BULL OAK CAPITAL, LLC

FIRM BROCHURE FORM ADV PART 2A This brochure provides information about the qualifications and business practices of Bull Oak Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (858) 999-3550 or by email at: info@bulloak.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. Registration does not imply a certain level of skill or training. Additional information about Bull Oak Capital, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Bull Oak Capital LLC’s CRD number is: 170325. 16236 San Dieguito Rd., Ste 4-22 #675752 Rancho Santa Fe, CA 92067-5752 (858) 999-3550 www.bulloak.com info@bulloak.com VERSION: 2/24/2025 - 1 -  ITEM 2 - MATERIAL CHANGES The purpose of this page is to inform you of any material changes since the last annual update to this brochure. If you are receiving this brochure for the first time, this section may not be relevant to you. Bull Oak Capital reviews and updates our brochure at least annually to make sure that it remains current. The material changes in this brochure from the last annual amendment of Bull Oak Capital on 02/06/2024 are described below. Material changes relate to Bull Oak Capital’s policies, practices, or conflicts of interests. • Item 5: Fees and Compensation Pursuant to SEC Rules, Bull Oak Capital will ensure that clients receive a summary of any materials changes to this Brochure within 120 days of the close of Bull Oak Capital’s fiscal year. Additionally, as the firm experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. For more information about the firm, please visit bulloak.com or call (858) 999-3550. - 2 -  ITEM 3 - TABLE OF CONTENTS ITEM 1: COVER PAGE ITEM 2: MATERIAL CHANGES………………………………………………………….…………………………………2 ITEM 3: TABLE OF CONTENTS ..................................................................................................................... 3 ITEM 4: ADVISORY BUSINESS ....................................................................................................................... 4 ITEM 5: FEES AND COMPENSATION… ........................................................................................................ 7 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................. 9 ITEM 7: TYPES OF CLIENTS .......................................................................................................................... 9 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF INVESTMENT LOSS ............................................................................................................ 9 ITEM 9: DISCIPLINARY INFORMATION ....................................................................................................... 10 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................... 10 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ................................................................................ 11 ITEM 12: BROKERAGE PRACTICES ............................................................................................................. 12 ITEM 13: REVIEWS OF ACCOUNTS .............................................................................................................. 13 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 13 ITEM 15: CUSTODY ..................................................................................................................................... 14 ITEM 16: INVESTMENT DISCRETION .......................................................................................................... 14 ITEM 17: VOTING CLIENT SECURITIES (PROXY VOTING) ........................................................................... 14 ITEM 18: FINANCIAL INFORMATION ........................................................................................................... 14 - 3 -  ITEM 4 - ADVISORY BUSINESS A. Description of the Advisory Firm Bull Oak Capital, LLC (hereinafter “Bull Oak”) is a Limited Liability Company organized in the state of California. Bull Oak became registered as an Investment Advisor with the SEC on March 2014. The principal owner is Ryan Anthony Hughes. B. Types of Advisory Services As discussed below, Bull Oak offers to its clients (primarily individuals and high net worth individuals but can include others) varying levels of investment advisory services, in addition to financial planning and related consulting services. Tier 3: Core Planning Bull Oak’s Core Planning service offers comprehensive financial planning designed to lay the foundation for a client’s financial future. Upon engagement for the Tier 3: Core Planning services, clients can gain access to, to the extent applicable: Insurance Review • Comprehensive Financial Plan • Net Worth Tracking & Progress Report • High-Yield Cash Account • • End of Year Tax Planning • Investment Management • Real Estate & Investment Property Planning • Estate Plan Review Tier 2: Professional Bull Oak’s Professional service offers a higher level of financial planning as it incorporates deeper analysis and more related services. In addition to the above services offered in Tier 3: Core Planning, the Tier 2: Professional tier can also provide, to the extent applicable: Job Offer Package Review • Estate Plan Meeting & Document Creation • • CPA Tax Planning, Preparation, & Filing Tier 1: Concierge Bull Oak’s Concierge service is designed for high-net-worth clients who desire personalized service and comprehensive wealth management. In addition