ARVEST INVESTMENTS, INC.

Part 2A of Form ADV: Firm Brochure Arvest Investments, Inc. Doing business as Arvest Wealth Management Physical Address: 5201 Village Parkway Rogers, Arkansas 72758 Mailing Address: P.O. Box 1515 Lowell, Arkansas 72745 Telephone: (888) 916-2121 Email: AWMSolutionsCenter@arvest.com Web Address: https://www.arvest.com/personal/invest March 17, 2025 This brochure provides information about the qualifications and business practices of Arvest Wealth Management an investment adviser registered with the SEC (#801 – 63738). Please note that registration with the SEC does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at (888) 916-2121 or AWMSolutionsCenter@arvest.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Arvest Wealth Management also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm’s CRD number is 42057. Arvest Wealth Management is the trade name used by Arvest Investments, Inc., an SEC registered investment adviser and broker-dealer, member FINRA/SIPC, and a wholly owned subsidiary of Arvest Bank.  Item 2 Material Changes This Firm Brochure, dated March 17, 2025, is our current disclosure document prepared according to the SEC’s requirements and rules. Arvest Wealth Management (the “Firm”) made the following material changes to Item 4 Advisory Business since its last annual update on March 15, 2024. Item 4 Advisory Business Updates Regarding Transition of Retirement Plan Consulting Services provided to the Trust Department of Arvest Bank Additional updates to Item 4 reflect the transition of Retirement Plan Consulting Services employer- sponsored retirement plan services from the Firm’s registered investment advisor to the Trust Department of Arvest Bank: adviser. The Firm, beginning in late 2024, started a process of written client notification and reassignment of its agreements concerning the Retirement Plan Consulting Services’ employer-sponsored retirement plan services from the Firm’s registered investment adviser to the Arvest Bank Trust Department. As relayed in the notifications, this change is due to an internal restructuring and is not intended to change clients’ experiences. The Firm’s Retirement Plan Relationship Managers are also employees of Arvest Bank and there will be no changes in the scope of services provided or fees collected as a result of the assignments. This process of notification and reassignment continues to the present. Once the retirement plan relationship has completed this transition, services will no longer be delivered through the Firm’s registered investment The information and disclosures contained within this document are relevant for our investment advisory clients and Retirement Plan Consulting Services clients, whose services are presently still delivered by the Firm’s registered investment adviser. Consistent with the current rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of business’ fiscal year, which is December 31. Furthermore, we will provide you with other interim disclosures about material changes, as necessary. the SEC’s website, You can access additional information about our firm, management personnel, investment advisor located at recent Firm Brochure at representatives and our most https://adviserinfo.sec.gov/firm/summary/42057. This site may also be reached through FINRA’s website, at https://brokercheck.finra.org/. Page 2 of 22 March 17, 2025  Item 3 Table of Contents Item 2 Material Changes .......................................................................................................................... 2 Item 3 Table of Contents.......................................................................................................................... 3 Item 4 Advisory Business ......................................................................................................................... 5 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................... 6 RETIREMENT PLAN CONSULTING .............................................................................................................. 6 FINANCIAL PLANNING SERVICES ............................................................................................................. 10 Item 5 Fees and Compensation ............................................................................................................. 11 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 11 RETIREMENT PLAN CONSULTING FEES ................................................................................................... 11 FINANCIAL PLANNING FEES .................................................................................................................... 13 Item 6 Performance-Based Fees and Side-By-Side Management ......................................................... 13 Item 7 Types of Clients ........................................................................................................................... 14 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 14 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 14 RETIREMENT PLAN CONSULTING ............................................................................................................ 14 Item 9 Disciplinary Information ............................................................................................................. 14 Item 10 Other Financial Industry Activities and Affiliations .................................................................... 15 FIRM REGISTRATIONS ............................................................................................................................. 15 MANAGEMENT PERSONNEL AND OTHER ASSOCIATES REGISTRATIONS................................................ 15 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 17 Item 12 Brokerage Practices .................................................................................................................... 19 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 19 RETIREMENT PLAN CONSULTING ............................................................................................................ 19 Item 13 Review of Accounts .................................................................................................................... 19 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 19 Page 3 of 22 RETIREMENT PLAN CONSULTING ............................................................................................................ 19 March 17, 2025  FINANCIAL PLANNING SERVICES ............................................................................................................. 20 Item 14 Client Referrals and Other Compensation .................................................................................. 20 Item 15 Custody ....................................................................................................................................... 20 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 20 RETIREMENT PLAN CONSULTING ............................................................................................................ 21 Item 16 Investment Discretion ................................................................................................................ 21 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 21 RETIREMENT PLAN CONSULTING ............................................................................................................ 21 Item 17 Voting Client Securities ............................................................................................................... 21 ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS ................................................. 21 RETIREMENT PLAN CONSULTING ............................................................................................................ 21 Item 18 Financial Information .................................................................................................................. 21 BUSINESS CONTINUITY PLAN ...................................................................................................................... 22 Page 4 of 22 March 17, 2025  Item 4 Advisory Business 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 Bank Group, Inc. which is 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, 2024, the Firm had regulatory advisory assets under management of $2,824,855,462.00 of which we managed $883,804,968.00 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. adviser. The Firm, beginning in late 2024, started a process of written client notification and reassignment of its agreements concerning the Retirement Plan Consulting Services’ employer-sponsored retirement plan services from the Firm’s registered investment adviser to the Arvest Bank Trust Department. As relayed in the notifications, this change is due to an internal restructuring and is not intended to change clients’ experiences. The Firm’s Retirement Plan Relationship Managers are also employees of Arvest Bank and there will be no changes in the scope of services provided or fees collected as a result of the assignments. This process of notification and reassignment continues to the present. Once the retirement plan relationship has completed this transition, services will no longer be delivered through the Firm’s registered investment The information and disclosures contained within this document are relevant for our investment advisory clients and Retirement Plan Consulting Services clients, whose services are presently still delivered by the Firm’s registered investment adviser. 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. Page 5 of 22 March 17, 2025  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. ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS 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. RETIREMENT PLAN CONSULTING 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 Page 6 of 22 March 17, 2025  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. 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: Page 7 of 22 March 17, 2025  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. 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 Page 8 of 22 March 17, 2025  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 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 Page 9 of 22 March 17, 2025  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. 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 Page 10 of 22 March 17, 2025  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 financial plans are limited to only those products offered through approved companies, as well as our clearing firm. Item 5 Fees and Compensation ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs. RETIREMENT PLAN CONSULTING FEES Fees for Retirement Plan Consulting’s (“Fees”) services are negotiable and vary based upon the nature, scope, and frequency of our services as well as the size and complexity of the plan. A general description of the different types of fees for Retirement Plan Consulting services appears in the fee schedule below: Fee Type Fee Range Assets Under Management – Plan or Account Value Flat Fee Project Fee 0.15% - 1.00% (Annualized) Negotiable Negotiable Depending upon the capabilities and requirements of the Plan’s recordkeeper or custodian, we may collect our Fees in arrears or in advance. Typically, Sponsors instruct the Plan’s recordkeeper or custodian to automatically deduct our Fees from the Plan account; however, in some cases a Sponsor may request that we send invoices directly to the Sponsor or recordkeeper/custodian. Some Plans have monthly fee assessment and collection, while others are quarterly. Please also consult the plan custodian’s disclosures and your advisory agreement with the Firm for additional information regarding fees and fee collection. Upon termination of any Retirement Plan Consulting services contract, any prepaid, unearned fees will be promptly refunded. Sponsors receiving Retirement Plan Consulting services may pay more than or less than a client might otherwise pay if purchasing the Retirement Plan Consulting services separately or through another service provider. There are several factors that determine whether the costs would be more or less, including, but not limited to, the size of the Plan, the specific investments made by the Plan, the number of or locations of Plan participants, services offered by another service provider, and the actual costs of Retirement Plan Consulting services purchased elsewhere. Considering the specific Retirement Plan Consulting services offered by the Firm, the Fees charged may be more or less than those of other similar service providers. Page 11 of 22 March 17, 2025  In determining the value of the Account for purposes of calculating any asset-based Fees, IARs will rely upon the valuation of assets provided by the Sponsor or the Plan’s custodian or recordkeeper without independent verification. If, however, there are circumstances which, in the IAR’s judgment, render the custodian’s valuation inappropriate, IARs will value securities listed on any national securities exchange at the closing price on the principal exchange on which they are traded and will value any other securities in a manner determined in good faith by IARs to reflect fair market value. In all events, any such valuation will not be any guarantee of the market value of any of the assets in the Plan. Unless we agree otherwise, no adjustments or refunds will be made in respect of any period for (i) appreciation or depreciation in the value of the Plan account during that period or (ii) any partial withdrawal of assets from the account during that period. If the Agreement is terminated by us or by the Sponsor, we will refund certain Fees to the Sponsor to the extent provided in Section 8 of the Agreement. Unless we agree otherwise, all Fees shall be based on the total value of the assets in the account without regard to any debit balance. All Fees paid to the Firm for Retirement Plan Consulting services are separate and distinct from the fees and expenses charged by mutual funds, variable annuities, and exchange-traded funds to their shareholders. These fees and expenses are described in each investment's prospectus. These fees will generally include a management fee, other expenses, and possible distribution fees. If the investment also imposes sales charges, a client may pay an initial or deferred sales charge. The Retirement Plan Consulting services provided by the Firm may, among other things, assist the client in determining which investments are most appropriate to each client's financial condition and objectives and to provide other administrative assistance as selected by the client. Accordingly, the client should review both the fees charged by the funds, the fund manager, the Plan's other service providers and the fees charged by the Firm to fully understand the total amount of fees to be paid by the client and to evaluate the Retirement Plan Consulting services being provided. While the following examples are not necessarily related to the Retirement Plan Consulting services, various vendors, product providers, distributors and others have provided and may, in the future provide, compensation by paying some expenses related to the following activities: training and education to include the Firm’s training and recognition events. Also, certain vendors have, and may in the future, provide marketing support (example seminars), invite us to participate in conferences, or on-line training that may further IARs' and employees' skills and knowledge. Also, some have and may, in the future, occasionally provide us with gifts, meals and entertainment of reasonable value consistent with industry rules and regulations. If applicable, and in the event the payments are received in connection with, or resulting from, the Retirement Plan Consulting services, we will disclose such payments to Sponsors in accordance with ERISA and Department of Labor regulations. No increase in the Fees will be effective without prior written notice. Advisory Fees in General: Clients should note that similar advisory services may be available from other registered investment advisors for similar or lower fees. Page 12 of 22 March 17, 2025  Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees more than $1,200 more than six months in advance of services rendered. Additional Fees and Expenses: In addition to our advisory fees, clients will be responsible for other fees and expenses incurred by their accounts, including, but not limited to, account service fees (example loan fees as applicable) charged by the custodian; any transaction charges imposed by a broker dealer; and internal investment charges such as mutual fund or exchange traded fund management fees. Please refer to disclosures and prospectuses provided by the plan custodian of your retirement plan. FINANCIAL PLANNING FEES The Firm has traditionally not charged for financial planning services and does not require the execution of an advisory agreement, regarding these services, in instances where we are providing them at no charge or requirement for future business. Should the Firm enter into agreement to receive payment for financial planning services, the Firm’s Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering a contract with any client. Our Financial Planning fees may be calculated and charged on an hourly basis, ranging from $25 to $100 per hour. Although the length of time it will take to provide a Financial Plan will depend on each client's personal situation, we will provide an estimate for the total hours at the start of the advisory relationship. Our Financial Planning fees also may be calculated and charged on a fixed fee basis, typically ranging from $250 to $1,000, depending on the specific arrangement reached/negotiated with the client. We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan. Upon termination of any financial planning contract, any prepaid, unearned fees will be promptly refunded. Financial Planning Fee Offset: The Firm reserves the discretion to reduce or waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to engage us for our Portfolio Management Services. Item 6 Performance-Based Fees and Side-By-Side Management The Firm does not charge clients performance-based fees. Page 13 of 22 March 17, 2025  Item 7 Types of Clients The Firm provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans • Charitable organizations • Corporations or other businesses not listed above. Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs, including the requirements for opening and maintaining a wrap fee program account. Our Retirement Plan Consulting services are available to clients that are sponsors or other fiduciaries to plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant-directed defined contribution plans and defined benefit plans. Plans may or may not be subject to ERISA. The Firm does not have a minimum asset amount requirement for our Retirement Plan Consulting accounts, but various plan custodians may. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs. RETIREMENT PLAN CONSULTING METHODS OF ANALYSIS INVESTMENT STRATEGIES Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. In May 2012, The Oklahoma Department of Securities (ODS) filed an Enforcement Division Recommendation against the Firm, its broker-dealer division, and our Chief Compliance Officer, alleging violations of our written policies and procedures, as it related to our handling of verbal complaints. There were no alleged violations of illegal activities, or that any customer suffered financial loss. In January 2013, the ODS and the Firm reached a verbal settlement, with the Firm agreeing to amend its policies and procedures regarding the handling of customer complaints, pay a $20,000 fine and that the Chief Compliance Officer receive a three-day suspension of his duties, as it relates to his activities in the Page 14 of 22 March 17, 2025  State of Oklahoma. A final Order was entered on May 9, 2013, confirming this agreement. We have amended our policies and procedures, paid the fine and the CCO served the suspension. The Firm, as a broker-dealer, is a member of FINRA. FINRA alleged that the Firm violated rules 4 and 5 of Regulation S-P, NASD Rule 3010(a)(2) and (b)(1), and FINRA Rules 3110(a)(2), (b)(1) and 2010 by, between January 2009 and December 2016, failing to provide required initial and annual privacy notices to certain brokerage customers, and failing to establish and maintain a supervisory system reasonably designed to ensure that it was meeting its privacy notice obligations. In May 2018, without admitting or denying FINRA’s findings, the Firm consented to the entry of findings and to the following sanctions, including a censure, a fine in the amount of $150,000, and an undertaking to revise as necessary its policies, procedures, and internal controls, which the Firm has already complied with. You can access additional information about our firm and our management personnel, including on the SEC’s website, located at adviserinfo.sec.gov, as well as FINRA’s website, at: https://brokercheck.finra.org Item 10 Other Financial Industry Activities and Affiliations FIRM REGISTRATIONS In addition to the Firm being an investment advisor registered with the SEC, our firm is registered as a FINRA member broker-dealer. MANAGEMENT PERSONNEL AND OTHER ASSOCIATES REGISTRATIONS Management personnel and some other associates of our firm, in addition to being licensed as investment advisor representatives are also separately licensed as registered representatives of the Firm, in our capacity as a FINRA member broker-dealer. While the Firm, our management personnel and client advisors always endeavor to put the interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional compensation itself creates a conflict of interest and may affect the judgment of these individuals when making recommendations. We are a registered investment advisor, a FINRA member broker-dealer, and a wholly owned subsidiary of Arvest Bank, a commercial bank that offers a broad spectrum of banking products, trust services and other financial services to consumers, small businesses, and commercial clients. As a subsidiary of Arvest Bank, our firm is under common ownership and control with several financial institutions, including Arvest Insurance, Inc., a licensed insurance agency with which we have a material business relationship (referred to collectively, together with Arvest Bank and the Firm in its capacity as a broker-dealer, as the “Related Companies”). Where appropriate, the Firm and our associates may recommend the various investment and investment- related services of the Related Companies to our advisory clients. The Related Companies and their Page 15 of 22 March 17, 2025  associates may also recommend the advisory services of our firm to their clients. The services provided by the Related Companies are separate and distinct from our advisory services and are provided for separate and additional compensation. There may also be arrangements between the Firm and these Related Companies where the Firm and/or the Related Companies and their associates receive payment in exchange for client referrals. No Firm client is obligated to use the services of any of the Related Companies. In addition, the management persons, and other associates of the Firm are management persons and insurance agents of Arvest Insurance, Inc., a licensed insurance agency. These individuals may also be insurance agents for one or more insurance companies. In their separate capacities as registered representatives of the Firm and/or insurance agents, these individuals can affect securities transactions and/or purchase insurance and insurance-related investment products for the Firm’s advisory clients, for which these individuals may generate separate and additional compensation. Clients, however, are not under any obligation to engage these individuals when considering the purchase/sale of securities or insurance. Clients should be aware that the receipt of additional compensation by the Firm and its Related Companies, affiliates and associates creates a potential conflict of interest that may impair the objectivity of our firm and these individuals when making advisory recommendations. The Firm endeavors always to put the interest of its clients first as part of our fiduciary duty as a registered investment advisor. The Firm’s policies require all Client Advisors 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. Note: Retirement Plan Advisors (RPAs) receive a base annual salary that is not production based. However, RPAs and Client Advisors may be eligible for certain bonus opportunities that are production based. Additionally, we take the following steps to address this conflict: • We disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our associates to earn compensation from the sale of individual securities, brokerage and insurance products and services in addition to our firm’s advisory fees, • We disclose to clients that they are not obligated to purchase recommended investment products from our associates or affiliated companies, • We collect, maintain and document accurate, complete, and relevant client background information, including the client’s financial goals, objectives and risk tolerance, our firm’s management and compliance associates conduct regular reviews of client accounts to verify that recommendations made to a client are suitable to the client’s needs and circumstances, • We require that our associates seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed, Page 16 of 22 March 17, 2025  • We periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm, and • We educate our associates regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. The Firm and our personnel owe a duty of care and a duty of loyalty to our clients and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports, or statements and confirmations if capturing all securities activity, as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions. The Firm’s Code of Ethics further includes the firm’s policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all associates are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to AWMSolutionsCenter@arvest.com, or by calling (888) 916-2121. Please do not hesitate to call your Client Advisor or the Firm Compliance number above if you have any questions. The Firm and individuals associated with our firm are prohibited from engaging in principal transactions for advisory accounts. The Firm and individuals associated with our firm are prohibited from engaging in agency cross transactions. Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our associates will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing associates to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal account’s securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in certain securities which may also be recommended to a client. Page 17 of 22 March 17, 2025  It is the expressed policy of our firm that no Firm Client Advisor may purchase or sell any security prior to a transaction(s) being implemented for their clients’ advisory accounts, when the Client Advisor has received an order(s) or has knowledge of pending trades for their clients, thereby; preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. We may aggregate our associate trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro rata, with each account paying the average price. Our associate accounts will be excluded in the pro rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or associate of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or associate of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received because of his or her employment unless the information is also available to the investing public. 3. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such associates from benefiting from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any Initial Public Offering (IPO) or private placement investments by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm, and anyone associated with this advisory practice that has access to advisory recommendations (access person). These holdings are reviewed on a regular basis by our firm’s Chief Compliance Officer or his/her designee. 6. We have established procedures for the maintenance of all required books and records. 7. All clients are fully informed that related persons may receive separate commission compensation when effecting transactions during the implementation process. 8. Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 9. All Firm principals and associates must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Page 18 of 22 March 17, 2025  10. We require delivery and acknowledgement of the Code of Ethics by each supervised, securities licensed person of our firm on an annual basis. 11. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 12. Any individual who violates any of the above restrictions may be subject to termination. As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm are separately registered as securities representatives of a broker-dealer and licensed as an insurance agent of various insurance companies. Please refer to Item 10 for a detailed explanation of these relationships and important conflict of interest disclosures. Item 12 Brokerage Practices ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs. RETIREMENT PLAN CONSULTING When appropriate, based upon the needs of each plan, we may recommend that a plan use a certain retirement plan platform or service provider (such as a recordkeeper, administrator or broker-dealer). That recommendation may include using our affiliated broker-dealer, also doing business as the Firm, to serve as broker-dealer in connection with the sale of securities or insurance products to the Plan. As noted above, for Plans that are subject to ERISA or are otherwise subject to Section 4975 of the Internal Revenue Code of 1986, as amended (the "Code"), 12b-1 fees paid by product sponsors to the Firm as broker-dealer of record to the Plan are either refunded to the plan or used to offset the fees. Item 13 Review of Accounts ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs. RETIREMENT PLAN CONSULTING We will contact you at least once a year to review our Retirement Plan Consulting services. It is important that you discuss any changes in the Plan's demographic information, investment goals, and objectives with your IAR. Plans may receive written reports directly from their IAR based upon the services being provided, including any reports evaluating the performance of Plan investment manager(s) or investments and as applicable recommended changes. Page 19 of 22 March 17, 2025  Regarding advisory services provided to retirement plan participants by the Firm Client Advisors, the Firm Client Advisor will review items such as: Investment Allocation, 1. 2. Participant Investor Profile or Suitability Changes, and 3. Any Recommended Investment Changes. FINANCIAL PLANNING SERVICES While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for financial planning clients unless otherwise contracted for. We appreciate your significant achievement in approaching the end of our disclosure document and hope in the future that your continued “investment in knowledge always pays (you) the best interest” – Ben Franklin. Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless otherwise contracted for. Item 14 Client Referrals and Other Compensation The Firm may pay Arvest Bank associates a nominal one-time cash award of no more than $25, for a qualified referral to a licensed Client Advisor, which is not dependent upon a sale being made. Additionally, the Firm securities licensed associates, to include IARs and Registered Representative (RR)s, may receive compensation for referrals made to Retirement Plan Consulting. Our firm does not pay referral fees to independent persons or firms (Solicitors) for introducing clients to us. It is the Firm’s policy not to accept or allow our related persons to accept direct compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. However, our firm does allow for soft dollar, indirect compensation from various vendors, product providers, distributors, and others. These providers may provide non-monetary compensation by paying some expenses related to training and education, excluding travel expenses. The Firm might receive payments to subsidize our own training programs or to sponsor an event. Certain vendors may invite us to participate in conferences, on-line training or receive publications that may further our skills and knowledge. Some may occasionally provide us with nominal gifts, meals, and entertainment of reasonable value consistent with industry rules and regulations. Item 15 Custody ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to the Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs. Page 20 of 22 March 17, 2025  RETIREMENT PLAN CONSULTING Additionally, the Firm will not serve as custodian for plan assets in connection with brokerage or investment advisory Retirement Plan Consulting services. Retirement plan sponsors are responsible for selecting the custodian for plan assets. The Firm Retirement Plan Consulting Group may be listed as the contact for the plan account held at an investment sponsor our custodian. Sponsor for the plan will complete account paperwork with the outside custodian that will provide the name and address of the custodian. The custodian for the plan is responsible for providing the plan with periodic confirmations and statements. We recommend that sponsors review the statements and reports received directly from the custodian or investment sponsor. Item 16 Investment Discretion ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to our Arvest Wealth Management Wrap Fee Program Brochure for a description of our wrap fee programs, including programs where we accept discretionary authority to manage securities accounts on behalf of clients. RETIREMENT PLAN CONSULTING When providing Retirement Plan Consulting services described herein, we may exercise discretionary authority or control over the investments specified in the Agreement. We perform these services to the Plan as a fiduciary under ERISA Section 3(21) and investment manager under ERISA Section 3(38). We are legally required to act with the degree of diligence, care, and skill that a prudent person rendering similar services would exercise under similar circumstances. This discretionary authority is specifically granted to us by Sponsor, as specified in the Agreement (see also, Item 4 above). Item 17 Voting Client Securities ARVEST WEALTH MANAGEMENT SPONSORED WRAP FEE PROGRAMS Please refer to our Wrap Fee Program Brochure for a description of our wrap fee programs. RETIREMENT PLAN CONSULTING The Firm’s Retirement Plan Consulting services has no authority or responsibility to vote any security held by the Plan or the related proxies. The Sponsor or trustee of the Plan reserves that authority. The Firm does not accept proxy voting authority in connection with any Retirement Plan Consulting services. Item 18 Financial Information The Firm has no additional financial circumstances to report. Page 21 of 22 March 17, 2025  Under no circumstances do we require or solicit payment of fees more than $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. The Firm has not been the subject of a bankruptcy petition at any time. BUSINESS CONTINUITY PLAN The Firm is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. Our Business Continuity Plan, which enables us to respond to events that significantly disrupt our business, may be obtained from our Retirement Plan Advisors and Retirement Plan Relationship Managers or Client Advisors (as applicable) and can also be found at our disclosures’ website: https://www.arvest.com/documents-and-resources/awm-disclosures Page 22 of 22 March 17, 2025 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure of Arvest Wealth Management March 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of Arvest Investments, Inc. d/b/a Arvest Wealth Management (the “Firm”), an investment adviser registered with the SEC (#801 – 63738). Please note that registration with the SEC does not imply a certain level of skill or training. If you have questions about the contents of this Brochure, please contact us at (888) 916-2121 or AWMSolutionsCenter@arvest.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Arvest Wealth Management also is available on the SEC’s website at www.adviserinfo.sec.gov. Arvest Wealth Management is the trade name used by Arvest Investments, Inc., an SEC registered investment adviser and broker-dealer, member FINRA/SIPC, and a wholly owned subsidiary of Arvest Bank. Physical Address: 5201 Village Parkway, Rogers, AR 72758 Mailing Address: P.O. Box 1515, Lowell, AR 72745 Web Address: https://www.arvest.com/personal/invest Page 1 of 39 March 17, 2025  Item 2 Material Changes This Firm Wrap Fee Program Brochure, dated March 17, 2025, is our current disclosure document prepared according to the SEC’s requirements and rules. We have made the following material changes since our annual update dated March 15, 2024. The Firm made the following revisions to “Item 4 – Services, Fees and Compensation” related to the description of our investment advisory services: 1. Updated page 15 “IMG Managed Equity Portfolios Philosophy & Fee Structure” to provide information regarding enhanced analysis and research processes: IMG Managed Equity Portfolios Philosophy & Fee Structure Our Equity investment philosophy is built around four key characteristics: • Quality – We consider quality securities to be those of established entities with proven track records, where it is reasonable to believe that our minimum goal of capital preservation will be met. • Value – We consider value to be those securities where we believe the security is attractively priced relative to our analysis of future prospects. • Long Term Approach – We are not short-term market timers. Our goal is to construct portfolios that will perform favorably over the long haul. • Diversification – Portfolios will be well diversified by both issuer and industry. We believe that this is a crucial element of risk management. We are value-oriented and focused on consistent, long-term performance. In order to accomplish these objectives, we combine traditional analysis with systematic research to create a fundamental factor rating for stocks based on their single factor score in the areas of: • Value (stocks undervalued by the market) • Quality (well-managed financially healthy companies) Low-Volatility (stable and predictable companies) • • Momentum (strong recent performance, correlates with themes) The process leverages many points of fundamental data, supplemented by sentiment and price information, to construct proprietary metrics, which are evaluated over a long-term horizon (1-3 years) to provide comprehensive understanding of company and factor trends. Rather than attempting to “time” short term market swings, we seek to identify high-quality stocks that possess long term value. Our ultimate goal is to provide actively managed portfolios of stocks with identifiable investment opportunities at risk levels below the overall market. Page 2 of 39 March 17, 2025  2. Updated on page 23 within the discussion of “IMG Managed Municipal Bond Portfolio” guideline and constraints applying to each portfolio. Specifically: • • Increasing from 15% to 17.5% the maximum concentration of the portfolio’s value in the securities of any single issuer (at market value) while maintaining the 10% maximum value concentration to be allocated to a specific portfolio holding. Increasing the maximum portfolio duration to a worst of 11 years (from 8 years) with a maximum average maturity of 15 years (from 11 years). A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to AWMSolutionsCenter@arvest.com , or by calling (888) 916-2121. Consistent with the current rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year, which is December 31. Furthermore, we will provide you with other interim disclosures about material changes, as necessary. You can access additional information about our firm and our management personnel on the SEC’s website, www.adviserinfo.sec.gov, and on FINRA’s website, https://brokercheck.finra.org/. Page 3 of 39 March 17, 2025  Item 3 Table of Contents Item 2 Material Changes ................................................................................................................2 Item 3 Table of Contents ................................................................................................................4 Item 4 Services, Fees and Compensation ........................................................................................5 General Information Regarding the Wrap Fee Programs......................................................................... 