fee and the administrative fee are combined. All additional costs, which include but are not
limited to costs for custody, clearing, ticket charges, commissions, transactions, and execution
(collectively “Brokerage Fees”) charged by the clearing firm, Pershing LLC (“Pershing”), are covered by
OAS and are not incurred by the client. Pershing also charges an account maintenance fee that the client
will pay on an annual basis. Discretionary Management Programs at Sawtooth may have alternate fee
structures.
Separately Managed Account (“SMA”) Programs
OAS sponsors and offers to its clients Separately Managed Account Programs through agreements
between OAS and the Account Managers. OAS performs the introducing brokerage services and its
Advisor Representatives do not have discretionary investment authority in the accounts under this
program. Such programs include sub-accounts of the client’s account managed by registered investment
advisors (“Separate Account Managers”) selected by one of the Account Managers. All Separate Account
Managers are entered in sub-advisory contracts with the Account Managers. The Account Managers
have discretionary authority to select the Separate Account Managers to be utilized in managing the
client’s assets. The Separate Account Managers have discretionary authority to direct the investment of
the assets under this program. Separate disclosure statements for the Account Managers and Separate
Account Managers are provided to the client by OAS.
Separately Managed Account Programs at Envestnet are wrap fee programs whereby the management
fee and the administrative fee are combined. Brokerage Fees charged by the clearing firm, Pershing, are
covered by OAS and are not incurred by the client. Pershing also charges an account maintenance fee
that the client will pay on an annual basis. Separately Managed Account Programs at Sawtooth may have
alternate fee structures.
Unified Managed Account (“UMA”) Programs
OAS sponsors and offers to its clients Unified Managed Account Programs through an agreement
between OAS and the Account Managers. OAS performs the introducing brokerage services and its
Advisor Representatives do not have discretionary investment authority in the accounts under this
program. The Account Managers have discretionary authority to supervise and direct all monies
contributed by the client, but they must act in accordance with the client’s investor profile, which includes,
but is not limited, to the consideration of liquidity needs, risk tolerance, and account objectives. Separate
disclosure statements for the Account Managers are provided to the client by OAS. UMA programs
include mutual funds, exchange-traded funds (“ETFs”), stocks, and bonds selected by the Account
Managers based on information submitted by the client to OAS.
Under this program, the Account Managers act as a Unified Managed Account manager (“UMA
Manager”). The Account Managers have arrangements with certain other registered investment advisors
who have agreed to act as third-party providers of research services (“Research Providers”). Under the
UMA programs managed by the Account Managers, Research Providers provide the Account Managers
with purchase and sale recommendations in the form of model portfolios. Generally, the Account
Managers manage assets in accordance with the specific investment strategies of the Research
Providers that have been
selected by the UMA Manager for use in its various UMA Programs.
Unified Managed Account Programs at Envestnet are wrap fee programs whereby the management fee
and the administrative fee are combined. Brokerage Fees charged by the clearing firm, Pershing, are
covered by OAS and are not incurred by the client. Pershing also charges an account maintenance fee
that the client will pay on an annual basis. Unified Managed Account Programs at Sawtooth may have
alternate fee structures.
AssetMark Advisor Managed Portfolios (“AMP”)
OAS offers the AMP platform to its clients. AMP is an open architecture, discretionary program for which OAS IARs serve
as the Account Managers on a discretionary basis. OAS IARs have discretionary authority to supervise and direct all
monies contributed by the client, but they must act in accordance with the client’s investor profile, which includes, but is
not limited to, the consideration of liquidity needs, risk tolerance, and account objectives. AMP programs include stocks,
bonds, mutual funds, and ETFs selected by OAS IARs based on information submitted by the client to OAS.
AMP is a wrap fee program whereby the management fee and the administrative fee are combined. Depending on the
account registration and/or the investments held within the account, Brokerage Fees may be charged by the custodian
selected by the client through consultation with the IAR. The custodian may also charge an account maintenance fee that
the client will pay on an annual basis.
The wrap program has its own official disclosure document (Appendix 1) that describes all fees and services. For
additional information, please refer to the Appendix 1.