to the above services offered in Tier 3: Core Planning and Tier 2: Professional, the Tier 1: Concierge tier can also provide, to the extent applicable: • Prioritized Meetings • Advanced Charitable Planning • Private Deal Review • Post-Exit Estate, Cash Flow, and Investment Allocation Planning • Second Generation Education and Legacy Planning - 4 -  Portfolio Management Bull Oak’s various other service offerings may also be combined with Bull Oak’s discretionary portfolio management services, for an additional asset-based fee. Bull Oak offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Bull Oak will outline the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: investment strategy, asset allocation, asset selection, risk tolerance, regular portfolio monitoring. Bull Oak evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Bull Oak will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Bull Oak seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Bull Oak’s economic, investment, or other financial interests. To meet its fiduciary obligations, Bull Oak attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Bull Oak’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Bull Oak’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments Bull Oak generally limits its investment advice to Exchange Traded Funds (ETFs). However, it may also include equities, mutual funds, fixed income securities, ETPs, cryptocurrencies, treasury inflation protected/inflation-linked bonds, and other financial instruments Bull Oak may deem appropriate on a case-by-case basis. Bull Oak may use other securities as well to help diversify a portfolio when applicable. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting Services As indicated above, to the extent requested by the client, Bull Oak may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Bull Oak does not serve as a law firm or accounting firm, and no portion of its services should be construed as legal or accounting services. Accordingly, Bull Oak does not prepare estate planning documents or tax returns. To the extent requested by a client, Bull Oak may recommend the services of other professionals for implementation services (E.g., attorneys, accountants, insurance agents, etc.). Depending upon the level of service the client engages with Bull Oak, Bull Oak may cover the cost for such services. Regardless, Bull Oak does not receive an economic benefit from arrangements between clients and referred third parties. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Bull Oak and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Retirement Rollovers A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Bull Oak recommends that a client roll over their retirement plan assets into an account to be managed by Bull Oak, such a recommendation creates a conflict of interest if Bull - 5 -  Oak will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Bull Oak. ERISA / IRC Fiduciary Acknowledgment When Bull Oak provides investment advice to a client regarding the client’s retirement plan account or individual retirement account, it does so as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. The way Bull Oak makes money creates some conflicts with client interests, so Bull Oak operates under a special rule that requires it to act in the client’s best interest and not put its interests ahead of the client’s. Under this special rule's provisions, Bull Oak must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put its financial interests ahead of the client’s when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that Bull Oak gives advice that is in the client’s best interest; • Charge no more than is reasonable for Bull Oak’s services; and • Give the client basic information about conflicts of interest. Legacy Engagements Certain of Bull Oak’s clients remain engaged with Bull Oak for legacy services and/or fee arrangements, which services and/or fee arrangements are not described in this Brochure and are no longer offered to new clients. Such legacy clients are advised to consult their executed agreement(s) with Bull Oak for further details. Client Obligations In performing its services, Bull Oak shall not be required to verify any information received from the client or from the client’s other designated professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify Bull Oak if there is ever any change in their financial situation or investment objectives for the purpose of reviewing/evaluating/revising Bull Oak’s previous recommendations and/or services. C. Client Tailored Services and Client Imposed Restrictions Bull Oak shall provide investment advisory services specific to the needs of each client. Specific client investment strategies and their implementation are dependent upon the client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing on certain securities or types of securities in accordance with their values or beliefs. Bull Oak reserves the right to either reject client-imposed restrictions or end the client relationship. Client-imposed restrictions will not be effective unless accepted by Bull Oak in writing. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Bull Oak does not participate in any wrap fee programs. E. Assets Under Management As of December 31, 2024, Bull Oak managed $196,175,570 in total assets, all of which were on a discretionary basis. - 6 -  ITEM 5 - FEES AND COMPENSATION A. Financial Planning Fees Tier 3: Core Planning The Core Planning service is offered as an annual agreement for a total base fixed fee of $12,350. This agreement renews automatically on a year-to-year basis. The Financial Planning fee is typically paid monthly in arrears. For example, in April, the fee would be calculated as $12,350/12 = $1,029.17. The Financial Planning fee may be adjusted based on the complexity and scope of the services required. Any such additional charges will be outlined in the Client’s Investment Advisory Agreement (“IAA”), if applicable. In no event will Bull Oak solicit or require prepayment of $1,200 or more in fees six months or more in advance. Clients who elect to receive Bull Oak’s discretionary portfolio management services in addition to Financial Planning will incur a separate and additional asset-based annual fee, as detailed in the Assets Under Management Fees section of this document. Tier 2: Professional The Professional Planning service is offered as an annual agreement for a total base fixed fee of $15,500. This agreement renews automatically on a year-to-year basis. The Financial Planning fee is typically paid monthly in arrears. For example, in April, the fee would be calculated as $15,500/12 = $1,291.67. The Financial Planning fee may be adjusted based on the complexity and scope of the services required. Any such additional charges will be outlined in the Client’s Investment Advisory Agreement (“IAA”), if applicable. In no event will Bull Oak solicit or require prepayment of $1,200 or more in fees six months or more in advance. Clients who elect to receive Bull Oak’s discretionary portfolio management services in addition to Financial Planning will incur a separate and additional asset-based annual fee, as detailed in the Assets Under Management Fees section of this document. Tier 1: Concierge The Core Planning service is offered as an annual agreement for a total base fixed fee of $31,000. This agreement renews automatically on a year-to-year basis. The Financial Planning fee is typically paid monthly in arrears. For example, in April, the fee would be calculated as $31,000/12 = $2,583.33. The Financial Planning fee may be adjusted based on the complexity and scope of the services required. Any such additional charges will be outlined in the Client’s Investment Advisory Agreement (“IAA”), if applicable. In no event will Bull Oak solicit or require prepayment of $1,200 or more in fees six months or more in advance. Clients who elect to receive Bull Oak’s discretionary portfolio management services in addition to Financial Planning will incur a separate and additional asset-based annual fee, as detailed in the Assets Under Management Fees section of this document. Fee Adjustments Annual fixed fees for ongoing Core Planning, Professional, and Concierge tier services can be adjusted up on an annual basis, based on changes to the Consumer Price Index for All Urban Consumers (“CPI-U”). Adjustments will typically reflect changes in the CPI-U from the preceding year but may be rounded to the nearest practical figure to ensure simplicity and clarity (E.g., $15,750 rather than the precise fractional amount of $15,742.57). Adjustments can be made each year the relevant services agreement remains in effect, in the calendar month in which the agreement was initially executed, based on the CPI-U data from the preceding year. Monthly fixed fees can be adjusted up, in direct proportion to the change in the CPI-U for the prior year. In no event will it be adjusted down. Adjustments made pursuant to this paragraph after the first full year of continuous services can be calculated based upon the client’s monthly fee. Subsequent adjustments can be calculated based upon the client’s then-current fixed monthly fee. In an inflationary environment, this means that existing clients may pay higher fees than new clients. - 7 -  Assets Under Management Fees For the Core Planning, Professional, and Concierge tier clients who also elect to receive Bull Oak’s discretionary portfolio management services, such portfolio management services will be subject to a separate and additional asset-based annual fee schedule. Value of Assets Under Management First $1,000,000 Above $1,000,000 Annual Management Fee 0.00% 0.35% For purposes of calculating assets under management, Bull Oak will consider all investment management accounts that constitute “household” of the client’s assets. Typically, a client’s household consists of any spouse, parent, child, partner, or sibling who resides at the same mailing address as the Client. The asset under management fee is a blended fee and is calculated by assessing the percentage rates using the predefined levels of assets as shown in the above chart. The client will be billed monthly in arrears. Bull Oak reserves the right to reduce, increase up to 1.5% for AUM above $1,000,000 (upon receiving client’s consent), or waive the minimum account size, terminate accounts that fall below the minimum established requirements, require additional funds be deposited to bring a client account value up to the required minimum or waive advisory fees and account minimums for employee, employee-related, or affiliate employee accounts. Bull Oak’s fees are generally not negotiable in the sole discretion of Bull Oak. Although Bull Oak believes its fees are competitive, Client is hereby advised that lower fees for comparable services may be available from other sources. Bull Oak may