6 Arvest Wealth Management SMA Equity and Balanced Strategies ......................................................... 9 Arvest Wealth Management SMA Fixed Income Strategies .................................................................... 9 Arvest Wealth Management Unified Managed Account (UMA) ............................................................ 10 BNYMA AdvisorFlex Portfolios ............................................................................................................... 10 BNYMA Target Risk Portfolios ................................................................................................................ 11 Mutual Funds & ETF Strategists ............................................................................................................. 12 IMG Equity, Balanced & Blended Strategies .......................................................................................... 15 IMG ETF Models ..................................................................................................................................... 18 IMG Fixed Income Strategies .................................................................................................................. 20 Advisor Directed – Discretionary ............................................................................................................ 23 Advisor Directed – Non-Discretionary .................................................................................................... 24 Modification of Client Advisory Fee Schedules/Fees Negotiable ........................................................... 25 Billing ...................................................................................................................................................... 25 Program Changes .................................................................................................................................... 26 Termination of the Advisory Relationship .............................................................................................. 26 ERISA Accounts ....................................................................................................................................... 27 Other Fees and Additional Compensation ............................................................................................. 27 Cash Sweep Program .............................................................................................................................. 28 Margin Accounts ..................................................................................................................................... 29 Transactions Executed Away from Pershing .......................................................................................... 29 Item 5 Account Requirements and Types of Clients ....................................................................... 29 Account Requirements ........................................................................................................................... 29 Types of Clients ....................................................................................................................................... 30 Item 6 Portfolio Manager Selection and Evaluation ....................................................................... 30 Selection and Review of Portfolio Managers ......................................................................................... 30 Advisory Business ................................................................................................................................... 30 Performance-Based Fees and Side-by-Side Management ..................................................................... 30 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 31 Voting Client Securities ........................................................................................................................... 36 Item 7 Client Information Provided to Portfolio Managers ............................................................ 36 Information Provided to Affiliated Portfolio Managers ......................................................................... 37 Information Provided to Non-affiliated Portfolio Managers .................................................................. 37 Item 8 Client Contact with Portfolio Managers.............................................................................. 37 Item 9 Additional Information ...................................................................................................... 37 Disciplinary Information ......................................................................................................................... 37 Financial Industry Activities and Affiliations........................................................................................... 38 Custody ................................................................................................................................................... 38 Code of Ethics ......................................................................................................................................... 38 Review of Accounts ................................................................................................................................ 39 Client Referrals ....................................................................................................................................... 39 Financial Information ............................................................................................................................. 39 Business Continuity Plan .................................................................................................................. 39 Page 4 of 39 March 17, 2025  Item 4 Services, Fees and Compensation 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 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, 2024, the Firm had regulatory advisory assets under management of $2,824,855,462.00 of which we managed $883,804,968.00 on a discretionary basis. The Firm provides investment advisory services through the Firm-sponsored wrap fee programs, as further described in this Part 2A Appendix 1 of Form ADV wrap fee program brochure (the “Arvest Wealth Management Wrap Fee Program Brochure”), and retirement plan consulting services, advice, and financial planning services, as described in our Part 2A of Form ADV (Firm Brochure). The Firm Brochure is provided separately to those applicable current and prospective clients. The Firm sponsors and offers the following wrap fee programs, as described in this Brochure: • 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, & Blended Strategies • IMG ETF Models • IMG Fixed Income Strategies • Advisor Directed – Discretionary • Advisor Directed – Non-Discretionary Through personal discussions with the client in which the client’s goals and objectives are established, the Firm’s investment advisor representatives, referred to as Client Advisors in this document, determine which programs and underlying portfolios are suitable to the client’s circumstances. Clients generally can request that reasonable restrictions be imposed on the types of investments to be held in their accounts. These restrictions may include prohibitions with respect to the purchase or sale of particular securities or types of securities. If, in its sole discretion, the Firm or the Portfolio Manager, believes that the restrictions are unreasonable or inappropriate for the account, the Firm will notify the Client that, unless the restrictions are removed, it may terminate the account. Clients will not be able to provide restrictions that prohibit or restrict the investment advisor of a mutual fund or Exchange Traded Fund (ETF) with respect to the purchase and sale of specific securities or types of securities within the mutual fund or ETF. Clients retain individual ownership of all securities held in their wrap fee program accounts and can request to receive trade confirmations and to vote proxies or, in certain cases where a portfolio manager accepts proxy voting authority, to delegate proxy voting authority to the portfolio managers, as described in their Firm advisory agreement and in this Brochure. Page 5 of 39 March 17, 2025  Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity needs and suitability. To ensure that our initial determination of an appropriate program and/or portfolios remains suitable and that the account continues to be managed in a manner consistent with the client’s financial circumstances and goals, we will: 1. Send quarterly written reminders with client account statements requesting any updated information regarding changes in the client’s investment objectives, risk tolerances, or financial situation, 2. At least annually, contact each participating client to determine whether there have been any changes in the client’s financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions, 3. Be reasonably available to consult with the client, and 4. Maintain client suitability information in each client’s file. General Information Regarding the Wrap Fee Programs A wrap fee program is an investment advisory program in which you pay one bundled annual fee (the “Client Advisory Fee”) to compensate the Firm and Portfolio Managers (including the Firm, when your Firm investment advisor representative (“Client Advisor”) or other Firm Portfolio Management and Research investment advisor representatives are acting as portfolio managers) for their services and to pay the brokerage transaction execution and custody and clearing costs associated with transactions in the your wrap fee program advisory account. Except as disclosed under “Item 9 – Additional Information – Custody,” with respect to client funds and securities of which we are deemed to have custody because they were pledged to our parent company, Arvest Bank, as collateral for loans, the Firm does not have custody of client funds and securities. All client funds and securities are held by a qualified custodian such that the Firm does not have physical custody of any funds and securities. The Firm’s wrap fee program accounts are held at Pershing LLC (“Pershing”), with the Firm acting as introducing broker pursuant to the Firm’s fully disclosed clearing services agreement with Pershing. Pershing serves as custodian for the accounts and provide execution and clearance of transactions. By entering into the Firm wrap fee program advisory agreement and participating in a wrap fee program, client authorizes and directs the Firm and the Portfolio Managers to trade through Pershing. Pershing provides the Firm access to its technology platform, which includes: The Proposal System, Proposal Output and Portfolio Analytics, initiation, and monitoring of new managed accounts, and the Firm and Portfolio Manager level asset and account reporting. In addition, Pershing provides the following operational services: support functions related to new account processing such as account funding notifications, processing of trade confirmation delivery instructions and proxy notices, house-holding for performance reporting and billing purposes, process account maintenance requests, billing and payment services, daily reconciliation of accounts and production of quarterly and on-demand performance reporting. Through our agreement with BNY Mellon Advisors, Inc. (“BNYMA”), an affiliate of Pershing and a SEC registered investment adviser, BNYMA provides access to individual account managers and investment advisory and discretionary services to the Firm with respect to the programs. The Firm’s clients have access to BNYMA’s investment advisory platform through their participation in the programs, including, as applicable, access to model providers and portfolio and asset managers reviewed and selected by BNYMA to participate in BNYMA’s investment advisory platform and, ultimately, reviewed and selected by the Firm to participate in the programs. BNYMA is an independent third-party money manager that also acts as a portfolio and/or overlay manager with respect to certain of the Firm-sponsored wrap fee programs (the “BNYMA Advised Programs”), as described below. Page 6 of 39 March 17, 2025  The applicable Client Advisory Fee depends in part on the program you have selected and is described later in this Item 4. The Client Advisory Fee, in addition to the annualized percentage agreed upon by you and your client advisor, is also based in part upon the market value of all assets under management in an advisory program account, including all balances in cash, money market funds, bank deposit programs, and securities positions, but excluding margin debit balance (if applicable). There may, however, be additional charges such as wire transfer fees or commissions for trades not executed through our clearing firm. The Client Advisory Fee does not cover trades executed through broker-dealers other than Pershing. Please refer to “Transactions Executed Away from Pershing” below regarding the reasoning and added costs and fees you may incur when your Portfolio Manager elects to execute trades away from Pershing. Additional information on the Client Advisory Fee is located later in Item 4 (pages 28 - 32) and in the Firm’s Wrap Fee Program Advisory Agreement. The Firm’s wrap fee program services may cost you more or less than purchasing similar services separately, assuming the services could be purchased directly from the various providers thereof. Each wrap fee program is available only for a Client Advisory Fee that is based upon a percentage of assets under management. In evaluating a wrap fee program, clients should consider several factors. A client may be able to obtain some or all the services available through a particular wrap fee program on an “unbundled” basis through the Firm or through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower (or higher) than the single, all-inclusive fee charged in the wrap fee program. Payment of an asset-based fee may produce accounting, bookkeeping or income tax results that differ from those resulting from the separate payment of (i) securities commissions and other execution costs on a trade-by-trade basis and (ii) advisory fees. Any securities or other assets used to establish a wrap fee program account may be sold, and the client will be responsible for payment of any taxes due. The Firm recommends that each client consult with his or her tax advisor or accountant regarding the tax treatment of wrap fee program accounts. Client Advisory Fees and the net fee revenues generated to the Firm vary between the various programs offered by the Firm. This presents a conflict of interest in that the Firm may receive higher fee revenues from some programs than from others and, because the Client Advisors’ salaries and bonus opportunities are based, in part, on production, i.e., the amount of net Client Advisory Fee revenues and other revenues generated to the Firm by their client accounts, we may have an incentive to recommend a higher-priced program when a comparable lower priced alternative may be available. The Firm’s wrap fee program alternative investment portfolio solutions are limited. This presents a conflict of interest by causing certain advisory clients to invest in higher-cost illiquid alternative investments through brokerage accounts that may charge more in upfront commissions than would be paid in fees through fee-based advisory accounts. The Firm’s policies require all Client Advisors to only recommend those programs and services that are in the best interest of each client. Furthermore, Client Advisors’ salaries, with exceptions for those with less tenure at our Firm (consult your Client Advisor’s ADV 2B), 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. The table on the next page provides a comparison of the wrap fee programs sponsored by the Firm. Please refer to the specific wrap fee program heading below for further information regarding the management and costs of the program you are considering. Additional information regarding BNYMA and each of the other third-party portfolio managers and model providers referenced in the table can be found in their Form ADV Part 2A. Additionally, periodic information regarding a portfolio manager or model provider and its strategy will be available to the Firm’s Client Advisors to provide to clients upon request. Page 7 of 39 March 17, 2025  Discretionary Program Wrap Fee Program Name Types of Securities Offered – Include Minimum Investment Maximum Client Advisory Fee* At Minimum Investment Amount 3.00% $25,000 (2) Yes Portfolio Manager Equities, ADRs, Mutual Funds, ETFs, Cash Arvest Wealth Management SMA Equity and Balanced Strategies 1.75% $25,000 (2) Yes Portfolio Manager Arvest Wealth Management SMA Fixed Income Strategies U.S. Treasury Securities, U.S. Agency, Cash, Residential/ Commercial MBS & CMOs, Investment Grade and High Yield Corporate and Municipal Bonds, Corporate Notes, Asset-Backed Securities Fixed Income ETF or Mutual Fund 3.00% $125,000 (2) SMAs, Models, Mutual Funds, ETFs, Equities Arvest Wealth Management Unified Managed Account (1) Yes BNYMA (Overlay Manager) and Selected Portfolio or Model Managers 1.75 % $25,000 BNYMA AdvisorFlex Portfolios (1) Yes BNYMA 16 tax-aware and 16 traditional multi- manager ETF/Mutual Fund portfolios 1.75% $25,000 BNYMA Target Risk Portfolios (1) Yes BNYMA Multi-manager ETF/Mutual Fund portfolios 1.75% $25,000 (2) Mutual Funds & ETF Strategies (1) Mutual Funds & Exchange Traded Funds Yes BNYMA and Selected Model Managers 3.00% IMG Equity, Balanced & Blended Strategies Yes IMG Equities, ADRs, Mutual Funds, ETFs, Cash $100,000 Equity Portfolios Except Strategic Equity, which is $200,000, & some Blended Strategies are 50,000 IMG ETF Models 1.75% $50,000 Strategic ETF Models Yes IMG 1.75% U.S. Treasury Securities, U.S. Agency, IMG Fixed Income Strategies Yes IMG $200,000 Managed Credit Mgd. Short-Term Credit Cash, Residential/ Commercial MBS & CMOs, Investment Grade, High Yield Corporate and Municipal Bonds, Corporate Notes, Asset-Backed Securities Fixed Income ETF or Mutual Fund $1,000,000 Core Fixed Income Mgd. Municipal Bond 1.75% $25,000 Advisor Directed– Discretionary Yes Client Advisor Equities, ADRs, Mutual Funds, UITs, ETFs and Cash 1.75% $25,000 Advisor Directed– Non-Discretionary Equities, ADRs, Mutual Funds, UITs, ETFs and Cash No Client Advisor Provides Advice * The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and.25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. (1) Denotes a BNYMA Advised Program. (2) Portfolio Manager higher minimum program values (as applicable) still apply. Page 8 of 39 March 17, 2025  Arvest Wealth Management SMA Equity and Balanced Strategies The Arvest Wealth Management SMA Equity and Balanced Strategies provides the client with an opportunity to access equity and balanced strategies of select third-party portfolio managers on which the Firm, utilizing research provided by BNYMA and the portfolio managers’ disclosure documents, among other items, conducts initial and ongoing research and due diligence. To be selected as a third-party portfolio manager under this program, certain information must be readily available to support the Firm’s initial and ongoing due diligence of the portfolio manager, and there must be sufficient economic efficiencies including the amount of fees charged by the portfolio manager or the level of interest in the