Oakmont Capital Management, LLC is an investment advisor registered with the Securities Exchange Commission. It was founded in 2002 and is a limited liability company organized under the laws of the Commonwealth of Pennsylvania. The Firm and its representatives have three primary offerings: (1) Investment Management and Wealth Services (2) Family Office Services (3) Institutional Consulting Prior to Oakmont Capital rendering any of these services, Clients are required to enter into one or more written agreements with Oakmont Capital that set forth the relevant terms and conditions of the advisory relationship (the “Investment Management Agreement”). The following is a description of the three services, who they are offered to, and how they are administered. Investment Management Services When acting as an Investment Manager, Oakmont Capital renders investment advisory services to Clients on an independent and collegial basis with its actions being governed by the risk/return objectives of the Client, as well as the terms and conditions of the Investment Management Agreement. The trading authority of Oakmont Capital often includes, but is not limited to, the buying and selling of individual securities, the re- investment of dividends/interest, and the deployment of cash balances. Typically, other than the withdrawal of the investment advisory fee as described in Item 5. of this Brochure, Oakmont Capital does not have the discretion or authority to withdrawal, possess, or contribute additional assets to an investment account. When implementing an investment strategy, Oakmont Capital cannot guarantee success. Clients should be aware that all forms of investing have the potential for loss, including their initial principal amount. Risk/return investment objectives, capital market assumptions, and portfolio size help determine the proper investment strategy for a Client. Typically, both active1 and passive2 investment styles are considered in the process. Depending on Client preferences, portfolios can be managed in relation to a blended benchmark, a specific return level, or an expected level of inflation. When appropriate, an Investment Policy Statement (“IPS”) is drafted to help guide the investment process and relationship expectations. It typically outlines the portfolio constraints, liquidity considerations, and performance standards. It is considered a “living” document and can be updated to accommodate changes that affect how the portfolio is managed. A properly written IPS can provide an effective framework for making prudent investment decisions. Clients are encouraged to notify Oakmont Capital promptly regarding any material changes to their financial circumstances and/or investment preferences. These changes, when appropriate, can be incorporated by amending the IPS. Depending on the needs and desires of the Client, Oakmont Capital can also provide financial planning as part of the investment advisory services offered. A financial plan typically addresses any or all of the following areas: retirement planning, financial budgeting, debt management, charitable giving, educational savings, cash flow management, tax analysis, and estate design considerations. 1 An active investment strategy attempts to outperform a specific index or target return through security selection and other trading activities. 2 A passive investment strategy tracks and replicates the performance of a specific index. To prepare a financial plan, Oakmont Capital will gather information through Client discussions, document reviews, and modeling. These activities help Oakmont Capital prepare a financial profile of the Client, identify any future objectives, and the amount of investment risk a Client is willing to assume. If a Client chooses to implement a financial plan designed by Oakmont Capital, they are encouraged to work closely with an attorney, accountant, insurance agent, and/or other relevant professionals to review the appropriateness of the plan and recommendations. The implementation of the plan is at the sole discretion of the Client. Family Office Services Oakmont Capital assists families in developing investment programs to meet the wealth needs of both current and future generations while accommodating the existing business and philanthropic initiatives of the family. In many instances, Oakmont Capital acts as the family’s Outsourced Chief Investment Officer (“OCIO”) and collaboratively integrates investment advisory services into the accounting, legal, and financing infrastructure of the family. When appropriate, the use of both public and private securities are incorporated in the portfolio design process. The Family Office services offered by Oakmont Capital are customizable and are governed by an Investment Management or Consulting Agreement. This agreement can be terminated at any time with written notification. The other party will consider the termination effective upon receipt of the written notification. Institutional Consulting Oakmont Capital offers consulting services to institutions and retirement plans through a Consulting Agreement. The services include, but are not limited to: ▪ Discretionary and non-discretionary management of investable