A. Description of the Advisory Firm Oak Creek Private Wealth Management LLC (hereinafter “OCPWM”) is a Limited Liability Company organized in the State of Oklahoma. The firm was formed in October 2019, and the principal owner is Pinnacle Investment Advisors which is owned by Pinnacle Holdings LLC. B. Types of Advisory Services Portfolio Management Services OCPWM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. OCPWM 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 OCPWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. OCPWM 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. OCPWM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of OCPWM’s economic, investment or other financial interests. To meet its fiduciary obligations, OCPWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, OCPWM’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 OCPWM’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. Selection of Other Advisers OCPWM will direct clients to third-party investment advisers. Before selecting other advisers for clients, OCPWM will verify that all recommended advisers are properly licensed, notice filed, or exempt in the states where OCPWM is recommending the adviser to clients. OCPWM will specifically direct clients to Envestnet Asset Management, Inc. (hereinafter “Envestnet”) CRD#111694. In general, Envestnet offers its services to OCPWM as sub-advisory services to be performed on Client’s account at the direction of OCPWM, and in certain limited instances, Envestnet works directly with the Client. In addition to the Envestnet sub- advisory services offered in the Programs, Envestnet also offers OCPWM many advisory service tools, whereby Envestnet provides only administrative and technology services and investment research and due diligence. OCPWM determines which services and Programs of Envestnet to utilize with its Clients and may utilize the services of other third- party services providers in conjunction with the Programs. The selection of services offered by Envestnet include:  Assessment assistance of the Client’s investment needs and objectives  Investment policy planning assistance  Assistance in development of an asset allocation strategy designed to meet the Client’s objectives  Recommendations on suitable

style allocations  Identification of appropriate managers and investment vehicles suitable to the Client’s goals  Evaluation of asset managers and investment vehicles meeting style and allocation criteria  Engagement of selected asset managers and investment vehicles on behalf of the Client  Ongoing monitoring of individual asset manager’s performance and management for “Approved” investment strategies.  Automated tools that assist in the review of Client accounts to ensure adherence to policy guidelines and asset allocation  Recommendations for account rebalancing, if necessary  Online reporting of Client account’s performance and progress  Fully integrated back office support systems to advisors, including interfacing with Client’s custodian, trade order placement, and confirmation and statement generation. Access to third party platforms and strategies through the ENV Platform. All clients will be provided a copy of the ADV Part 2A brochure and Appendix 1 for Envestnet. Pension Consulting Services OCPWM offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions • providing guidance on various assets classes and investment options • recommending money managers to manage plan assets in ways designed to achieve objectives • monitoring performance of money managers and investment options and making recommendations for changes • recommending other service providers, such as custodians, administrators and broker-dealers • creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Services Limited to Specific Types of Investments OCPWM generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), non-U.S. securities, venture capital funds and private placements. OCPWM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions OCPWM 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 impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent OCPWM from properly servicing the client account, or if the restrictions would require OCPWM to deviate from its standard suite of services, OCPWM reserves the right to end the relationship. 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, and certain other administrative fees. OCPWM recommends Envestnet Asset Management, Inc. which in turn manages a wrap fee program. E. Assets Under Management OCPWM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 1,870,205.00 $ 1,002,130.00 December 2023