portfolio manager on the part of the Firm clients. The portfolio managers have discretionary authority to invest, reinvest, sell, or retain account assets under management by them. The annual Client Advisory Fee schedule for Arvest Wealth Management SMA Equity and Balanced Strategies is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 3.00% 2.50% 2.00% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) Varies – Review Manager ADV-2A Varies – Review Manager ADV-2A Varies – Review Manager ADV-2A 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Arvest Wealth Management SMA Fixed Income Strategies The Arvest Wealth Management SMA Fixed Income Strategies program provides the client with an opportunity to access fixed income strategies of select third-party portfolio managers on which the Firm, utilizing research provided by BNYMA and the portfolio managers’ disclosure documents, among other items, conducts initial and ongoing research and due diligence. To be selected as a third-party portfolio manager under this program, certain information must be readily available to support the Firm’s initial and ongoing due diligence of the portfolio manager, and there must be sufficient economic efficiencies including the amount of fees charged by the portfolio manager or the level of interest in the portfolio manager on the part of the Firm clients. The Firm is the sponsor of the program with the portfolio managers serving as the sub-advisors. The portfolio managers have discretionary authority to invest, reinvest, sell, or retain account assets under management by them. The annual Client Advisory Fee schedule for Arvest Wealth Management SMA Fixed Income Strategies is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.25% 1.00% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) Varies – Review Manager ADV-2A Varies – Review Manager ADV-2A Varies – Review Manager ADV-2A 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. Page 9 of 39 March 17, 2025  2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .06% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Arvest Wealth Management Unified Managed Account (UMA) UMA is a multi-discipline managed account product housed in a single account. There are six models with traditional asset classes available. Additionally, non-traditional asset classes may be made available. The Firm is the sponsor, and BNYMA serves as the overlay manager. The Firm and BNYMA work together to determine the default asset allocation percentages and allowable bands for each model. BNYMA and the Firm select the investments to be used for each style allocation, also known as each sleeve, of the core models. Additionally, BNYMA investment committee and the Firm approves each investment vehicle available in the UMA. A sleeve can contain a third-party portfolio manager’s equity model, an exchange traded fund, a mutual fund, or a combination of all three. Additionally, a mutual fund model or ETF model provided by a third-party strategist (model creator) may be used within the UMA. Equity third-party money managers, as well as mutual fund or ETF model programs, transmit trade instructions to Pershing, on behalf of the Firm, for Pershing to execute on a discretionary basis. Fixed Income portfolios trading is handled different with third-party money managers execute trading their individual portfolios within the UMA. The Arvest Wealth Management UMA is flexible in that once the client has selected program available investments, the portfolio manager is granted limited discretionary trading authority to include the authority to allocate assets across the selected Models, Sleeve Managers, ETFs, mutual funds and other securities; and to implement in its discretion Model changes received from Model Providers; and to rebalance the account in accordance with target allocations and program trading parameters established by our Firm. BNYMA will allocate assets across the investment option(s) selected by the client for their UMA account, in a manner consistent with our Firm’s instruction. The client retains final authority for the asset allocation decisions and the selection of individual investment options to fill the selected asset allocation. The annual Client Advisory Fee schedule for Arvest Wealth Management UMA is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $125,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 3.00% 2.50% 2.00% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) Varies – Review Manager Disclosures Varies – Review Manager Disclosures Varies – Review Manager Disclosures 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. BNYMA AdvisorFlex Portfolios The Firm is the sponsor and BNYMA acts as the portfolio manager for the AdvisorFlex Portfolios, which is a managed account program that includes three, objectives-based strategies (Appreciation, Income and Preservation), with multiple BNYMA proprietary models within each strategy, as further described in BNYMA’s disclosure documents (BNYMA ADV Part 2A). Client, with the assistance of Client’s Firm Client Advisor, is responsible for selecting the appropriate model for the Client. For each investment selection within a model, BNYMA identifies several options from which Client may choose. Page 10 of 39 March 17, 2025  BNYMA will implement certain updates and changes to the models and may replace one investment vehicle with another and/or change the asset allocation of the model. If a model does not perform according to expectations, BNYMA may adjust the model. The annual Client Advisory Fee schedule for BNYMA Advisor Flex Portfolios is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.50% 1.15% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.10% 0.10% 0.10% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. BNYMA Target Risk Portfolios Target Risk Portfolios offers ten (10) diversified, discretionary investment models, including four (4) tax aware models, that generally include allocations to traditional asset classes. Target Risk 20/80 is the most conservative model, with the majority of the model allocated to fixed income and the balance to equities; Target Risk US Equity 100/0 is the most aggressive model with an allocation focused on equities. For the tax aware models, Target Risk Tax Aware 80/20 is the most aggressive model. The Firm is the sponsor of within the Firm Wrap Fee Program, and BNYMA serves as the portfolio manager. As portfolio manager, BNYMA determines the asset allocation strategy and selects investment vehicles for each investment style component of ten portfolios based on proprietary models. These models may consist of open- and closed- end mutual funds, exchange traded funds and other securities, as determined by BNYMA, in its sole discretion. Tax aware models include municipal bond funds in the fixed income asset classes. The ten (10) Target Risk model portfolios are: • Target Risk 20/80 • Target Risk 40/60 • Target Risk 60/40 • Target Risk 80/20 • Target Risk Equity 100/0 • Target Risk US Equity 100/0 • Target Risk Tax Aware 20/80 • Target Risk Tax Aware 40/60 • Target Risk Tax Aware 60/40 • Target Risk Tax Aware 80/20 Suitability is determined at the account level according to the model expectations. If a model does not perform according to expectations, BNYMA may adjust the model. Please consult BNYMA disclosure documents (ADV Part 2A) for additional information regarding this program. The annual Client Advisory Fee schedule for BNYMA Target Risk Portfolios is as follows: Page 11 of 39 March 17, 2025  Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.50% 1.15% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.10% 0.10% 0.10% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Mutual Funds & ETF Strategists The Mutual Funds & ETF Strategists Program is a model delivery program where the Firm, as program sponsor, selects certain third-party investment advisors (referred to herein as the strategists or model providers), made available under BNYMA’s advisory platform, who provide model portfolios to BNYMA for use in the program. Individual portfolios or models are selected by client, with the assistance and advice of Client Advisor. BNYMA acts as the overlay portfolio manager to the program and manages client accounts in its discretion based on the selected models, implementing model changes and rebalancing client accounts pursuant to target allocations and program trading parameters. The annual Client Advisory Fee schedule for the model portfolios in Arvest Wealth Management’s Mutual Funds & ETF Strategists Program is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.50% 1.15% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.00% 0.00% 0.00% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. BlackRock Investment Management, LLC Target Allocation Portfolios BlackRock Investment Management, LLC provides models to BNYMA on a non-discretionary basis for use in the program. These model strategies build portfolios with a blend of mutual fund and ETFs. These portfolios seek to provide a range of risk and return levels by diversifying across various asset classes and a wide variety of factors that can impact investments, such as asset interest rates, credit spreads and foreign exchange. Clients, with the advice of their Client Advisor, may choose from eleven different models which are also available in Tax Aware versions: • BlackRock Target Allocation - 0/100 (0% Equity and 100% Fixed Income Exposures) • BlackRock Target Allocation - 10/90 • BlackRock Target Allocation - 20/80 • BlackRock Target Allocation - 30/70 • BlackRock Target Allocation - 40/60 Page 12 of 39 March 17, 2025  • BlackRock Target Allocation - 50/50 • BlackRock Target Allocation - 60/40 • BlackRock Target Allocation - 70/30 • BlackRock Target Allocation - 80/20 • BlackRock Target Allocation - 90/10 • BlackRock Target Allocation - 100/0 (100% Equity and 0% Fixed Income Exposures) Additionally, 5 Long Horizon allocation models for investors with longer term investment time frames and 4 Target Income models for those seeking fixed income securities exposure and income generation are available. Calvert – Responsible Allocation Models The Calvert-Responsible Allocation Models are mutual fund allocation advisory model portfolios. Calvert acts as a nondiscretionary investment sub-adviser presenting model portfolios to BNYMA for use in the program. The Calvert Research and Management (CRM) Asset Allocation Team is responsible for management and oversight of the models. This includes implementing strategic asset allocation decisions, evaluating the effectiveness of their decisions, and monitoring the underlying fund options. The Calvert-Responsible Allocation Models seek to achieve their investment objectives by investing primarily in a portfolio of underlying Calvert fixed-income and equity funds that meet the models’ investment guidelines. Each of the underlying Calvert mutual funds utilizes both financial and responsible investment analysis. The models currently available under the program are: • Calvert Responsible Conservative Model whose stated objective is to seek current income and capital appreciation, consistent with the preservation of capital, • Calvert Responsible Moderate Model whose stated objective is to seek long-term capital appreciation and growth of income, with current income a secondary objective, • Calvert Responsible Growth Model whose objective is to seek long-term capital appreciation, • Calvert Responsible Income with Capital Preservation Model, whose objective is income consistent with preservation of capital, and • Calvert Responsible Aggressive Growth Model, whose objective is long-term capital appreciation. First Trust Strategic Risk Model Portfolios The First Trust Strategic Risk Model Portfolios consist of ETFs and are created by the First Trust Advisors Model Investment Committee. These models are aimed at total return while diversifying the risk exposure of various asset classes over the long term. The models currently available in order of increasing risk profile are: 1. FT Strategic Risk - Capital Preservation (Conservative Model), 2. FT Strategic Risk – Conservative Growth Model 3. FT Strategic Risk – Balanced Growth Model 4. FT Strategic Risk – Moderate Growth Model 5. FT Strategic Risk – Aggressive Growth Model Page 13 of 39 March 17, 2025  Goldman Sachs Asset Management LP – ETF Asset Allocation Models The models are created by Goldman Sachs Asset Management (GSAM) multi-asset class investment team, which analyzes the economic cycle and incorporates asset class views in seeking to position the portfolios for the current economic environment. The team uses quantitative and qualitative techniques like macro valuations, stress tests and scenario analysis in identifying and reacting to cyclical changes in economies. The GSAM models currently available in the program are following ETF models: 1. Asset Allocation Model Portfolio S&P Conservative ETF, 2. Asset Allocation Model Portfolio S&P Moderate ETF, 3. Asset Allocation Model Portfolio S&P Growth ETF, 4. Asset Allocation Model Portfolio S&P Conservative Income ETF, 5. Asset Allocation Model Portfolio S&P Enhanced Growth ETF, 6. Asset Allocation Model Portfolio S&P Moderate Conservative ETF, 7. Asset Allocation Model Portfolio S&P Moderate Growth ETF, and 8. Asset Allocation Model Portfolio S&P Ultra Conservative ETF. Russell Investment Core Model Strategies and Tax-Managed Core Model Strategies Russell Investment Management, LLC provides models on a non-discretionary basis to BNYMA for use in the program. These model strategies are designed to optimize asset allocation strategies based on various investment principles. This Russell model portfolio strategy currently provides five core Russell models and five tax-managed Russell models. These models offer clients an opportunity to select from varied asset allocations and investment styles to address a variety of investment objectives. The five core model strategies’ corresponding tax-managed versions are designed to maximize after-tax return for a client’s taxable dollars. These tax-managed models may be appropriate for clients desiring a more tax sensitive approach for their non-qualified accounts. The current five core model strategies are: 1. Conservative, 2. Moderate, 3. Balanced, 4. Growth, and 5. Equity Growth. Vanguard Advisers, Inc. ETF Strategic Model Portfolios-CRSP Vanguard Advisers, Inc. (“VAI”) provides ETF models on a non-discretionary basis to BNYMA for use in the program. These strategic model portfolios are created and maintained by VAI’s Investment Strategy Group and reflect VAI’s belief in a top-down approach stressing asset allocation, broad diversification, and low costs. Their model portfolio construction includes exposure to U.S and international equities as well as domestic and international fixed income securities. The VAI model portfolios also strive to maintain internal expense ratios that are lower than industry averages. The ETF Strategic Model Portfolios are available in several asset allocation combinations ranging from 100% bond exposure to 100% stock exposure with models representing 20% incremental changes in between. Page 14 of 39 March 17, 2025  IMG Equity, Balanced & Blended Strategies IMG Equity, Balanced & Blended Strategies portfolios include several managed Equity & Balanced portfolios that are managed by investment advisory portfolio managers from the Firm’s Portfolio Management and Research (PMR). Note, the Firm has changed the name of Investment Management Group (IMG) Portfolio Management to Portfolio Management and Research. IMG Managed Equity Portfolios Philosophy & Fee Structure Our Equity investment philosophy is built around four key characteristics: • Quality – We consider quality securities to be those of established entities with proven track records, where it is reasonable to believe that our minimum goal of capital preservation will be met. • Value – We consider value to be those securities where we believe the security is attractively priced relative to our analysis of future prospects. • Long Term Approach – We are not short-term market timers. Our goal is to construct portfolios that will perform favorably over the long haul. • Diversification – Portfolios will be well diversified by both issuer and industry. We believe that this is a crucial element of risk management. We are value-oriented and focused on consistent, long-term performance. In order to accomplish these objectives, we combine traditional analysis with systematic research to create a fundamental factor rating for stocks based on their single factor score in the areas of: • Value (stocks undervalued by the market) • Quality (well-managed financially healthy companies) Low-Volatility (stable and predictable companies) • • Momentum (strong recent performance, correlates with themes) The process leverages many points of fundamental data, supplemented by sentiment and price information, to construct proprietary metrics, which are evaluated over a long-term horizon (1-3 years) to provide comprehensive understanding of company and factor trends. Rather than attempting to “time” short term market swings, we seek to identify high-quality stocks that possess long term value. Our ultimate goal is to provide actively managed portfolios of stocks with identifiable investment opportunities at risk levels below the overall market. The annual Client Advisory Fee schedule for the IMG Equity and Balanced Portfolios is as follows: IMG Equity, Balanced, and Blended Strategies Portfolios Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $ 50,000 - $ 250,000 Next $ 250,001 - $1,000,000 Next $1,000,001 - $5,000,000 Next $5,000,001 and Up 3.00% 2.50% 2.00% 2.00% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.50% 0.50% 0.40% 0.35% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. Because the Firm investment advisor representatives in Portfolio Management and Research serve as portfolio managers under this program, the Firm gets paid the portfolio manager fee that is included in the Client Advisory fee. The Client Advisory Fee also includes a Platform Fee, estimated to range Page 15 of 39 March 17, 2025  somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Note, however, that such Platform Fee is not debited against Client Advisor’s production with respect to this Program for the purposes of calculating Client Advisor’s compensation. IMG Managed Core Equity Portfolio The IMG Managed Core Equity Portfolio is managed by investment advisory portfolio managers from the Firm’s PMR. The IMG Managed Core Equity Portfolio invests most of its assets in equity securities of companies that are Large-Cap (market capitalization > $10bln) in nature, with an emphasis on domestic U.S. corporations. Although the investment philosophy and style of investing in this Portfolio is similar to that of ABG’s Equity Common Trust Fund, PMR advisory portfolio managers make no representation that the past performance of ABG’s Equity Common Trust Fund will predict or guarantee the future performance results of the IMG Managed Core Equity Portfolio. Certain equity sub-classes (i.e., International and Mid-Cap) may be utilized from time to time using mutual funds and ETFs. As well, from time to time, a portion of the portfolio may be held in money market funds. IMG Managed Strategic Equity Portfolio The IMG Managed Strategic Equity Portfolio is managed by investment advisory portfolio managers from the Firm’s PMR. The IMG Managed Strategic Equity Portfolio invests in equity securities of companies across multiple market capitalizations and geographic locales. The IMG Managed Strategic Equity Portfolio will utilize the strategy employed by ABG’s Equity Common Trust Fund for a portion of the investments, in combination with satellite investments from higher beta equity sub-classes through the purchase of mutual funds and/or ETFs. Although a portion of the Portfolio is similar to that of ABG’s Equity Common Trust Fund, PMR advisory portfolio managers make no representation that the past performance of ABG’s Equity Common Trust Fund will predict or guarantee the future performance results of the IMG Managed Strategic Equity Portfolio. Certain equity