Arvest Investments, Inc., doing business as Arvest Wealth Management (the “Firm”), is a corporation organized under the laws of the State of Arkansas. The Firm is 100% owned by Arvest Bank, Fayetteville, Arkansas. Arvest Bank is a wholly owned subsidiary of Arvest Holdings, Inc., a wholly owned subsidiary of Arvest Bank Group, Inc., a corporation of which Jim C. Walton and Samuel Robson Walton each own or control over 25%, but less than 50% of the equity. The Arvest mission statement: People helping people find financial solutions for life. The Firm is an investment advisor registered with the Securities and Exchange Commission (SEC), with its principal place of business located in Arkansas, with advisors located in Arvest Bank branches in Arkansas, Oklahoma, Missouri, and Kansas. The Firm began conducting investment advisory business in 2004. As of December 31, 2023, the Firm had regulatory advisory assets under management of $2,593,400,723.00 of which we managed $857,957,789.00 on a discretionary basis. The Firm provides investment advisory services through its retirement plan consulting services and its financial planning services, as described in this Part 2A of Form ADV (Firm Brochure). Also, through the Firm-sponsored wrap fee programs, as further described in its Part 2A Appendix 1 of Form ADV wrap fee program brochure (the “Arvest Wealth Management Wrap Fee Program Brochure”). The Wrap Fee Program Brochure is provided separately to those applicable current and prospective clients. The Firm’s Client Advisors, Retirement Plan Advisors and Retirement Plan Relationship Managers will evaluate each client’s individual needs, financial goals, and attitudes towards risk to help the client identify which accounts and program(s) are appropriate for the client. The services provided after the initial recommendation will vary depending on account type and program selected. You should carefully review each recommended advisory service with your Client Advisor to be sure you understand the nature of the services being offered. Fees vary between the various services and programs offered by the Firm. This presents a conflict of interest in that the Firm may receive higher fees from some services and programs than from others and, because the salaries and/or bonuses of our Client Advisors and Retirement Plan Advisors (RPAs) are based in part on production, i.e. the amount of Client Advisory fees and other revenues generated to the Firm by their advisory client accounts, we may have an incentive to recommend higher-priced services or programs when a comparable lower priced alternative may be available. Note, Retirement Plan Relationship Managers’ (RPRMs) do not receive compensation directly from advisory fees, the sale of securities or other investment products through their salary or annual bonus opportunity. The Firm’s policies require all Client Advisors, RPAs and RPRMs to only recommend those services that are in the best interest of each client. Furthermore, Client Advisors’ salaries are calculated and set semi- annually. For each performance-based salary calculation, 6 months of prior production are used to determine application of the Client Advisor’s performance to a payout grid used to set an Advisor’s salary level. Retirement Plan Advisors (RPAs) receive a base annual salary that is not production based. However, RPAs and Client Advisors may qualify for certain bonus opportunities that are production based. Page 8 of 30 March 15, 2024 The Firm offers investment advisory services (including Firm advisory and portfolio management services, Arvest Wealth Management Portfolio Management and Research (PMR), formerly known as Investment Management Group Portfolio Management, portfolio management of the IMG Portfolios, and third-party portfolio management services) through the Firm-sponsored wrap fee programs: ● Arvest Wealth Management SMA Equity and Balanced Strategies ● Arvest Wealth Management SMA Fixed Income Strategies ● Arvest Wealth Management Unified Managed Account ● BNY Mellon Advisors, Inc. (BNYMA) AdvisorFlex Portfolios ● BNY Mellon Advisors, Inc. (BNYMA) Target Risk Portfolios ● Mutual Funds & ETF Strategists ● IMG Equity & Balanced Strategies ● IMG ETF Models ● IMG Fixed Income Strategies ● Advisor Directed – Discretionary ● Advisor Directed-Non-Discretionary Please refer to the Firm Wrap Fee Program Brochure for a description of sponsored wrap fee programs. The Firm, through its Retirement Plan Consulting Group offers (1) Discretionary Investment Management Services, (2) Non-Discretionary Investment Advisory Services and/or (3) Retirement Plan Consulting Services to employer-sponsored retirement plans and their participants. Depending on the type of the Plan and the specific arrangement with the Sponsor, we may provide one or more of these services. Prior to being engaged by the Sponsor, we will provide a copy of this Form ADV Part 2A along with a copy of our Privacy Policy and the Retirement Plan Investment Advisory Agreement (“Agreement”) that contains the information required under Sec. 408(b)(2) of the Employee Retirement Income Security Act ("ERISA") as applicable. Page 9 of 30 March 15, 2024 The Agreement authorizes our investment adviser representatives ("IARs") acting as RPAs, RPRMs or Client Advisors, as described below, to deliver one or more of the following services: Discretionary Investment Management Services These services are designed to allow the Plan fiduciary to delegate responsibility for managing, acquiring, and disposing of Plan assets that meet the requirements of the Employee