assets ▪ Advice on fiduciary policies, procedures, and objectives ▪ Outsourced Chief Investment Officer (OCIO) services ▪ Asset allocation design and implementation ▪ Drafting and monitoring of an Investment Policy Statement ▪ Spending policy design and management ▪ Consolidated performance reporting ▪ Due diligence and fee negotiations of service providers ▪ Return pattern management and hedging programs ▪ Topic specific research (real estate, private equity, hedge funds, etc.) ▪ Trustee training and education. When Oakmont Capital provides consulting services to retirement plans or similar investment programs, the authorized representative designated by the governing documents of the entity (e.g., the plan sponsor, trustee, or named fiduciary) will (i) make the decision to retain Oakmont Capital; (ii) agree to the scope of the services that Oakmont Capital will provide; and (iii) in the absence of any discretionary arrangements, make the ultimate decision as to accept any of the recommendations that Oakmont Capital provides. The authorized representatives or plan fiduciaries are free to seek independent advice about the appropriateness of any recommended action or service. The Client or Oakmont Capital is entitled to terminate the Consulting agreement at any time with written notification. The other party will consider the termination effective upon receipt of the written notification. Zoe Wealth Management Platform via the Apex Clearing Corporation Oakmont Capital has contracted with Zoe Financial, Inc. (“Zoe Financial”), an unaffiliated investment advisory firm, to provide access to the Zoe Wealth Management Platform (“Platform”) via the Apex Clearing Corporation (“Apex”), an unaffiliated SEC-registered broker-dealer. The Platform consists of technology and systems that support online account management, portfolio administration, and trading services for Clients. Oakmont Capital offers both automated and non-automated investment programs through the Platform. Within these programs, Clients are invested in a range of investment strategies and/or models as designed or identified by Oakmont Capital consisting of various allocations to exchange-traded funds, individual securities, mutual funds, and/or cash equivalents. When participating in the Platform, Client brokerage accounts are opened and maintained by the Client at Apex. Oakmont Capital is independent of, not owned by, or supervised by Zoe Financial or Apex. Oakmont Capital is the primary point of contact with respect to the Platform, however the staff of Zoe Financial may support the Client and/or Oakmont Capital as administratively

needed. Furthermore, Oakmont Capital is responsible for determining the appropriateness of the Platform for the Client, choosing a suitable investment strategy in relation to the risk/return objectives of the Client, and managing the investment account on an ongoing basis. The Platform also provides Oakmont Capital with access to a software engine in which Oakmont Capital can manage the Client investment account with automatic rebalancing, tax-loss harvesting, and/or partial share trading capabilities. However, for the software engine to be applied to a client investment account in part or its entirety, the Client needs to be eligible and deemed appropriate at the discretion of Oakmont Capital. Attorney and Accounting Firm Arrangements Oakmont Capital has negotiated arrangements with certain law and accounting firms under which Oakmont Capital has agreed to cover the costs of certain professional services provided by these firms to current Clients. The cost of these services is paid from the advisory fees collected by Oakmont Capital. No Client is obligated to engage these professionals or to receive their covered legal and/or accounting services. The opportunity to receive these services is generally open to Investment Management, Family Office, and Institutional Consulting Clients with a minimum annual fee paid to Oakmont Capital of $10,000 or greater. The minimum annual fee required for eligibility is subject to negotiability at the discretion of Oakmont Capital, and the Client can terminate the services provided by these firms at any time with written notification to the legal and/or accounting firm. Ownership and Control of Oakmont Capital Management, LLC As a limited liability company, Oakmont Capital is owned by two individuals. Mr. Koteski is the acting Managing Member. No other member directly or indirectly controls the Firm. Mr. Koteski acquired the Managing Member title in June 2002 and his CRD # is 2765692. He owns greater than 78% of the outstanding interests in the Firm. The other member has a non-controlling interest and does not participate in the day-to-day operations of the Firm. Types of Investments Oakmont Capital will offer advice on various types of investments including, but not limited to, the following: ▪ Equity securities (exchange traded or over-the-counter listed) ▪ Investment company securities (mutual funds, collective investment trusts, etc.) ▪ Corporate debt securities (investment grade and non-investment grade) ▪ Certificates of deposit and commercial paper of various institutions ▪ Local and state municipal securities ▪ Exchange