sub-classes (i.e., International, Emerging Markets, Mid-Cap, Small-Cap) may be utilized from time to time using mutual funds and/or ETFs. In addition, from time to time, a portion of the portfolio may be held in money market funds. IMG Dividend Income and Growth (DIG) Portfolio DIG Portfolio is managed by investment advisory portfolio managers from the Firm’s PMR. The IMG DIG Portfolio is constructed of a broadly diversified selection of dividend-paying equity securities across multiple market capitalizations and sectors in the US, though some American Depository Receipts (ADRs) may be included. The Portfolio will invest in approximately 25 – 35 securities that will typically have both an attractive current yield and the likelihood to consistently raise dividends. The Portfolio team considers the strength of the company’s balance sheet, market position, corporate leadership and governance when building the Portfolio. Page 16 of 39 March 17, 2025  The Portfolio is typically fully invested, and its cash position will normally be less than 5% to 10%. Some key Portfolio guidelines: • Guideline 1: Dividend Yield > = 2% upon inclusion/rebalancing. The reasons we use 2% as the dividend yield requirement are: 1) The S&P500 current yield is approximately 2%; 2) Some growth companies have the ability and potential to raise dividends though they may not be paying the highest dividends currently; and 3) Avoid excessive concentration of investments in a few sectors. • Guideline 2: % to Target > = 20%. As capital appreciation is an important consideration, we seek to limit portfolio exposure to equities of rich valuation. • Guideline 3: Financial Viability. Cash flow sustainability and growth, liquidity, leverage, interest coverage, dividend payout policy, history, and outlook, are examined to ensure the financial viability of a firm being an ongoing entity and the sustainability of its current and future dividend payouts. • Guideline 4: Diversification. The portfolio will remain diversified across 10 sectors with no sector counting for more than 30% of the total portfolio’s stock valuation. IMG Blended Strategies Portfolios IMG Blended Strategies Portfolios are managed by investment advisory portfolio managers from the Firm's PMR. The portfolios are comprised of allocations to an IMG Dividend Income and Growth (DIG), Core Equity, or Strategic Equity Managed Portfolio combined with securities that are allocated to one of ten IMG Strategic ETF (Exchange Traded Funds) Models. Also, managed fixed income portfolios (e.g., IMG Managed Credit Fixed Income, Managed Short-Term Credit Fixed Income, Core Fixed Income, and Managed Municipal Bond) may be blended with securities of one of the IMG Strategic ETF portfolios. Finally, securities of a managed equity portfolio may be blended with securities of a managed fixed income portfolio. The combinations of managed portfolios and ETF models are selected by the client in various percentages made available by the Firm. The minimum account values for these blended strategies portfolios vary between $50,000 to $2,000,000. Please consult with your Client Advisor regarding the minimum investment and account values of the portfolio prior to investing. IMG Equity and Balanced Portfolios within the Arvest Wealth Management Unified Management Account (UMA) Certain IMG Equity and Balanced Portfolios, currently Core Equity, DIG Equity, and Strategic Equity, are also available for investment within our Firm’s UMA. Clients and potential clients investing in these portfolios should be aware of differences in the way securities transactions are completed for the UMA portfolios versus our IMG Separately Managed Account (SMA) portfolios. UMA portfolios’ security transactions are completed through a model delivery process, where the applicable managers from our Firm’s PMR relay portfolio model composition to BNYMA, who provides limited discretionary portfolio manager overlay services in executing the corresponding portfolio model trades. The differences in processes for UMA and SMAs’ trade executions means that trades necessary to incept advisory portfolios or to execute desired investment changes may take place at different times. Additionally, BNYMA, as described in their disclosure documents, has a Trade Rotation Policy which allocates the distribution of model updates across multiple programs and model providers. This means in some cases BNYMA may not execute model delivered trades until after our Firm has executed trades in the SMA, or other non-UMA portfolios we manage on a discretionary basis. Page 17 of 39 March 17, 2025  Trade Rotation Policies for IMG Equity, Balanced, Blended, and ETF Model Portfolios Our Firm’s PMR utilizes trade-rotation policies which are intended to allocate transactions equitably over time across our client base, subject to extenuating circumstances and to trading directions imposed by clients. The effectiveness of these policies can depend on market factors such as the liquidity of the securities being traded and the size of the transactions. In order to process trades for different client types and platforms, our firm maintains two trading groups: one executes trades for Arvest Bank Trust trading relationships, and another executes trades for Arvest Wealth Management Advisory trading relationships (generally wrap-fee accounts where Arvest portfolio managers have discretion). This could cause certain accounts to pay more or receive less for a security than other accounts. When necessary, the two groups use reasonable efforts to coordinate so that clients receive fair and best execution, which may include rotating initial trading between the two groups, or creating a “step out trade,” where an Arvest Bank Trust order will be aggregated with an Arvest Wealth Management Advisory order for execution. In addition, we offer advisory services through UMA model delivery platforms, where allocation decisions made by our Portfolio Managers are communicated via the overlay manager's technology provider. Clients utilizing a UMA model delivery platform will have transactions effected at the overlay manager's discretion. In order to ensure fair practice across discretionary trading platforms or UMA model delivery platforms, our firm generally initiates random trade rotation across applicable platforms. Where a platform falls in the rotation could favorably or adversely affect a client’s executions relative to other clients; however, the random nature of trade rotation is intended in the long run to provide fair placement and execution to all discretionary trading platforms and UMA model delivery platforms. Circumstances may cause a particular platform to be unable to receive trade instructions or model holdings; in such cases, we cause trades to be executed for the next platforms in rotation until the issue is resolved; and as a result, those unable to receive trade instructions or model holdings will receive different, and perhaps less favorable, prices for their transactions then they would have received had the platform received those instructions or model holdings in the original trade rotation. We may utilize rotations or allocation methods other than those described above if we believe such rotation or method is appropriate under the circumstances and that such alternative rotation or method is generally fair and equitable. We reserve the right to vary from these policies to comply with additional requirements that may be placed on us by our platforms, intermediaries, and clients, including but not limited to timing of trades and broker selection. Notwithstanding these policies, one group of clients may have transactions effected before or after another group of clients. We reserve the right to change these policies at our discretion. IMG ETF Models IMG Strategic ETF Models are managed by investment advisory portfolio managers from the Firm’s PMR. IMG Strategic ETF Models provide diversified portfolio solutions to meet defined risk tolerance objectives. There are ten strategic ETF models available. Models offered include: • Taxable Income, • Conservative Income, • Moderate Income, • Aggressive Income, • Conservative Growth & Income, • Moderate Growth & Income, • Aggressive Growth & Income, • Conservative Growth, • Moderate Growth, and • Aggressive Growth. Each model is designed around a targeted strategic asset allocation. The following asset classes can be included in the models: cash and cash alternatives, fixed income, alternative income, commodities, Page 18 of 39 March 17, 2025  currency, domestic and international equity securities. The strategic asset allocation targets provide the long-term strategic guideline. However, the models may be adjusted over time based on new research, analysis, or market developments. IMG ETF Models availability within the Arvest Wealth Management Unified Management Account (UMA) IMG Strategic ETF Models are also available for investment within our Firm’s UMA. Clients and potential clients investing in these portfolios should be aware of differences in the way securities transactions are completed for the UMA portfolios versus our non-UMA portfolios. UMA portfolios’ security transactions are completed through a model delivery process, where the applicable managers from our Firm’s PMR relay portfolio model composition to BNYMA, who provides limited discretionary portfolio manager overlay services in executing the corresponding portfolio model trades. The differences in processes for UMA and non-UMA portfolios’ trade executions means that trades necessary to incept advisory portfolios or to execute desired investment changes may take place at different times. Additionally, BNYMA, as described in their disclosure documents, has a Trade Rotation Policy which allocates the distribution of model updates across multiple programs and model providers. This means in some cases BNYMA may not execute model delivered trades until after our Firm has executed trades in non-UMA portfolios we manage on a discretionary basis. As detailed earlier in “Trade Rotation Policies for IMG Equity, Balanced, Blended, and ETF Model Portfolios” our Firm’s PMR utilizes trade-rotation polices which are intended to allocate transactions equitably over time across our client base, subject to extenuating circumstances and to trading directions imposed by clients. These same trade rotation policies also apply to our IMG Strategic ETF Models. IMG Tactical Blends ETF Models IMG Tactical Blends ETF Models are managed by investment advisory portfolio managers from the Firm's PMR. The model is comprised of allocations to a Strategic ETF Portfolio and to an absolute return strategy through a tactically managed ETF(s) or mutual fund(s). IMG utilizes a proprietary-research and scoring process to select the tactically managed mutual fund(s) and/or ETF(s). Clients may choose from various percentages of the ETF Model and tactical component made available by the Firm. This strategy is focused on mitigating large losses during the pronounced declines in the equity market and participating in as much of the gains as possible when the markets are rising. The tactical ETF(s)/fund(s) use various proprietary indicators to determine if funds should be invested in risk assets or, when defensively positioned, cash equivalents and/or fixed income. The tactical blends models may underperform during choppy markets that lack leadership or when leadership changes in the market. Additionally, the strategy may not participate fully in rising market environments. The following asset classes may be included in the tactical portion of the model: cash and cash alternatives, fixed income, commodities, real assets, domestic and international equity securities, and derivatives. Page 19 of 39 March 17, 2025  The annual Client Advisory Fee schedule for the IMG ETF Models is as follows: IMG ETF Model Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $50,000 - $200,000 Next $200,001 - $250,000 Next $250,001 - $500,000 Next $500,001 - $1,000,000 Next $1,000,001 - $5,000,000 Next $5,000,001 - $10,000,000 $10,000,001 and Up 1.75% 1.75% 1.50% 1.50% 1.15% 1.15% 1.15% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.25% 0.20% 0.20% 0.15% 0.10% 0.07% 0.05% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. Because the Firm investment advisor representatives in Portfolio Management and Research serve as portfolio managers under this program, the Firm gets paid the portfolio manager fee that is included in the Client Advisory fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Note, however, that such Platform Fee is not debited against Client Advisor’s production with respect to this Program for the purposes of calculating Client Advisor’s compensation. IMG Fixed Income Strategies Our goal with all our IMG Fixed Strategies, which are managed fixed income portfolios, is to maximize the cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. We accomplish this via the following: • Upfront and ongoing credit monitoring. We scrutinize credits prior to purchase in an attempt to avoid placing our clients in positions that are likely to deteriorate materially in quality. Our ongoing analysis of corporate and municipal issuer filings, rating agency pronouncements and news flow allows us to quickly react to deteriorating fundamentals. • Relative value analysis. We continually monitor both current and historical yield relationships between various sectors of the bond market in order to position our clients in the most attractive areas. Our goal is to own securities that we believe are likely to provide a better after-tax return relative to treasury securities of similar maturity or duration. • Managing interest rate risk. We monitor the duration and maturity structures of our portfolios with a goal of positioning client portfolios into the most attractive portions of the yield curve and in order to maintain an acceptable degree of interest rate risk. • Trading. We utilize the services of several bond dealers around the country to obtain the best prices for our clients. Secondary market trades are generally shopped competitively, to ensure best execution. PMR Fixed Income investment advisory portfolio managers will make all reasonable efforts to invest client funds into a particular strategy as soon as practicable, and generally no more than sixty days from receipt of client funds into the account. Exceptions will be made for the Managed Municipal Bond Portfolio, due to the desirability of purchasing bonds at new issuance and the irregular schedule of acceptable new issues. In most cases, however, an account should be fully invested within six months. For clients desirous of a higher weighting of the portfolio being allocated to bonds issued in their state of residence, accounts should be fully invested within twelve months. Page 20 of 39 March 17, 2025  The annual Client Advisory Fee schedule for the IMG Fixed Income Portfolio Models is as follows: IMG Fixed Income Portfolios Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee First $50,000 - $200,000 Next $200,001 - $250,000 Next $250,001 - $1,000,000 Next $1,000,001 - $5,000,000 Next $5,000,001 - $10,000,000 $10,000,001 and Up 1.75% 1.75% 1.25% 1.00% 1.00% 1.00% Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 0.35% 0.30% 0.25% 0.20% 0.15% 0.10% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. Because the Firm investment advisor representatives in Portfolio Management and Research serve as portfolio managers under this program, the Firm gets paid the portfolio manager fee that is included in the Client Advisory fee. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Note, however, that such Platform Fee is not debited against Client Advisor’s production with respect to this Program for the purposes of calculating Client Advisor’s compensation. IMG Managed Credit Fixed Income Portfolio The IMG Managed Credit Fixed Income Portfolio is a 100% fixed income portfolio, will be comprised primarily of a mix of intermediate term investment-grade corporate, taxable municipal and securitized bonds and is managed by portfolio managers from the Firm’s PMR. A high yield ETF or mutual fund may be utilized from time to time in order to enhance returns. The portfolio goal is to maximize the cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. The following guidelines and constraints apply to each portfolio: • All individual corporate bonds must be rated at least Baa3 or BBB- by one of the three major credit ratings agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase. • All individual municipal bonds must be rated at least Baa1 or BBB+ by one of the major rating agencies • (S&P, Moody’s, and Fitch) at the time of purchase. In the event an issuer’s rating (for a corporate or municipal security) falls below investment-grade by all three rating agencies, the security must be liquidated or reported to the IMG Investment Committee at the next scheduled meeting. Note that the Committee may approve the issuer for retention or authorize a timeline or price target for liquidation. • Securitized bonds must be rated Aaa or AAA by one of the three major credit ratings agencies at the time of purchase. Additionally, a commercial mortgage-backed mutual fund or ETF may be used, provided the fund/ETF has been approved for use in other IMG products. • 10% maximum concentration of the portfolio’s value in the securities of any single issuer (at market value). • Up to 10% of the portfolio’s value may be invested in a high-yield mutual fund(s) or ETF(s). • Maximum portfolio duration of 7 years. • Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide leverage. IMG Managed Short-Term Credit Fixed Income Portfolio The IMG Managed Short-Term Credit Fixed Income Portfolio is a 100% fixed income portfolio, will be comprised primarily of a mix of short term to intermediate-term investment grade corporate, taxable municipal and securitized bonds and is managed by portfolio managers from the Firm’s PMR. A high yield Page 21 of 39 March 17, 2025  ETF or mutual fund may be utilized from time to time in order to enhance returns. The portfolio goal is to maximize the cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. The following guidelines and constraints apply to each portfolio: • All individual corporate bonds must be rated at least Baa3 or BBB- by one of the three major credit ratings agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase. • All individual municipal bonds must be rated at least Baa1 or BBB+ by one of the major rating agencies • (S&P, Moody’s, and Fitch) at the time of purchase. In the event an issuer’s rating (for a corporate or municipal security) falls below investment-grade by all three rating agencies, the security must be liquidated or reported to the IMG Investment Committee at the next scheduled meeting. Note that the Committee may approve the issuer for retention or authorize a timeline or price target for liquidation. • Securitized bonds must be rated Aaa or AAA by one of the three major credit ratings agencies at the time of purchase. Additionally, a commercial mortgage-backed mutual fund or ETF may be used, provided the fund/ETF has been approved for use in other IMG products. • 10% maximum concentration of the portfolio’s value in the securities of any single issuer (at market value). • Up to 10% of the portfolio’s value may be invested in a high-yield mutual fund(s) or ETF(s). • Maximum portfolio duration of 4 years. • Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide leverage. IMG Core Fixed Income Portfolio The IMG Core Fixed Income Portfolio, formerly known as the IMG Managed Diversified Bond Portfolio, is a 100% fixed income portfolio, will be comprised primarily of a mix of short-term, intermediate-term and long-term bonds and will be broadly diversified among various fixed income sectors, including (but not limited to): U.S. treasury securities, U.S. agency securities, residential mortgage-backed securities and collateralized mortgage obligations, investment-grade corporate bonds, taxable municipal securities, commercial mortgage-backed securities, and asset-backed securities. A high-yield ETF or mutual fund may also be utilized from time to time in order to enhance returns. Portfolios