Retirement Income Security Act of 1974 ("ERISA"). We will perform these investment management services through our RPAs and/or RPRMs (described as IARs) and charge fees as described in this Form ADV and the Agreement. If the Plan is subject to ERISA, we will perform these services as an “investment manager” as defined under ERISA Section 3(38) and as a “fiduciary” to the Plan as defined under ERISA Section 3(21). Specifically, the Sponsor may determine that we perform the: following services: SELECTION, MONITORING & REPLACEMENT OF DESIGNATED INVESTMENT ALTERNATIVES ("DIA"): IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to the Sponsor an Investment Policy Statement (IPS) that contains criteria from which the IAR will select, monitor, and replace the Plan's DIA. Once approved by the Sponsor, applicable IARs will review the investment options available to the Plan and will select the Plan's DIA in accordance with the criteria set forth in the IPS. On a periodic basis, IARs will monitor and evaluate the DIA and replace any DIA that no longer meet the IPS criteria. CREATION & MAINTENANCE OF MODEL ASSET ALLOCATION PORTFOLIOS ("MODELS"): IARs will create a series of risk-based Models comprised solely among the Plan's DIA; and, on a periodic basis and/or upon reasonable request, IARs will reallocate and rebalance the Models in accordance with the IPS or other guidelines approved by the Sponsor. SELECTION, MONITORING & REPLACEMENT OF QUALIFIED DEFAULT INVESTMENT ALTERNATIVES ("QDIA"): Based upon the options available to the Plan, IARs will select, monitor, and replace the Plan's QDIA in accordance with the IPS. MANAGEMENT OF TRUST FUND: IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan and provide to the Sponsor an IPS that contains criteria from which IARs will select, monitor, and replace the Plan's investments. Once approved by the Sponsor, IARs will review the investment options available to the Plan and will select the Plan's investments in accordance with the criteria set forth in the IPS. On a periodic basis, IARs will monitor and evaluate the investments and replace any investment(s) that no longer meet the IPS criteria. Non-Discretionary Fiduciary Services These services are designed to allow the Sponsor to retain full discretionary authority or control over assets of the Plan. We will solely be making recommendations to the Sponsor. We will perform these Non-Discretionary investment advisory services through our IARs, acting as either RPAs, RPRMs or Client Advisors, and charge fees as described in this Form ADV 2A and the Agreement. If the Plan is covered by ERISA, we will perform these investment advisory services to the Plan as a "fiduciary" defined under ERISA Section 3(21). The Sponsor may engage us to perform one or more of the following Non-Discretionary investment advisory services: INVESTMENT POLICY STATEMENT ("IPS"): IARs will review with the Sponsor the investment objectives, risk tolerance and goals of the Plan. If the Plan does not have an IPS, IARs will provide recommendations to the Sponsor to assist with establishing an IPS. If the Plan has an existing IPS, IARs will review it for consistency with the Plan's objectives. If the IPS does not represent the objectives of the Plan, IARs will recommend to the Sponsor revisions to align the IPS with the Plan's objectives. Page 10 of 30 March 15, 2024 ADVICE REGARDING DESIGNATED INVESTMENT ALTERNATIVES ("DIA"): Based on the Plan's IPS or other guidelines established by the Plan, IARs will review the investment

options available to the Plan and will make recommendations to assist the Sponsor with selecting DIA to be offered to Plan participants. Once the Sponsor selects the DIA, IARs will, on a periodic basis and/or upon reasonable request, provide reports and information to assist the Sponsor with monitoring the DIA. If a DIA is required to be removed, IARs will provide recommendations to assist the Sponsor with replacing the DIA. ADVICE REGARDING MODEL ASSET ALLOCATION PORTFOLIOS ("MODELS"): Based on the Plan's IPS or other guidelines established by the Plan, IARs will make recommendations to assist the Sponsor with creating risk-based Models comprised solely among the Plan's DIA. Once the Sponsor approves the Models, IARs will provide reports, information, and recommendations, on a periodic basis, designed to assist the Sponsor with monitoring the Models. Upon reasonable request, and depending upon the capabilities of the recordkeeper, IARs will make recommendations to the Sponsor to reallocate and/or rebalance the Models to maintain their desired allocations. ADVICE REGARDING QUALIFIED DEFAULT INVESTMENT ALTERNATIVES ("QDIA"): Based on the Plan's IPS or other guidelines established by the Plan, IARs will review the investment options available to the Plan and will make recommendations to assist the Sponsor with selecting or replacing the Plan's QDIA. ADVICE REGARDING INVESTMENT OF TRUST FUND: Based on the Plan's IPS, IARs will review the investment options available to the Plan and will make recommendations to assist the Sponsor with selecting investments that meet the IPS criteria. Once the Sponsor selects the investment(s), IARs will, on a periodic basis and/or upon reasonable request, provide reports and information to assist the Sponsor with monitoring the investment(s). If the IPS criteria require any investment(s) to be replaced, IARs will provide recommendations to assist the Sponsor with replacing the investment(s). Retirement Plan Consulting Services Retirement Plan Consulting services are designed to allow our IARs, acting as either RPAs, RPRMs or Client Advisors, to assist the Sponsor in meeting his/her fiduciary duties to administer the Plan in the best interests of Plan participants and their beneficiaries. Retirement Plan Consulting services are performed so that they would not be considered “investment advice” under ERISA. The Sponsor may elect for our IARs to assist with any of the following services: Administrative Support