traded funds (ETF’s) ▪ Mortgage and asset backed securities ▪ United States government or agency securities ▪ Option contracts on securities, indices, and/or commodities ▪ Warrants and Restricted Stock Units (RSU’s) ▪ Private partnerships or investment funds including venture capital, private equity, hedge funds, real estate, commodity, oil & gas, etc. ▪ Any other type of investment deemed suitable or held in a Client portfolio. Depending on the situation, Oakmont Capital will advise or analyze a security based upon it being a stand- alone investment and/or part of a diversified or concentrated portfolio. Clients have the ability to impose restrictions on the type of securities Oakmont Capital is permitted to purchase on their behalf by providing any such restrictions to Oakmont Capital in writing. The Client can add or remove these restrictions as needed or desired. Oakmont Capital does not participate in any wrap fee programs. As of December 31, 2023, Oakmont Capital had approximately $528,412,608 in assets under management, with $135,044,993 being non-discretionary and $393,367,615 being discretionary. When Acting as an Advisor to Retirement Plan Participants or Outside Accounts Oakmont Capital can advise a participant within a retirement plan. When a Client or prospective Client are separating from service from an employer and are covered by a retirement plan, they are typically presented with four options: (i) leaving their assets with the employer plan, (ii) rolling over the assets into a new employer’s plan, (iii) rolling over the assets into an Individual Retirement Account (“IRA”), or (iv) cashing out the account (which could result in tax consequences and/or penalties). Oakmont Capital can recommend that a Client rolls over the assets into an IRA in which Oakmont Capital receives an asset-based or fixed fee. Conversely, if a Client or prospective Client chooses to leave the assets with their former employer or roll them into a new employer plan, Oakmont Capital does not receive any compensation or the compensation can be lower than if the Client rolls the assets into an IRA managed by Oakmont Capital. Therefore, Oakmont Capital has an economic incentive to encourage a Client or prospective Client to rollover the assets into an IRA managed by the Firm. Oakmont Capital considers a variety of factors before recommending a rollover, including but not limited to: available fees and expenses, investment options, penalty-free withdrawals, creditor and judgment protection, employer stock appreciation, and required minimum distributions. No Client is under any obligation to rollover plan assets into an IRA or to engage Oakmont Capital. Clients and prospective Clients considering a rollover from a qualified employer-sponsored retirement plan to an IRA, or from an IRA to another IRA, are encouraged to consider and investigate the factors for both advantages and disadvantages of the rollover action. Pursuant to Department of Labor regulations, Oakmont Capital is required to acknowledge in writing its fiduciary status under Section 3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”), as applicable. When Oakmont Capital provides investment advice to a Client regarding a retirement plan or IRA, the Firm and its representatives are a fiduciary within the meaning of Title I of ERISA and the Code, as applicable. If a Client account is maintained on behalf of or in connection with a qualified employer-sponsored retirement plan subject to ERISA, as amended, or similar government regulation, pursuant to which the Client has sole authority to direct the investment thereof, Client acknowledges and understands that the investment discretion of Oakmont Capital will be limited to the investment alternatives provided by the plan and that Oakmont Capital will have no duty, responsibility, or liability for plan assets that are not included in the Client account. The Client also agrees to furnish Oakmont Capital with a copy of the documents governing the plan upon request. In the event that the plan sponsor or custodian will not permit Oakmont Capital direct access, the Client will provide Oakmont Capital with the password and/or log-in information to effectuate any transactions in the individual account of the Client pertaining to such plan. Oakmont Capital may only accept the Client’s password and/or log-in information for the sole purpose of effecting transactions in the Client’s account, and Oakmont Capital will not have, nor will it accept, any authority to effectuate any other type of transactions or changes, including but not limited to, the changing of beneficiaries or effecting account disbursements or transfers to any 3rd party or entity. The provision of the password and/or log-in information by the Client to Oakmont Capital shall constitute authorization by the Client for Oakmont Capital to access the individual account of the Client within the plan. Client further acknowledges and understands that Oakmont Capital will not receive any communication from the plan sponsor or custodian, and it shall remain the exclusive obligation of the Client to notify Oakmont Capital of any changes or restrictions pertaining to the individual account of the Client.