will be managed by Portfolio Managers from the Firm’s PMR. The portfolio goal is to maximize the cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. The Firm undertook an action to better streamline the process of auditing, identifying, and stratifying managed strategies. As a result, the PMR elected to change the name of IMG Managed Diversified Bond to IMG Core Fixed Income to better align with this initiative. No material changes to the management of this portfolio were initiated. Only the name was changed, which will ensure that strategies are referred to by consistent nomenclature internally across the platforms the Firm’s PMR manages clients’ and the Firm’s funds. Additionally, the streamline process changes will support assets under management (AUM) calculations being conducted in a consistent manner. The primary benchmark for portfolios managed in this strategy will be the Bloomberg U.S. Aggregate Bond Index. The following guidelines and constraints apply to each portfolio: • All corporate bonds must be rated at least Baa3 or BBB- by one of the three major credit ratings agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase. • All individual municipal bonds must be rated at least Baa1 or BBB+ by one of the major rating agencies (S&P, Moody’s, and Fitch) at the time of purchase. • No more than 15% of the portfolio’s value may be invested in bonds rated below A3 or A- (by all three • rating agencies) at the time of purchase. In the event an issuer’s rating (for a corporate or municipal security) falls below investment-grade by all three rating agencies, the security must be liquidated or reported to the IMG Investment Page 22 of 39 March 17, 2025  Committee at the next scheduled meeting. Note that the Committee may approve the issuer for retention or authorize a timeline or price target for liquidation. • Securitized bonds must be rated Aaa or AAA by one of the three major credit ratings agencies at the time of purchase. Additionally, a commercial mortgage-backed mutual fund or ETF may be used, provided the fund/ETF has been approved for use in other IMG products. • 10% maximum concentration of the portfolio’s value in the securities of any single issuer (at market value). • Up to 10% of the portfolio’s value may be invested in a high-yield mutual fund(s) or ETF(s). • Portfolio duration range of 3 to 7 years. • Minimum average portfolio rating of A1 or A+. • Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide leverage. IMG Managed Municipal Bond Portfolio The IMG Managed Municipal Bond Portfolio is a 100% fixed income portfolio, comprised primarily of a mix of short term, intermediate term and long-term bonds and will be invested predominantly in securities which produce income that is exempt from federal income taxes (except under extraordinary circumstances). The portfolio managers may also place a heavier emphasis on bonds issued within the client’s state of residence. Portfolios will be managed by portfolio managers from the Firm’s PMR. The portfolio goal is to maximize the after-tax cash yield (primarily) and total return (secondarily) of each account, consistent with maintaining an overall investment-grade credit quality. The following guidelines and constraints apply to each portfolio: • All municipal bonds must be rated at least Baa2 or BBB by one of the three major credit ratings • agencies (Moody’s, Standard & Poor’s, and Fitch) at the time of purchase. In the event an issuer’s rating falls below investment-grade, or is withdrawn, by all three rating agencies, the security must be liquidated or reported to the IMG Investment Committee at the next scheduled meeting. The Committee may approve the issuer for retention or authorize a timeline or price target for liquidation. • 17.5% maximum concentration of the portfolio’s value in the securities of any single issuer (at market value) and a 10% maximum value concentration to be allocated to a specific portfolio holding. • Maximum portfolio duration to worst of 11 years with a maximum average maturity of 15 years. No more than 10% of a portfolio’s value shall be placed in maturities of 20 years and longer. • Portfolio leverage is not allowed, nor is an investment in ETFs created specifically to provide leverage. Clients are encouraged to consult a tax advisor to determine if municipal bonds are an appropriate investment prior to investing in this strategy. Advisor Directed – Discretionary The Advisor Directed-Discretionary Program is a wrap fee program designed to provide investment advice through your Client Advisor, acting as a portfolio manager, for a fee based on the value of your assets in the program. Acting under the Firm advisory agreement, your Client Advisor establishes an account at Pershing for the purpose of creating a portfolio to be managed by your Client Advisor on a discretionary basis. BNYMA has no discretion over assets managed in the Advisor Directed-Discretionary Program and is not providing investment advisory services to you. At the inception of the relationship, your Client Advisor uses your investment profile to create a congruent asset allocation and select portfolio securities. Your Client Advisor will enter transaction orders consistent with your investment profile, risk tolerance and objectives. In some cases, your Client Advisor may use your investment profile, risk tolerance and objectives information in selecting a congruous Client Advisor Page 23 of 39 March 17, 2025  developed portfolio strategy that is also employed for other clients with similar profiles and attributes. Currently the list of approved investments for the Advisor Directed-Discretionary Program includes mutual funds, exchanged traded funds (“ETFs”), options (limited to covered calls and purchases), fee- based unit investment trusts (“UITs”), equities, bonds, and other securities. Additionally, alternative, or complex investments may be employed. Examples of these alternative or complex investments include alternative mutual funds, buffered UITs, and leveraged ETFs. Descriptions of these alternative investments and risks associated with them may be found in Item 6 under “Investment Strategies” and “Risk of Loss” within this Wrap Fee Program Disclosure. Because of the account’s discretionary nature, your Client Advisor has full judgment over the selection and number of investments to be purchased or sold in the account, without obtaining your prior consent or approval. Once a portfolio is constructed, your Client Advisor monitors the account and rebalances the portfolio as changes in market conditions and client circumstances warrant. The annual Client Advisory Fee schedule for Advisor Directed – Discretionary is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 2 2 2 First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.50% 1.15% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. Note that because your Firm Client Advisor serves as portfolio manager under this program, the Firm does not assign a separate allocation for its portion of the Client Advisory Fee earned for its services as (a) program sponsor and (b) portfolio manager. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Advisor Directed – Non-Discretionary The Advisor Directed-Non-Discretionary Program is a wrap fee program similar to the Advisor Directed- Non-Discretionary Program described above in that it is also an “advisor as portfolio manager” program, designed to provide investment advice through your Client Advisor for a fee based on the value of your assets in the program. However, in the Advisor Directed Non-Discretionary Program, your Client Advisor establishes an account at Pershing for the purpose of creating a portfolio to be managed by your Client Advisor on a non-discretionary basis, meaning that you remain ultimately responsible for selecting the investments for, and approving transactions in, the account. At the inception of the relationship, your Client Advisor uses your investment profile based on recommend portfolio securities suitable for you based on an asset allocation model, consistent with your investment profile, risk tolerance and objectives. Currently the list of approved investments for the Advisor Directed- Non-Discretionary Program includes mutual funds, ETFs, options (limited to covered calls and purchases), fee-based UITs, equities, bonds, and other securities. Additionally, alternative, or complex investments may be employed. Examples of these alternative or complex investments include alternative mutual funds, buffered UITs, and leveraged ETFs. Descriptions of these alternative investments and risks associated with them may be found in Item 6 under “Investment Strategies” and “Risk of Loss” within this Wrap Fee Program Disclosure. Page 24 of 39 March 17, 2025  Because the account is not discretionary nature, your Client Advisor will provide you with investment advice, but you will retain full judgment over the selection and amount of investments to be purchased or sold in the account. Once a portfolio is constructed, your Client Advisor monitors the account and will provide you with advice and recommendation regarding rebalancing the portfolio as changes in market conditions and client circumstances warrant, but Client Advisor will not have the authority to enter into any transactions without obtaining your prior consent or approval. The annual Client Advisory Fee schedule for Advisor Directed – Non-Discretionary is as follows: Client Advisory Fee (Maximum)1 and Maximum Portfolio Manager Fees2 (included in Client Advisory Fee) Client Account Size Client Advisory Fee Maximum Portfolio Manager Fee2 (Included in Client Advisory Fee) 2 2 2 First $25,000 - $250,000 Next $250,001 - $1,000,000 $1,000,001 and up 1.75% 1.50% 1.15% 1 Client Advisory Fees listed above are “Blended” meaning for each breakpoint achieved, the accompanying rate is charged for assets within the breakpoints range. The Client Advisory Fees in each breakpoint’s range are then added, or blended, together. 2 The portfolio manager fees are included in the Client Advisory Fee. Note that because your Firm Client Advisor serves as portfolio manager under this program, the Firm does not assign a separate allocation for its portion of the Client Advisory Fee earned for its services as (a) program sponsor and (b) portfolio manager. The Client Advisory Fee also includes a Platform Fee, estimated to range somewhere between .05% and .25%, charged by the Firm, based upon client account size, to offset a program fee that BNYMA and Pershing charge the Firm as compensation for advisory (BNYMA’s overlay/portfolio management services with respect to the BNYMA Advised Programs), administrative, clearing and custody services. Modification of Client Advisory Fee Schedules/Fees Negotiable The Firm reserves the right, in its sole discretion, to negotiate or modify (either up or down) the Client Advisory Fee schedules set forth herein for any client due to a variety of factors, including but not limited to the level of reporting and administrative operations required to service an account, the investment strategy or style, the number of portfolios or accounts involved, assets to be placed under management and/or the number and types of services provided to the client. Because the Firm’s fees are negotiable, the actual fee paid by any client or group of clients may be different from the fees reflected in Firm’s Client Advisory Fee schedules herein. The specific Client Advisory Fee schedule for a client will be identified in the Firm advisory agreement with each client. Billing The Client Advisory Fee is charged quarterly in advance and is calculated using the market value of all assets under management in an advisory program account, including all balances in cash, money market funds, bank deposit programs, and securities’ positions, but excluding margin debit balance (if applicable). The Client Advisory Fee is calculated as of the last business day of the previous quarter by our custodian or BNYMA and is due on the first business day of each calendar quarter. This last business day of the previous quarter valuation includes the values of any assets sold but not yet settled but does not include the values of any assets purchased but not yet settled. The initial Client Advisory Fee is based upon the market value of all assets under management in the account at inception is due in full on the date the account is accepted by the Firm and the custodian. For the period from inception date through the last business day of the then current full calendar quarter, the initial Client Advisory Fee is pro-rated accordingly. Our clearing firm debits your account for the fees charged by the Firm, BNYMA, Pershing, and portfolio managers and model providers, as applicable, and remits the fees to the respective parties accordingly. Additions and Withdrawals: Clients, with Firm Wrap Fee Program accounts, may make additions to the account at any time. Additions may be in cash and securities, subject to the requirements of the program and portfolios selected and the ability of the Firm or the portfolio manager to decline to accept particular Page 25 of 39 March 17, 2025  securities. A client may withdraw assets from the account upon request. Written request or written confirmation from the client may be required for certain withdrawals, including, when following the withdrawal of assets from the account would be below the program’s minimum account value requirements, in connection with certain account terminations, or in certain other circumstances as the Firm may determine in its sole discretion. The Client acknowledges that any withdrawals from the account will be subject to, and the client shall allow time for, the usual and customary securities trading and settlement procedures, and processes relating to the transfer of funds electronically or via physical check (generally 2 - 5 business days not counting actual mailing time for a check). A request to add or withdrawal from the account should not be considered a “market order” because the corresponding security trades may take multiple days to execute. Adjustments to the Client Advisory Fees related to additions and withdrawals are made quarterly (for the prior quarter) when net flows reach a cumulative threshold of $5,000. The adjustments will be prorated based upon the dates of the additions and/or withdrawals. Please refer to your Firm advisory agreement for specific information concerning your Client Advisory Fee and for additional information regarding our billing practices. Program Changes Clients may change their existing program within the Firm’s Wrap Fee Program either through executing a new advisory agreement, or in certain instances, through completion and submission of the “Change A Manager And/Or Style” form without executing a new advisory agreement. The Firm, in processing a program change for any account, will refund any prepaid, unearned fees on the program being terminated. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Additionally, the Firm will treat the billing on the new advisory program in similar fashion to how we would treat a new advisory account inception i.e. The initial Client Advisory Fee for the new program is based upon the market value of all assets under management in the account at new program’s inception and is due in full on the date the account is accepted by the Firm and the custodian - for the period from the new program’s inception date through the last business day of the then current full calendar quarter, the initial Client Advisory Fee for the new program is pro-rated accordingly. Termination of the Advisory Relationship Client may terminate his or her Firm advisory agreement, without penalty, within five business days of signing, and receive a full refund of all Client Advisor Fees paid by the client. Following the initial five business day period, the Firm advisory agreement may be terminated by either party upon request to the other party. Upon termination of the Firm advisory agreement, the Firm or the custodian will make a pro- rata refund to the client of the Client Advisory Fee paid to the Firm pursuant to this Agreement for the period after the effective date of termination through the end of the then current Client Advisory Fee billing period. Termination will not, however, affect liabilities or obligations of the Firm and the client incurred, or arising under transactions initiated, prior to such termination. The client may incur additional charges or fees in connection with transfers of securities or cash following termination of advisory status. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Additionally, the Firm may terminate the advisory status of a client’s account that falls below the minimum investment and balance requirements of the advisory portfolio they are invested. Our Firm’s Investment Advisor Representatives (IARs) will attempt to contact clients with below minimum investment balances to discuss alternatives such as adding funds to the portfolio, repositioning to advisory portfolios with Page 26 of 39 March 17, 2025  lower minimum balance requirements (as applicable), movement of security positions in kind to brokerage account status, or liquidating account security positions. The Firm may terminate an account’s advisory status when its associates attempted but were unable to contact these impacted clients. The securities will be maintained “in kind” in these instances until further direction is received from the client. Similar to additions and withdrawals requests the client shall allow time for, the usual and customary securities trading and settlement procedures, and processes relating to the transfer of funds electronically or via physical check (generally 2 - 5 business days not counting actual mailing time for a check). A request to add or withdrawal from the account should not be considered a “market order” because the corresponding security trades may take multiple days to execute. ERISA Accounts The Firm is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act (“ERISA”). As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, the Firm may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees. Should the Firm or our related persons receive a commission or 12b-1 fee payment in a Firm advisory ERISA account, these fees will be rebated back to the client’s account. Other Fees and Additional Compensation There may be other costs assessed which are not included in the Client Advisory Fee, such as fees, expenses and charges levied by mutual funds, ETFs, American Depositary Receipts (ADRs) and money market funds. In addition, there are other fees charged by the custodian, as applicable, that are not included in your Client Advisory Fee, such as costs associated with the purchase and sale of certain mutual funds and other similar securities held in your account, exchange or auction fees, transfer taxes, costs for transactions executed other than at the custodian, any fees imposed by the SEC, electronic fund and wire transfer fees, security reorganizations, voluntary and mandatory corporate actions, fees for client-initiated transfers, costs associated with investment of your funds in cash sweep funds, annual custodial fees for Simplified Employee Pension (SEP), Simple IRAs, other retirement accounts (excluding only Traditional and Roth IRAs) and termination fees for all IRA and retirement accounts and other charges mandated by law. Account and service fees such as the annual IRA custodial fees for SEP and Simple IRAs and IRA account termination fees are charged in amounts that exceed the costs incurred by the Firm. This reflects a voluntary markup that the Firm receives on these fees and charges. Please refer to the Firm’s current “Schedule of Miscellaneous Account & Service Fees” available at our disclosures web page www.arvest.com/documents-and- resources/awm-disclosures or reach out to your Client Advisor should you have any questions relating to these charges. The Firm diligently attempts to ensure that, when exercising discretionary authority, portfolio managers invest client advisory wrap fee program account assets in a mutual fund’s most cost efficient, non-12b-1 fee share class available in an effort to avoid having client returns reduced by distribution (and/or shareholder services) 12b-1 fees and lower overall investment costs for our clients. Notwithstanding these efforts, should 12b-1 fees be received by the Firm with respect to a client advisory wrap fee program account, these fees will be rebated to the client or their account. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully Page 27 of 39 March 17, 2025  understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Various vendors, product providers, distributors and others have provided and may, in the future provide, compensation by paying some expenses related to the following activities: training and education to include the Firm’s training and recognition events. Also, certain vendors have, and may in the future, provide marketing support (example seminars), invite us to participate in conferences, or on-line training that may further Investment Advisor Representatives' and employees' skills and knowledge. Also, some have and may, in the future occasionally provide us with gifts, meals and entertainment of reasonable value consistent with industry rules and regulations. Under the Firm’s clearing agreement with Pershing, Pershing has made available to the Firm certain incentives, such as credits to cover implementation, technology, and strategic plan support costs and an annual cash incentive based upon the net annual growth in assets we introduce to our clearing firm, exclusive of market value changes. These incentives, if received, will not be credited against, and will not reduce, the Client Advisory Fees or other amounts a client owes to the Firm. Although these incentives, if received, may be considered compensation to the Firm, they will not be applied towards our Client Advisors’ production in connection with the determination of their production-based salaries. Additionally, under the Firm’s clearing agreement with Pershing, the Firm is subject to a significant termination fee if the clearing agreement is terminated prior to the eight-year agreement term. Although this termination clause does not represent current revenue to our firm, it does create a financial incentive for the Firm to maintain our clearing agreement with Pershing, even if it is not in the best interest of advisory clients to do so. Cash Sweep Program The Firm offers an automatic cash sweep program where uninvested cash balances in eligible client accounts held with Pershing will be invested in an FDIC-insured bank deposit sweep vehicle (which is currently the default option) or in a money market fund (subject to certain limitations and restrictions, including with respect to minimum sweep balances and advisory account type), as more fully described in our Cash Sweep Disclosure document, available at www.arvest.com/documents-and-resources/awm- disclosures. The Firm’s agreement with Pershing provides that Pershing will compensate the Firm based on the balances of client accounts held in such sweep accounts. The amount of compensation varies between the various cash sweep alternatives, which clients may choose from. The salaries and bonus opportunities of Client Advisors are based in part on production, i.e., the amount of net Client Advisory fee revenues and other revenues, including cash sweep program revenues, generated to the Firm by their advisory client accounts. Consequently, the possibility of this compensation creates an incentive for the Firm, or its Client Advisors, to make decisions for the account which would have the effect of increasing this compensation. Such compensation or payments are not credited against, and will not reduce, the Client Advisory Fees or other amounts a client owes to the Firm. The Firm does not receive any fees or compensation from the sweep vehicle(s) designated for IRA and ERISA accounts. Please refer to our Cash Sweep Disclosure document for additional information about our Cash Sweep program, including information regarding the share of cash sweep revenues we receive on each of the available cash sweep vehicles, or reach out to your Client Advisor should you have any questions. BNYMA Advised Program accounts will have their cash sweeps determined by BNY Mellon Advisors, Inc. Information in this regard may be found in BNYMA’s disclosure documents, which are provided to clients in those programs. The Firm and its Client Advisors do not receive any cash sweep compensation with respect to those BNYMA Advised Programs. Page 28 of 39 March 17, 2025  Margin Accounts Under the Firm’s clearing agreement with Pershing, if a client obtains a margin loan from Pershing, the Firm will receive a share of the margin interest generated on debit balances in the client’s margin account. The Firm establishes the interest rate schedule that determines the interest charges to your account. The amounts charged include a markup of the rates that Pershing charges the Firm for margin financing. As the Firm earns additional compensation when you have a margin balance, this creates an incentive for our firm to establish the interest rate schedule at a level that is financially advantageous for our firm. Additionally, the Firm’s receipt of interest revenue creates a financial incentive for our firm to suggest strategies using margin that may not be in a client’s best interest. The Firm’s Client Advisors are not compensated on margin interest revenue generated to the Firm by their assigned client accounts. Transactions Executed Away from Pershing Implementation and execution of transactions in the wrap fee programs are conducted by the Firm as an introducing firm on a fully disclosed basis through its clearing firm, Pershing, LLC. However, portfolio managers associated with the wrap fee programs have the option of executing transactions away from Pershing if they believe it is in the client’s best interests to do so. This is frequently referred to as “trading away” or “step out trading.” The portfolio manager – not the Firm – decides as to when it trades with Pershing or away from Pershing. A portfolio manager’s ability to trade away is not limited, as the portfolio manager’s fiduciary duty to clients, as well as its expertise in trading its portfolio securities, makes the portfolio manager responsible for determining the suitability of trading away from Pershing. The wrap fees disclosed previously in this document do not cover transaction charges or other charges, including commissions, markups, and markdowns resulting from transactions effected through or with a broker dealer other than Pershing, which is the custodian. In addition, some portfolio managers executing trades in U.S. Treasury securities will incur a system cost from the portal through which the trades are processed. As a result, these trades could be more costly than trades that execute with Pershing and could negatively affect the performance of the account. Further, the additional trading costs will not be reflected on clients’ trade confirmations or account statements. Typically, the executing broker will embed the added costs into the transaction price, making it difficult to determine the exact added cost for transactions executed away from Pershing. The Firm does not receive additional fees when portfolio managers execute transactions away from Pershing. Considering the additional charges that apply to step out transactions, the portfolio manager could determine that placing clients’ transactions with Pershing is in clients’ best interest. Alternatively, the portfolio manager may execute transactions with a broker-dealer firm other than Pershing if the portfolio manager believes that doing so is consistent with its obligation to obtain best execution. Item 5 Account Requirements and Types of Clients Account Requirements Please refer to Item 4 for specific information regarding the minimum account size required for each of our programs. Page 29 of 39 March 17, 2025  Types of Clients The Firm provides the advisory services described in this Brochure to individuals, pension or profit-sharing plans, trusts, charitable organizations, corporations, and other business entities. Item 6 Portfolio Manager Selection and Evaluation Selection and Review of Portfolio Managers The Firm Client Advisors generally determine which portfolio managers to recommend to clients. The Firm selects portfolio managers for its wrap fee programs based upon the nature of the products offered and services provided. The Firm may also add or remove portfolio managers from the programs based upon the requests of the Firm Client Advisors, or for any reason, in its sole discretion. The Firm uses information provided by BNYMA and portfolio managers, as well as publicly available information, in reviewing and selecting third-party portfolio managers and model managers suitable for the Firm’s wrap fee programs. BNYMA provides information and research to the Firm with respect to managers that are research covered by BNYMA. BNYMA uses proprietary processes for screening and evaluating managers made available under its advisory platform that focuses on quantitative factors such as historical performance and volatility, as well as the manager's reputation and approach to investing. The Firm does not audit, verify, or guarantee the accuracy, completeness, or methods of calculation of any historic or future performance or other information provided by BNYMA or any third-party portfolio manager. There can be no assurance that the performance information from BNYMA and portfolio manager, or other source is or will be calculated on any uniform or consistent basis or has been or will be calculated according to or based on any industry or other standards. The Firm’s selection and review process with respect to the Firm related persons serving as portfolio managers under our wrap fee programs differs from the selection and review process described above with respect to third party portfolio managers. The minimum requirements for the Firm Client Advisors and other investment advisor representatives to serve as a Firm portfolio manager include college degree or satisfactory past relevant business and portfolio management experience, in addition to the required industry examinations and registrations, if any. The Firm conducts a detailed annual review of its IMG portfolio management team’s processes and activities as part of the Firm’s compliance review of its supervisory and operational departments. All associates have annual written performance reviews. Advisory Business The Firm acts as discretionary portfolio manager for clients in the Arvest Wealth Management Advisor Directed Discretionary Program and IMG portfolios. Please refer to Item 4 for a description of (a) our portfolio management services with respect to these programs, (b) how we tailor our advisory services to our clients’ needs and (c) clients’ ability to impose reasonable restrictions on investing in certain securities or types of securities, and (d) the portion of the Client Advisory Fees that we receive for our services as portfolio manager with respect to these programs. Performance-Based Fees and Side-by-Side Management Fees based on a share of capital gains or capital appreciation of assets of a client are commonly referred to as “performance-based fees.” Neither the Firm nor any of its supervised persons accept performance- based fees. Page 30 of 39 March 17, 2025  Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We may use the following methods of analysis in formulating our investment advice and/or managing client assets in the programs for which we act as portfolio managers (the IMG Portfolios, the Adviser Directed- Discretionary Program, and the Adviser Directed-Non-Discretionary Program): Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis. We analyze past market movements and apply that analysis to the present to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. Quantitative Analysis. We use mathematical models to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. A risk is using qualitative analysis is that our subjective judgment may prove incorrect. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. Investment Strategies As portfolio managers, we use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client’s account for a year or longer. Typically, we employ this strategy when: • We believe the securities to be currently undervalued, and/or • We want exposure to a particular asset class over time, regardless of the current projection for this class. Page 31 of 39 March 17, 2025  Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them within a relatively brief time (typically a year or less). We do this to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. Use of Options. We may use options as an investment strategy. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. A seller, or writer, of an option contract receives a premium (credit) from the buyer and has obligations at the option’s exercise. An option, just like a stock or bond, is a security. An option is also a derivative because it derives its value from an underlying asset. The two types of options are “calls” and “puts”: • A “call” gives us the right to buy an asset at a certain price within a specific period of time. We will buy a “call” if we have determined that the stock will increase substantially before the option expires. Additionally, we could sell a call to receive a premium, keeping in mind our obligations to the buyer if the options are exercised. • A “put” gives us, the holder, the right to sell an asset at a certain price within a specific period of time. We will buy a “put” if we have determined that the price of the stock will fall before the option expires. Additionally, we could sell a put to receive a premium, keeping in mind our obligations to the buyer if the options are exercised. We will use options to speculate on the possibility of a sharp price swing. We will also use options to “hedge” a purchase of the underlying security; in other words, we will use an option purchase to limit the potential upside and downside of a security we have purchased for your portfolio. We use “covered calls,” in which we sell an option on security you own. In this strategy, you receive a fee for making the option available, and the person purchasing the option has the right to buy the security from you at an agreed-upon price. We use a “spreading strategy,” in which we purchase two or more option contracts (for example, a “call” option that you buy and a “call” option that you sell) for the same underlying security. This effectively puts you on both sides of the market, but with the ability to vary price, time, and other factors. We, and other portfolio managers in our wrap fee program, may also employ complex or alternative investments. Examples of these alternative investments are alternative mutual funds, buffered UITs, and leveraged ETFs. Alternative mutual funds include a wide range of investment objectives to meet various needs. Unlike traditional mutual funds, alternative mutual funds often seek to accomplish their investment objectives by investing in non-traditional investments such as global real estate, start-up companies, or commodities. Additionally, these alt funds generally use more complex investment and trading strategies than traditional mutual funds, such as selling stocks short, or using derivatives or leverage. A Buffered UIT uses an investment strategy designed to provide upside performance potential, subject to a cap, with some downside protection. The portfolios invest in options based on the price performance of shares of a reference asset, often an ETF. The performance may be impacted by a variety of factors to include among others, redemption activity, dilution of your investment, unusual market events, market movements, and changes in the liquidity of options. Leveraged ETFs are exchange-traded funds that use financial derivatives and debt as leverage to amplify the returns of an underlying index. Generally leveraged ETFs are more expensive than traditional ETFs and the potential for greater (amplified) performance also brings the potential for greater losses. Risk of Loss Investments in securities are inherently risky and clients should be prepared to bear the risk that they could lose some or all the money they invest. Material risk factors related to the investment strategies Page 32 of 39 March 17, 2025  we, or other portfolio managers within our wrap fee program, may use and asset classes that may be invested into include, but are not limited to, the following: Asset Allocation Risk - A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry, or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Risks for all forms of analysis - Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Long-term purchase strategy risk - A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Risks Associated with Investing in Commodities. An investment in commodity-linked derivative instruments may be subject to greater volatility than investments in traditional securities, particularly if the instruments involve leverage. The value of commodity-linked derivative instruments may be affected by changes in overall market movements, commodity index volatility, changes in interest rates, or factors affecting a particular industry or commodity, such as drought, floods, weather, livestock disease, embargoes, tariffs, and international economic, political, and regulatory developments. The use of derivatives presents risks different from, and possibly greater than, the risks associated with investing directly in traditional securities. Among the risks presented are market risk, credit risk, counterparty risk, leverage risk and liquidity risk. The use of derivatives can lead to losses because of adverse movements in the price or value of the underlying asset, index, or rate which may be magnified by certain features of the derivatives. Risks Associated with Investing in an Exchange-Traded Fund (ETF) - ETFs are subject to market risk, including the possible loss of principal. The value of the portfolio will fluctuate with the value of the underlying securities. ETFs may trade for less than their net asset value. ETFs may have underlying investment strategy risks similar to investing in commodities, bonds, real estate, international markets or currencies, emerging growth companies, or specific sectors. Investors should consider an ETF’s investment objective, risks, charges, and expenses carefully before investing. Convertible Securities Risk - Convertible securities are subject to the usual risks associated with debt securities, such as interest rate risk and credit risk. Convertible securities also react to changes in the value of the common stock into which they convert and are thus subject to market risk. Counterparty Risk - The risk that a counterparty to a financial instrument entered into by the Portfolio Manager or held by a special purpose or structured vehicle becomes bankrupt or otherwise fails to perform its obligations due to financial difficulties, including making payments to the Portfolio. • Counterparty risk involved in ETFs with full replication and ETFs with representative sampling strategies – An ETF using a full replication strategy generally aims to invest into all constituent assets in the same weightings as its benchmark. ETFs adopting a representative sampling strategy will invest in some, but not all the relevant constituent assets. ETFs investing through synthetic instruments issued by third parties carry more counterparty risk than ETFs investing directly in the underlying assets. Page 33 of 39 March 17, 2025  • Synthetic replication strategies – ETFs using a synthetic replication strategy use swaps or other derivative instruments to gain exposure to a benchmark. Currently, synthetic replication ETFs can be further categorized into two forms: • Swap-based ETFs – Total return swaps allow ETF managers to replicate the benchmark performance of ETFs without purchasing the underlying assets. Swap-based ETFs are exposed to counterparty risk of the swap dealers and may suffer losses if such dealers default or fail to honor their contractual commitments. • Derivative embedded ETFs – ETF