A. Firm Information
Compton Financial Group, LLC d/b/a Red Oak Financial Group (“Red Oak Financial” or the “Advisor”) is a
registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is
organized as a Limited Liability Company (“LLC”) under the laws of the State of Maryland. Red Oak Financial
was founded in January 2013 and is owned and operated by Christopher P. Compton (Managing Member and
Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by Red Oak Financial.
B. Advisory Services Offered
Red Oak Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, businesses and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Red Oak Financial’s fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Wealth Management Services
Red Oak Financial provides Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services in connection with discretionary management of
investment portfolios. These services are described below.
Investment Management Services - Red Oak Financial provides investment advisory solutions for its Clients
based on model portfolios created by the Advisor. The Advisor primarily utilizes exchange traded funds (“ETFs”)
and mutual funds to create proprietary model portfolios offered to its Clients. The Advisor may also utilize other
investments to meet the model objectives. Red Oak Financial evaluates and selects investments for inclusion in
model portfolios only after applying its internal due diligence process. The Advisor will work with the Client to
identify their investment goals, objectives, and risk tolerance to construct a portfolio from the Advisor’s model
portfolios. The Advisor may retain certain types of investments based on a Client’s legacy holdings, which will be
maintained outside of the models.
Red Oak Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Red Oak Financial will construct, implement and monitor the portfolios and allocate Client assets to
ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client.
Red Oak Financial evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Red Oak Financial may, on occasion, redistribute investment allocations to
diversify the portfolio. Red Oak Financial may invest in specific positions to increase sector or asset class
weightings. The Advisor may employ cash positions as a possible hedge against market movement. Red Oak
Financial may sell 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 the Client, or any risk deemed unacceptable for the Client’s
risk tolerance.
At no time will Red Oak Financial accept or maintain custody of a Client’s funds or securities. All Client assets
will be managed within their designated account[s] at the Custodian, pursuant to the investment advisory
agreement. For additional information, please see Item 12 – Brokerage Practices and Item 15 – Custody.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
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Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Use of Independent Managers – When deemed to be in the Client’s best interest, Red Oak Financial will
recommend that a Client utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the
Client may be required to authorize and enter into an advisory agreement with the Independent Manager[s] that
defines the terms in which the Independent Manager[s] will provide investment management and related
services. The Advisor may also assist in the development of the initial policy recommendations and managing
the ongoing Client relationship.
The Advisor will perform initial and ongoing oversight and due diligence over the
selected Independent Manager[s] to ensure the Independent Managers’ strategies and target allocations remain
aligned with its clients’ investment objectives and overall best interests. The Client, prior to entering into an
agreement with unaffiliated investment manager[s] or investment platform[s], will be provided with the
Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures).
Financial Planning Services - Red Oak Financial will typically provide a variety of financial planning and
consulting services to Clients on an initial and on an as needed basis, either as a component of wealth
management services or pursuant to a stand-alone financial planning agreement. Services are offered in several
areas of a Client’s financial situation, depending on their goals and objectives. Client may also engage the
Advisor for financial planning services in a separate engagement.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
insurance needs, personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Red Oak Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. Plans or consultations are typically completed within six months of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction[s] through the Advisor.
Retirement Plan Advisory Services
Red Oak Financial provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist
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the Plan Sponsor in meeting its fiduciary obligations to the Plan. Each engagement is customized to the needs of
the Plan and Plan Sponsor. Services generally include:
● Vendor Analysis
● Plan Participant Enrollment and Education Tracking
● Investment Policy Statement (“IPS”) Design and Monitoring
● Performance Reporting
● Investment Oversight and Due Diligence (ERISA 3(21))
● Investment Management (ERISA 3(38))
● Ongoing Investment Recommendation and Assistance
● ERISA 404(c) Assistance
● Benchmarking Services
Red Oak Financial may provide investment advisory services on behalf of the Plan and Plan Sponsor, which may
be in either a 3(21) or 3(38) context depending on whether or not the Advisor is also providing discretionary
investment management over the Plan assets. For 3(38) services, the Advisor shall have the discretion to select
the investments for the Plan and/or make investment decisions on behalf of Plan Participants.
C. Client Account Management
Prior to engaging Red Oak Financial to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services include:
● Establishing an Investment Strategy – Red Oak Financial, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s investment goals and objectives.
● Asset Allocation – Red Oak Financial will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Red Oak Financial will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
● Investment Management and Supervision – Red Oak Financial will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Red Oak Financial does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Red Oak Financial.
E. Assets Under Management
As of December 31, 2023, Red Oak Financial manages $721,019,163 in Client assets, $376,028,280 of which
are managed on a discretionary basis and $344,990,883 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.