• Assist the Sponsor in reviewing objectives and options available through the Plan
• Review Plan committee structure and administrative policies/procedures
• Recommend Plan participant education and communication policies under ERISA 404(c)
• Assist with development/maintenance of fiduciary audit file and document retention policies
• Deliver fiduciary training and/or education periodically or upon reasonable request
• Recommend procedures for responding to Plan participant requests Service Provider Support
• Assist fiduciaries with a process to select, monitor and replace service providers
• Assist fiduciaries with review of Covered Service Providers ("CSP") and fee benchmarking
• Coordinate and assist with CSP replacement and conversion Page 11 of 30 March 15, 2024 Investment Monitoring Support
• Periodic review of investment policy in the context of Plan objectives
• Assist the Plan committee with monitoring investment performance
• Educate Plan committee members, as needed, regarding replacement of DIA and/or QDIA Participant Services
• Facilitate group enrollment meetings and coordinate investment education
• Assist Plan participants with financial wellness education, retirement planning and/or gap analysis Potential Additional Retirement Services Provided Outside of the Agreement In providing Retirement Plan Consulting services, the Firm and its IARs may establish a client relationship with one or more Plan participants or beneficiaries. Such client relationships develop in various ways, including, without limitation: ●as a result of a decision by the Plan participant or beneficiary to purchase services from the Firm not involving the use of Plan assets, ●as part of an individual or family financial plan for which any specific recommendations concerning the allocation of assets or investment recommendations relating to assets held outside of the Plan, or ●through a rollover of an Individual Retirement Account ("IRA Rollover").
If the Firm is providing Retirement Plan Consulting services to a plan, IARs may, when requested by a Plan participant or beneficiary, arrange to provide services to that participant or beneficiary through a separate agreement. If a Plan participant or beneficiary desires to affect an IRA Rollover from the Plan to an account advised or managed by the Firm, IARs will have a conflict of interest if his/her fees are reasonably expected to be higher than those paid to the Firm in connection with the Retirement Plan Consulting services. IARs will disclose relevant information about the applicable fees charged by the Firm prior to opening an IRA account. Any decision to affect the rollover or about what to do with the rollover assets remain that of the Plan participant or beneficiary alone. In providing these optional services, we may offer employers and employees information on other financial and retirement products or services offered by the Firm and our IARs. Individually Tailored Services When providing investment fiduciary services, we will tailor our advice or (if applicable) discretion to meet the investment policies or other written guidelines adopted by the Sponsor. The Firm IARs may also provide advice, under a separate advisory agreement, to plan participants of retirement plans that are not associated with the Firm. When providing Participant Investment Advice, such advice will be based upon the investment objectives, risk tolerance and investment time horizon of each individual Plan participant. Page 12 of 30 March 15, 2024 FINANCIAL PLANNING SERVICES We provide financial planning services in addition to the advisory services listed previously. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information, and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients utilizing this service receive a written report, which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial planning process may address some or all, of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax, spending and planning for past, current, and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability. However, we do not give specific tax advice, deferring to the client’s personal accountant or tax preparer.
• INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long- term care, liability, home, and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid, and elder law. However, we do not give tax, legal advice or prepare estate planning documents, such as wills, trusts or powers of attorney. We gather required information through in-depth personal interviews. Information gathered includes the client’s current financial status, tax status, future goals, performance objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent and/or financial advisor. Implementation of financial plan recommendations is entirely at the client’s discretion. LIMITATIONS: Client Advisors of the Firm are registered representatives of a broker-dealer and/or insurance agents/brokers of various insurance companies. Specific product recommendations made in Page 13 of 30 March 15, 2024 financial plans are limited to only those products offered through approved companies, as well as our clearing firm.