managers may use other derivative instruments to synthetically replicate the economic benefit of the relevant benchmark. The derivative instruments may be issued by one or multiple issuers. Derivative embedded ETFs are subject to the counterparty risk of the derivative instruments’ issuers and may suffer losses if such issuers default or fail to honor their contractual commitments. Cybersecurity Risk – Investment Advisers, in addition to the clients they serve, are exposed to, and rely on, a broad array of interconnected systems and networks, both internally and through service providers such as custodians, brokers, dealers, and technology providers. All these parties use digital engagement tools and other technology to varying degrees in their communications and engagements. As a result, they face cybersecurity risks and may experience cybersecurity incidents. Cybersecurity risks, include, but are not limited to compromised company, employee, or client data, corruption or loss of data, and disruption or inability to provide services. Default Risk – The risk that the issuer of a fixed-income security or the counterparty to a contract may or will default or otherwise become unable or unwilling to honor a financial obligation, such as making interest or principal payments. Foreign Currency Risk – Securities issued by foreign companies are frequently denominated in foreign currencies. The change in value of a foreign currency against the U.S. dollar will result in a change in the U.S. dollar value of securities denominated in that foreign currency. Foreign Investment Risk – The Portfolio may invest in securities of foreign issuers. Investments in securities of foreign securities are subject to risks associated with foreign markets, such as adverse political, social, and economic developments, accounting standards or governmental supervision that is not consistent with that to which U.S. companies are subject, limited information about foreign companies, and less liquidity in foreign markets. These risks may be more pronounced for investments in developing countries. Government Agency Risk – Direct obligations of the U.S. Government such as Treasury bills, notes and bonds are supported by its full faith and credit. Indirect obligations issued by Federal agencies and government-sponsored entities generally are not backed by the full faith and credit of the U.S. Treasury. Accordingly, while U.S. Government agencies and instrumentalities may be chartered or sponsored by Acts of Congress, their securities are neither issued nor guaranteed by the U.S. Treasury. Inflation risk – Prices of a Portfolio’s investments will likely move in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. Interest Rate Risk – Fixed income securities increase or decrease in value based on changes in interest rates. If rates increase, the value of fixed income securities generally declines. On the other hand, if rates fall, the value of the fixed income securities generally increases. Legislative Risk – There can be no assurance as to what actions might be taken by any federal, state, or municipal legal authority that may adversely affect investments held by the Portfolio. These actions may include (but are not limited to) changes on environmental issues, regulation, social issues, and taxation. Page 34 of 39 March 17, 2025  Liquidity Risk – Due to a lack of demand in the marketplace or other factors, a Portfolio may not be able to sell some or all the investments promptly or may only be able to sell investments at less than desired prices. Management Risk – The Portfolio is actively-managed. The Portfolio’s value may decrease if the Firm pursues unsuccessful investments or fails to correctly identify risks affecting the broad economy or specific issuers comprising the Portfolio. Market Risk – The market value of securities may fall or fail to rise. Market risk may affect a single issuer, sector of the economy, industry, or the market as a whole. The market value of securities may fluctuate, sometimes rapidly and unpredictably. Municipal Obligation Risk – Municipal security prices can be significantly affected by political changes as well as uncertainties in the municipal market related to taxation, legislative changes, or the rights of municipal security holders. Because many municipal securities are issued to finance similar projects, especially those relating to education, healthcare, transportation and utilities, conditions in those market sectors can affect municipal bond prices. Prepayment Risk – Issuers may choose to pay off debt earlier than the stated maturity date on a bond. When this happens, the bond fund may not be able to reinvest the proceeds in an investment with as high a return or yield. Real Estate Industry and Real Estate Investment Trust (REIT) Risk - These risks can include fluctuations in the value of the underlying properties, defaults by borrowers or tenants, market saturation, decreases in market rates for rents, and other economic, political, or regulatory occurrences affecting the real estate industry, including REITs. REITs depend upon specialized management skills, may have limited financial resources, may have less trading volume, and may be subject to more abrupt or erratic price movements than the overall securities markets. REITs are also subject to the risk of failing to qualify for tax-free pass- through of income. Risks in Commercial Real Estate Market – A Portfolio’s investments in commercial real estate are subject to risks affecting real estate investments generally (including market conditions, competition, property obsolescence, changes in interest rates and casualty to real estate). Risk of Impaired Credit Quality – If debt obligations held by a Portfolio are downgraded by ratings agencies, go into default, or if management action, legislation or other government action reduces the issuers’ ability to pay principal and interest when due, the obligations’ value may decline and a Portfolio’s value may be reduced. Because the ability of an issuer of a lower-rated or unrated obligation (including particularly “junk” or “high yield” bonds) to pay principal and interest when due is typically less certain than for an issuer of a higher rated obligation, lower-rated and unrated obligations are generally more vulnerable than higher-rated obligations to default, ratings downgrades, and liquidity risk. Political, economic, and other factors also may adversely affect governmental issues. Commodities and Commodity Derivatives Investing Risk – An investment in commodity-linked derivative instruments may be subject to greater volatility than investments in traditional securities, particularly if the instruments involve leverage. The value of commodity-linked derivative instruments may be affected by changes in overall market movements, commodity index volatility, changes in interest rates, or factors affecting a particular industry or commodity, such as drought, floods, weather, livestock disease, embargoes, tariffs, and international economic, political, and regulatory developments. The use of derivatives presents risks different from, and possibly greater than, the risks associated with investing directly in traditional securities. Among the risks presented are market risk, credit risk, counterparty risk, leverage risk and liquidity risk. The use of derivatives can lead to losses because of adverse movements in Page 35 of 39 March 17, 2025  the price or value of the underlying asset, index, or rate which may be magnified by certain features of the derivatives. Small-Cap and Mid-Cap Risk – Securities of small or mid-capitalization companies that may not have the size, resources, and other assets of large-capitalization companies. As a result, the securities of small- or mid-cap companies held by the Portfolio may be subject to greater market risks and fluctuations in value than large-cap companies or may not correspond to changes in the stock market in general. Risks associated with Complex or Alternative Investments – These types of investments are often more speculative, illiquid, expensive, and subject to higher degree of risk than traditional securities. The potential benefits of using derivative and illiquid investments and, or complex trading strategies could have a negative impact on a client’s ability to achieve their investment objectives. Voting Client Securities The Firm does not have and will not accept authority to vote client securities, with respect to any of the programs described in this Brochure, except for the IMG Programs, as described below. IMG Programs The Firm acts as discretionary portfolio manager through its PMR for clients in the IMG portfolios. The conditions that govern the PMR’s authority to vote proxies on behalf of clients are contained in our advisory agreement. If Clients investing in the IMG portfolios elected to delegate to IMG program portfolio manager the authority to vote proxies on their behalf, pursuant the advisory agreement, PMR investment advisory portfolio managers will vote proxies on behalf of its clients. If clients elected to vote proxies on their own behalf, they will receive proxy related information directly from their custodian. We will vote proxies in the best interests of clients and in accordance with our established policies and procedures. It is our policy to vote client shares primarily in conformity with Glass-Lewis & Co. recommendations. Glass-Lewis & Co. is a neutral third party that issues recommendations based on its own internal guidelines. Using Glass-Lewis & Co. recommendations assist in limiting conflict of interest issues between the Firm and our clients. PMR utilizes a third-party electronic voting platform, ProxyEdge (a division of Broadridge Financial Solutions, Inc.) to vote client shares. The Firm or ProxyEdge retains a record of all proxy voting information for the requisite amount of time, including a copy of each proxy statement received, a record of each vote cast, and a copy of any document created that was material to deciding on how to vote proxies. Item 7 Client Information Provided to Portfolio Managers You must complete an account profile with the assistance of your Client Advisor. The account profile outlines your investment objectives, financial circumstances, risk tolerance and any restrictions you may wish to impose on your investment activities. We will notify you in writing at least annually to update your account profile and indicate if there have been any changes in your financial situation, investment objectives or instructions. You agree to inform us in writing of any material change in your financial circumstances that might affect the way your assets should be invested. Your Client Advisor will be reasonably available to you for consultation on these matters and will act on any changes in your account profile deemed to be material or appropriate as soon as practical after we become aware of the change. Page 36 of 39 March 17, 2025  Information Provided to Affiliated Portfolio Managers The Firm employees who serve as portfolio managers have access to all client information obtained by the Firm and Client Advisors with respect to the particular client accounts they manage. Information Provided to Non-affiliated Portfolio Managers Non-affiliated portfolio managers have access to potentially all client information with respect to clients whose accounts they manage through a “distributor workstation” that is used to monitor and manage client activity. Such information includes client identifying information such as name, address, and tax ID; account profile information such as investment objective and risk tolerance; and administrative information such as disbursement requests, statements, confirmations, and other documents prepared by the custodian, Pershing. In addition, individual portfolio managers sometimes request additional information such as copies of client account agreements, other account related agreements, such as IRA adoption forms and beneficiary designations, and IRS form W-9. To the extent the Firm believes such requests are reasonably related and necessary to the services being provided by the third-party portfolio managers, the Firm generally honors those requests. Item 8 Client Contact with Portfolio Managers The primary contact for clients with respect to all Firm-sponsored wrap fee advisory programs is the client’s Client Advisor, including programs where the Client Advisor acts as portfolio manager and programs where a different Firm affiliated party or third-party acts as portfolio manager. There are no restrictions on a client’s access to his or her Client Advisor. Non-affiliated portfolio managers typically service clients of multiple firms, and direct client access to those portfolio managers is, therefore, not routine. In most cases, the Firm clients rely on the firm to monitor the performance and appropriateness of non-affiliated portfolio managers and to manage the relationship. Nevertheless, the Firm is not aware of any prohibition against the client communicating directly with non-affiliated Portfolio Managers in appropriate. In certain instances, your Client Advisor may coordinate a response with the Portfolio Manager (if applicable) or arrange for you to consult directly with the Portfolio Manager. Item 9 Additional Information Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. In May 2012, The Oklahoma Department of Securities (ODS) filed an Enforcement Division Recommendation against the Firm, its broker-dealer division, and our Chief Compliance Officer, alleging violations of our written policies and procedures, as it related to our handling of verbal complaints. There were no alleged violations of illegal activities, or that any customer suffered financial loss. In January 2013, the ODS and the Firm reached a verbal settlement, with the Firm agreeing to amend its policies and procedures regarding the handling of customer complaints, pay a $20,000 fine and that the Chief Compliance Officer receive a three-day suspension of his duties, as it relates to his activities in the State of Oklahoma. A final Order was entered on May 9, 2013, confirming this agreement. We have amended our policies and procedures, paid the fine and the CCO has served the suspension. The Firm, as a broker-dealer, is a member of FINRA. FINRA alleged that the Firm violated rules 4 and 5 of Regulation S-P, NASD Rule 3010(a)(2) and (b)(1), and FINRA Rules 3110(a)(2), (b)(1) and 2010 by, between January 2009 and December 2016, failing to provide required initial and annual privacy notices to certain brokerage customers and failing to establish and maintain a supervisory system reasonably designed to Page 37 of 39 March 17, 2025  ensure that it was meeting its privacy notice obligations. In May 2018, without admitting or denying FINRA’s findings, the Firm consented to the entry of findings and to the following sanctions, including a censure, a fine in the amount of $150,000, and an undertaking to revise as necessary its policies, procedures, and internal controls, which the Firm has already complied with. You can access additional information about our firm and our management personnel on the SEC’s website adviserinfo.sec.gov, and on FINRA’s website, https://brokercheck.finra.org. Financial Industry Activities and Affiliations The Firm is also a general securities broker/dealer, member FINRA/SIPC, registered with the SEC and various state regulatory agencies. The Firm is wholly owned by Arvest Bank, an Arkansas state-chartered bank. The Firm is also affiliated with Arvest Insurance, Inc., an Arkansas insurance agency, and wholly owned subsidiary of Arvest Bank, offering life and health insurance products. All are wholly owned by Arvest Bank. The Firm’s Client Advisors are licensed as general securities brokers, insurance agents, and registered investment advisors. The Firm’s investment Client Advisors may recommend that clients purchase insurance products through Arvest Insurance, Inc., or banking, loan, and trust services through Arvest Bank for which clients may incur separate costs, including fees, interest, and other changes in addition to the Client Advisory Fee described herein; however, clients are under no obligation to purchase products or services through an affiliated financial services company. Custody The Firm does not maintain physical custody of client assets (which are maintained by Pershing, a third- party qualified custodian, as discussed in Item 4 above); however, we are deemed to have custody of certain clients’ wrap fee account assets pledged by such clients as collateral to secure their obligations to repay loans obtained from the Firm’s parent company, Arvest Bank. Additionally, the Firm would be deemed to have custody in certain instances where Arvest Bank, a Client Advisor, or another Firm-related person serves as trustee, or has similar powers conferred by a trust document, general power of attorney, or guardianship related to a Firm advisory account, which could result in conflicts of interest given the dual roles involving the Firm and its related persons. All Firm clients receive account statements directly from Pershing at least quarterly. We urge our clients to carefully review these statements. While the Firm does not typically prepare or send clients its own account statements, should you also receive any account statements from the Firm, we urge you to compare the account statements received from the qualified custodian with those received from our firm. Code of Ethics Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. The Firm and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement, and recordkeeping provisions. Page 38 of 39 March 17, 2025  Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal account(s) securities identical to or different from those recommended to our clients. In addition, any related person may have an interest or position in a certain security which may also be recommended to a client. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, when the associate has received an order(s) or has knowledge of pending trades for clients, thereby; preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to AWMSolutionsCenter@arvest.com , or by calling (888) 916-2121. Review of Accounts While the underlying securities within an account are continually monitored by the account’s portfolio managers, accounts are reviewed at least annually in writing by the Client Advisor assigned to the account. Accounts are reviewed in the context of each client’s stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client’s individual circumstances, or the market, political or economic environment. Our clearing firm/custodian provides statements at least quarterly and confirmations of transactions that include periodic reports summarizing account performance, balances, and holdings. Client Referrals The Firm does not pay referral fees to independent persons or firms for introducing clients to us. We may pay Arvest Bank associates a nominal one-time cash award of no more than $25, for a qualified referral to a licensed Client Advisor, which is not dependent upon a sale being made. It is the Firm’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards, or other prizes from a non-client in conjunction with the advisory services we provide to our clients. Financial Information Under no circumstances does the Firm require or solicit payment of fees more than $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a balance sheet for our most recently completed fiscal year. The Firm is not aware of any financial condition that is reasonably likely to impair its ability to meet its commitments to its clients. The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Business Continuity Plan The Firm is committed to safeguarding the interests of our clients and customers in the event of an emergency or significant business disruption. Our Business Continuity Plan, which enables us to respond to events that significantly disrupt our business, may be obtained from our Client Advisors, and can also be found at our disclosures website: https://www.arvest.com/documents-and-resources/awm- disclosures Page 39 of 39 March 17, 2025