Oak City Consulting, LLC (referred to herein as “Oak City Consulting,” “OCC,” the “Adviser,” “Company,” the “Firm,” “we,” “us” or “our”), a North Carolina limited liability company, is an investment adviser that is registered with the U.S. Securities and Exchange Commission (the “SEC”) pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Company has been registered with SEC since March 11, 2012, and is based in Wake Forest, North Carolina. Ross Roggensack serves as Managing Member, Chief Executive Officer and Chief Investment Officer. Melissa Clapp Smith serves as Managing Member and Christie Baucom serves as Chief Compliance Officer. Advisory Services Oak City Consulting’s portfolio management and investment advisory services are offered to individual separate accounts, foundations, Christian endowments, charitable organizations and families (each a “Client” and collectively, “Clients”). In addition, the Company is engaged in licensing as an index provider to Exchange Traded Funds (“ETFs”). Currently Oak City Consulting owns, develops and sponsors one index (the “Index Provider”), namely, the Emerging Markets Human Flourishing Index (“the Index”). The types of Clients to which Oak City Consulting provides investment management services are more fully disclosed in Oak City Consulting’s Form ADV Part 1 and summarized in Item 7 – Types of Clients of this Brochure. Our purpose is to provide institutional investment consulting to Christian endowments, foundations, and families in order to build His Kingdom by submitting to proper stewardship, practicing humility, and becoming good servants to our Clients. We have worked with Christian institutions and families for over twenty (20) years. The Firm strives to implement a Biblically Responsible Investing overlay into investment strategies whenever feasible. Biblically Responsible Investing works to integrate Scriptural guidelines within an investment portfolio. This method looks for companies to invest in that are making a positive impact on our society, as well as applying screening processes to avoid those that do not. If a company traded on a public exchange is publicly known to violate Biblical principles, Biblically Responsible Investing strives to stay clear from buying those companies directly through a separate managed account or indirectly through mutual funds and ETFs. Oak City Consulting uses third party sources and internal processes to screen investments. The Firm recommends, on occasion, redistributing investment allocations to diversify the portfolio. We recommend specific positions to increase sector or asset class weightings and employing cash positions as a possible hedge against market movement, which has the ability to adversely affect the portfolio. Oak City Consulting may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Oak City Consulting will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. At no time will Oak City Consulting accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account pursuant to the Client Investment Advisory Agreement. In all cases, Clients have a direct and beneficial interest in their securities, rather than an undivided interest in a pool of securities. We do have limited authority to direct the Custodian to deduct our investment advisory fees from your accounts, but only with the appropriate written authorization from clients. You are advised and are expected to understand that our past performance is not a guarantee of future results. Certain market and economic risks exist that adversely affect an account’s performance. This could result in capital losses in your account. Selection of Sub-Advisers For certain strategies, Oak City Consulting outsources a portion of the investment selection to independent professional asset managers, who are not affiliated with Oak City Consulting, who serve as sub-advisers (“Sub-Adviser”). These independent professional Sub-Advisers are Mutual Fund, Exchange Traded Fund (“ETF”), and/or Private/Alternative (when applicable) Investment Managers. Similarly, the Firm outsources a portion of the investment selection to independent professional asset managers, that are not Mutual Funds, ETFs, etc. (e.g., independent boutique investment advisers managing multi-asset alternative strategies). Prior to referring any Clients to Sub-Advisers, OCC will make sure that they are registered, or notice filed. A Sub-Adviser’s responsibility varies and may include the authority to:
• exercise discretion to determine the types of securities bought and sold, along with the percentage allocation;
• apply their discretion on when to buy and sell;
• apply their discretion on the timing of transactions;
• select the broker-dealer for execution of securities transactions, if appropriate;
• vote proxies; and