Financial Planning
Financial planning services offered through OAS include the creation of financial plans and consultations. Following a
thorough financial review, a plan will include a detailed analysis and recommendations. Consultations are provided for
specific, targeted areas and include a written statement of observations and/or recommendations.
Employer-Sponsored Retirement Plan Consulting Services
OAS offers consulting and advisory services to employer-sponsored retirement plans. It may also assist employers by
providing plan enrollment and investment education to plan participants and beneficiaries. Prior to opening a Retirement
Plan account, a Retirement Plan Consulting Agreement (“Agreement”) must be completed by the plan sponsor
(“Sponsor”). The purpose of the Agreement is to collect certain information concerning plan design, plan objectives and
third-party service providers. Once completed, OAS will deliver a copy of the Agreement and applicable disclosures to the
Sponsor. The Sponsor must indicate the desired services in the Agreement and review the Agreement and disclosures to
determine the services are necessary and the compensation is reasonable prior to executing the Agreement.
Under limited circumstances and pursuant to a written agreement, OAS will provide certain services as a fiduciary under
the Employer Retirement Income Security Act of 1974, as amended (“ERISA”) to employer-sponsored retirement plans.
ERISA fiduciary services offered by OAS are limited to only include:
Investment Manager Selection and Monitoring Support Services:
OAS may provide recommendations and advice designed to assist the Sponsor in selecting and monitoring a
discretionary investment manager (“Manager”) as defined under Section 3(38) of ERISA. The Manager, and not OAS, will
be solely responsible to work with the Sponsor to develop an appropriate investment policy statement (“IPS”) and to select
and monitor the plan’s designated investment alternatives that are consistent with the objectives of the IPS. The Manager
may also make available model asset allocation portfolios for plan participants.
In assisting the Sponsor, OAS may make recommendations that are, among other things, based upon the Manager’s
style, process and investment guidelines; manager specific impact; survey data; and fee analysis. The Sponsor will have
the final approval on the hiring and/or retention of any Manager recommended by OAS.
Upon request, OAS may further assist the Sponsor with collecting and evaluating information relating to the ongoing
monitoring of the Manager, including the reasonableness of the Manager’s fees and to benchmark the Manager’s overall
performance vis-à-vis applicable, recognized industry indices.
OAS may also provide the following administrative and/or ministerial functions to employer sponsored retirement plans,
for which it will not be considered to be a fiduciary under ERISA:
Plan Governance Review and Committee Support:
OAS may assist the Sponsor with the establishment and maintenance of the plan committee and will recommend
protocols designed to help the Sponsor manage and administer the plan. The Sponsor is solely responsible for
appointing or removing plan committee members; however, OAS may educate plan committee members about their
fiduciary duties, help the plan committee coordinate regular meetings and assist the plan committee with maintaining a
fiduciary audit file.
Vendor Management:
OAS may assist the Sponsor with selecting and monitoring the plan’s service providers. OAS may use third-party tools
and publicly available data to assist the Sponsor with benchmarking the fees charged by a service provider. The Sponsor
retains decision-making authority to select, remove and/or replace the plan’s service providers.
Employee Enrollment and Investment Education:
OAS may conduct periodic group enrollment and education meetings with employees and educational meetings with plan
participants and beneficiaries. OAS will utilize standardized materials that are consistent with “investment education,” as
that term is defined in Department of Labor Interpretative Bulletin 96-1, in connection with providing Employee Enrollment
and Investment Education services. Such information may include information about the benefits of plan participation,
investment objectives of plan investment options, general financial and investment information, asset allocation portfolios
of hypothetical individuals with different time horizons and risk profiles and interactive investment materials such as
questionnaires to assess the impact of different allocations on retirement income. OAS may also provide interactive
investment materials to assist participants in assessing their future retirement income needs. In providing Employee
Enrollment and Investment Education services, OAS will not provide any “investment advice” as that term is defined in
ERISA and will, therefore, not be acting as an ERISA fiduciary in rendering such services.
Self-Directed Brokerage Account (“SBDA”) Education
Where a qualified retirement plan contains a company stock or SDBA investment option, OAS will not be required to take
such investment options into account with respect to its determinations or recommendations. Plan fiduciaries will retain
sole fiduciary responsibility with respect to such company stock or SDBA option.