• take other portfolio management actions that Oak City Consulting delegates or deems appropriate. As part of the discretionary investment management agreement the Client executes with Oak City Consulting, the Client provides Oak City Consulting with a limited power of attorney over the Client’s assets that are invested through Sub-Advisers. The limited power of attorney grants Oak City Consulting the right to receive certain documents from the Sub-Adviser on the Client’s behalf, including but not limited to, prospectuses, shareholder reports, privacy notices, proxies and the Sub-Adviser’s Form ADV Part 2A. This limited power of attorney granted by the Client may be rescinded at any time upon written notice (email will suffice) from the Client to Oak City Consulting. The manager is selected by matching their investment strategy and risk profile with a Client’s risk profile and stated investment needs and objectives. The money managers selected under these programs will have discretion to determine the securities they buy and sell within the account, subject to reasonable restrictions imposed by Clients. The selection of the securities and the investment decisions are made in accordance with the Client Profile and/or Investment Policy Statement (“IPS”) we complete with a Client and their objectives and risk tolerance. The Mutual Fund, ETF, SMA, and/or Private/Alternative (when applicable) Investment Manager enables Clients to pursue their investment objectives with the Firm as manager all in one consolidated portfolio. Oak City Consulting actively monitors the performance of the selected manager and may recommend a change in the manager when and if we believe such a change would be in a Client’s best interest. The Client will enter into a separate management agreement with the SMA manager. The agreement you enter into with the Mutual Fund, ETF, SMA, and/or Private/Alternative (when applicable) Investment Manager will disclose the fees a Client will pay to them for the management of the account. The Company employs investment advice that is primarily based on the analysis of investment programs and separate account managers by reviewing the background of the managers, their investment process, investment philosophy, methodology, stability of the managers, referrals, historical performance, and disclosure documents. We may perform research on various programs through third-party resources such as Zephyr Portfolio Analytics (“Zephyr”), a research solution offered through Informa Intelligence, Inc. Zephyr is a comprehensive data base comprising the universe of separately managed accounts, which provides us with research tools we use in our selection and recommendation of managers. We also perform our own due diligence on managers and may use publicly available resources as sources of information while conducting our research. Upon request, Oak City Consulting will provide Clients with information about any Sub-Adviser appointed by Oak City Consulting. This information may include content provided by a Sub-Adviser explaining its investment style, or an explanation from Oak City Consulting describing the Sub-Adviser’s investment style. Additionally, Oak City Consulting will provide Clients with a copy of the Sub-Adviser’s Form ADV Part 2A upon request. Private Fund and Alternative

Investment Managers Oak City Consulting offers Clients access to certain alternative investments. Clients should understand that an alternative investment strategy is subject to a number of risks and is not suitable for all investors. Alternative investments are generally classified as an investment other than a traditional stock, bond, mutual fund or exchange traded fund. Alternative investments include hedge funds, private equity funds, venture capital funds, private real estate funds and other private investments. Investing in alternative investments is only intended for experienced and sophisticated investors who are willing to bear the high economic risk associated with such an investment. By themselves, alternative investments do not constitute a balanced investment program. Clients should carefully review and consider potential risks before investing, including carefully reviewing all disclosure documents, private offering memoranda, prospectuses, or other offering materials provided by Oak City Consulting and any separate manager or third-party service provider of an alternative investment. Many alternative investment offering documents are not reviewed or approved by federal or state regulators. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of each Client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each Client on a one-on-one basis through interviews and questionnaires to determine the Client’s investment objectives, risk tolerance and suitability information. Furthermore, when the Company serves as investment adviser, it enters into a written investment management agreement with each of its advisory Clients. Investment management agreements include provisions related to each Client’s management fees, investment strategy, investment guidelines, termination rights, proxy voting and sub-adviser, if applicable. Licensing Services as an Index Provider to ETFs The Company is engaged in licensing as an index provider to Exchange Traded Funds (“ETFs”). Currently Oak City Consulting owns, develops and sponsors one index (as “Index Provider”), namely, the Emerging Markets Human Flourishing Index (the “Index”). The Index is constructed to track the performance of companies within emerging market countries that sufficiently promote human flourishing. The essence of human flourishing is that all humans are worthy of being treated with dignity and respect. To be eligible for inclusion in the Index, a security must be a constituent of the Bloomberg Emerging Markets Large & Mid Cap universe and be issued by a company domiciled in a country that has a sufficient “Human Dignity Score." The Index Provider also applies additional size and liquidity screens to ensure that the Index is composed of securities that are sufficiently liquid for inclusion in an ETF. The Index Provider uses data from Freedom House to determine a country’s Human Dignity Score, which is used in the security screening process described in Item 8 – Methods of Analysis, Investment Strategies, & Risk of Loss of this Brochure. The Company has retained Bloomberg Index Services Limited., a U.K. limited company (“BISL”), to provide calculation index services for the Index. The Index Provider is not affiliated with BISL. Currently, there is one product that will utilize the Index, which is a U.S.-listed or issued ETF. The product provider listed below represents our primary Client from this category. First Trust Advisors L.P. The Company licenses its proprietary index to First Trust Advisors L.P. (“First Trust” or “Licensee”), for use in an exchange traded fund. The First Trust Emerging Markets Human Flourishing ETF (the “Fund”) is an exchange-traded fund (“ETF”) that seeks investment results that correspond generally to the price and yield, before the fund’s fees and expenses, of the Emerging Markets Human Flourishing Index. The First Trust Emerging Markets Human Flourishing ETF lists and principally trades its shares on NYSE Arca, Inc. ("NYSE Arca" or the “Exchange”). Market prices may differ to some degree from the net asset value of the shares. Unlike mutual funds, the Fund issues and redeems shares at net asset value, only in large blocks of shares called "Creation Units." The Fund is a series of First Trust Exchange-Traded Fund II (the “Trust”) and an exchange-traded index fund organized as a separate series of a registered management investment company. First Trust Advisors L.P., the Fund's investment advisor, maintains no discretion with regard to the compilation and composition of the Index or any changes thereto. The Company has entered into a licensing agreement with First Trust to accept license fees based on the average daily net assets of the funds. The existence of these agreements creates material conflicts of interest because they provide Oak City Consulting with an incentive to increase the ETF’s assets under management (“AUM”), which it may do by investing client assets in it. However, where such a conflict of interest exists, Oak City Consulting will not charge additional advisory fees on client assets invested in the ETFs. For additional information regarding fees and compensation related to licensing services please see Item 5 – Fees and Compensation and Item 11 – Code of Ethics (Conflicts of Interest) of this Brochure. In summary, Oak City Consulting provides the following advisory services:
• Discretionary Investment Management, except as otherwise set forth in any applicable Client Agreement. Our Clients authorize Oak City Consulting to investigate, purchase, and sell on behalf of Client, various securities and investments. Oak City Consulting is authorized to execute purchases and sales of securities on Client’s behalf without consulting Client regarding each sale or purchase. Client may, however, terminate the discretionary authority of Oak City Consulting immediately upon written or verbal notice.
• Non-Discretionary Investment Management. In these types of Client Agreements, Oak City Consulting is authorized to execute purchases and sales of securities only after securing permission from Client regarding each transaction.
• The Company is engaged in licensing as an index provider to Exchange Traded Funds. Currently Oak City Consulting owns, develops and sponsors one index, namely, the Emerging Markets Human Flourishing Index. In these types of Client Agreements, Oak City Consulting is authorized to execute a licensing agreement and any other related written agreements as applicable. Fees for Oak City Consulting’s licensing services are negotiated on an individual basis with each Client. Future indexes developed, owned and licensed by the Company have the ability to implement a fixed or variable fee arrangement that will be determined on a case-by-case basis with the licensee of the index provided by the Company. Furthermore, Oak City Consulting tailors its investment advice to the specific needs of its Clients and is subject to applicable investment restrictions set forth in the governing documents, including the investment advisory agreement, for the applicable Clients. The Company works with Clients to formulate appropriate and agreed-upon investment guidelines. Oak City Consulting works with Clients to determine the feasibility of monitoring proposed restrictions and limitations. Clients who restrict their investment portfolios may experience potentially worse performance results than Clients with unrestricted portfolios even for Clients with similar objectives. Oak City Consulting reserves the right to reject or terminate any Client that seeks restrictions which Oak City Consulting is unable to implement, or which may fundamentally alter the investment objective of the Client. Regulatory Assets Under Management As of December 31, 2023, Oak City Consulting managed approximately $153,759,762 in discretionary assets and $628,770,829 in non-discretionary assets, totaling $782,530,591 of advisory assets. The SEC has adopted a uniform method for advisers to calculate assets under management for regulatory purposes which it refers to as an adviser’s “regulatory assets under management.” Regulatory assets under management are generally an adviser’s gross assets, i.e., assets under management without deduction for outstanding indebtedness or other accrued but unpaid liabilities. Oak City Consulting reports its regulatory assets under management in Item 5 of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.