amend its fee schedule at any time by providing written notice to Client. Fee Negotiability and Alternative Fee Arrangements Bull Oak reserves the right to negotiate its fees, or engage in alternative fee arrangements not described herein, based upon various objective and subjective factors, including but not limited to: the representative assigned to the account, the amount of assets to be invested, the complexity of the engagement, the anticipated number of meetings and servicing needs, related accounts, future earning capacity, anticipated future additional assets, negotiations with the client, and other factors. As a result, similarly situated clients may be differing fees, and comparable advisory services may be available from other investment advisers for similar or lower fees. Before engaging Bull Oak to provide investment advisory services, clients are required to enter into an agreement with Bull Oak, setting forth the terms and conditions of the engagement (including termination), which describes the fees and services to be provided. The agreement between Bull Oak and the client will continue in effect until terminated by either party in accordance with the terms of the agreement. Clients may terminate their agreement within five (5) business days of signing their Investment Advisory Agreement, without penalty and with full refund of Bull Oak’s fees. Thereafter, their agreement shall continue in effect until terminated by Bull Oak or the Client in writing. The termination of the relationship will be effective as of the date of the terminating party’s written notice. In the event Bull Oak’s services are terminated prior to the expiration of the agreement, Bull Oak is entitled to a pro-rata fee to ensure that the annual fixed fee for its tier planning service and its portfolio management services is met. Due to factors such as value of services rendered to client at the onset of an engagement, no refunds are provided and no pro-rata billing is assessed. B. Payment of Portfolio Management Fees Bull Oak’s tier planning service and asset-based portfolio management fees are withdrawn directly from the client's accounts by the custodian upon receiving client's written authorization on a monthly basis. Fees are paid in arrears. - 8 -  For purposes of calculating assets under management, Bull Oak will consider all investment management accounts which constitute “household” of the Client’s assets. Typically, a Client’s household consists of any spouse, parent, child, partner or sibling who resides at the same mailing address as the Client. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Bull Oak. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees Bull Oak collects its Portfolio Management fees in arrears. It generally does not collect such fees in advance. Annual fixed fees for the Core Planning, Professional, and Concierge tiers are generally payable on a monthly basis as indicated above. Legacy Engagements As discussed in Item 4 above, certain of Bull Oak’s clients remain engaged with Bull Oak for legacy services and/or fee arrangements, which services and/or fee arrangements are not described in this Brochure and are no longer offered to new clients. Such legacy clients are advised to consult their executed agreement(s) with Bull Oak for further details. E. Outside Compensation For the Sale of Securities to Clients Neither Bull Oak nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY- SIDE MANAGEMENT Bull Oak does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. ITEM 7 - TYPES OF CLIENTS Bull Oak generally provides advisory services to individuals and high-net-worth individuals. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, & RISK OF INVESTMENT LOSS Bull Oak believes that investors must diversify broadly and should avoid making unnecessarily large bets on any one security, asset class, or geographic region. Bull Oak invests primarily in exchanged-traded funds in an attempt to capture the returns of an entire asset class, rather than predict which securities within that asset class will outperform. Bull Oak considers each client’s risk tolerance and time horizon when constructing a portfolio, ensuring that investments align with their individual financial goals and comfort with risk. Bull Oak regularly monitors portfolios to ensure that each client’s allocation to every security or asset class remains - 9 -  within acceptable ranges. When necessary, Bull Oak may buy or sell securities to bring the portfolio back towards its targeted allocations. Investing in securities, including exchange traded funds and mutual funds, always involves risk of loss which clients should expect to bear. Specifically, client portfolios are exposed to the following primary risks: • Market Risk – Economic, political, and issuer-specific events may cause the value of securities to rise or fall. • Small Company Risk – Securities of small companies are often less liquid than those of large companies. As a result, small company stocks may fluctuate relatively more in price. • Foreign Securities and Currencies Risks – Foreign securities prices may decline or fluctuate because of economic or political actions of foreign governments, and/or because of less regulated or less liquid securities markets. Investors holding these securities are also exposed to foreign currency risk (the possibility that foreign currency may fluctuate in value against the U.S. dollar). • Emerging Markets Risk – Numerous emerging market countries have experienced serious economic and political problems. Stock markets in many emerging market countries are relatively small, expensive to trade and risky. Foreigners are sometimes limited in their ability to invest in, and withdraw assets from, these markets. • Credit Risk – The issuer of a security may be unable to make interest payments and/or repay principal when • • • due. A downgrade to an issuer’s credit rating or a perceived change in an issuer’s financial strength may affect a security’s value. Interest Rate Risk – The prices of fixed income securities tend to move in the opposite direction of interest rates. In general, fixed income securities with longer maturities are more sensitive to these price changes. Income Risk – The potential for a decline in a fund’s income due to falling interest rates. Inflation Risk (also called Purchasing Power Risk) – The cash flows from an investment may not be worth as much in the future because of changes in purchasing power due to inflation. • Tax Risks Related to Short Term Trading – Bull Oak may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long-term strategies. ITEM 9 - DISCIPLINARY INFORMATION A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Bull Oak nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. - 10 -  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Bull Oak nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither Bull Oak nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. All material conflicts of interest Under Section 260.238 (k) of the Corporations Code are disclosed regarding the investment adviser, its representatives or any of its employees, which could be reasonably expected to impair the rendering of unbiased and objective advice. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Bull Oak does not utilize nor select third-party investment advisors. All assets are managed by Bull Oak management. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics Bull Oak has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts, and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Additionally, Bull Oak has adopted a Code of Professional Conduct as recommended by the CFA Institute, Asset Manager Code of Professional Conduct. Bull Oak's Code of Ethics is available free upon request to any client or prospective client. • To act in a professional and ethical manner at all times • To act for the benefit of clients • To act with independence and objectivity • To act with skill, competence, and diligence • To communicate with clients in a timely manner and accurate manner • To uphold the rules governing capital markets B. Recommendations Involving Material Financial Interests Bull Oak does not recommend that clients buy or sell any security in which a related person to Bull Oak or Bull Oak has a material financial interest. C. Investing Personal Money in the Same Securities as Clients In an effort to prevent conflicts of interest, it is the policy of Bull Oak that its associated persons are not permitted to invest in the same securities purchased for clients. Should this change in the future, Bull Oak will revise its Code of - 11 -  Ethics and update this Brochure accordingly. D. Trading Securities At/Around the Same Time as Clients’ Securities Please see Item 11.C above. ITEM 12 - BROKERAGE PRACTICES A. Factors Used to Select Custodians and/or Broker/Dealers We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are overall most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below Bull Oak will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. For the benefit of no commissions or transaction fees, fully digital account opening, a large variety of security options, and complete integration with software tools, Bull Oak recommends Altruist Financial LLC, an unaffiliated SEC-registered broker dealer and FINRA/SIPC member, as the clients' custodian. Bull Oak does not receive any research or other soft-dollar benefit by nature from its relationship with Altruist Financial LLC. Additionally, Bull Oak does not receive any referrals in exchange for using Altruist Financial LLC as a broker dealer. Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. B. Research and Other Soft-Dollar Benefits We do not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our clients. Altruist Financial LLC receives revenue on brokerage accounts opened through the Altruist platform. - 12 -  While Bull Oak has no formal soft dollars program in which soft dollars are used to pay for third- party services, Bull Oak recommends Altruist Financial LLC due to its complete integration with software tools and fully digital account opening. C. Brokerage for Client Referrals Bull Oak receives no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. D. Clients Directing Which Broker/Dealer/Custodian to Use Bull Oak will require clients to use a specific broker-dealer to execute transactions. E. Aggregating (Block) Trading for Multiple Client Accounts Bull Oak may aggregate or bunch securities to be purchased or sold for multiple clients. This may, but not always, result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Bull Oak does not typically invest in illiquid securities. ITEM 13 - REVIEWS OF ACCOUNTS A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client portfolio management accounts are reviewed at least annually only by either a Portfolio Manager or a Financial Advisor of Bull Oak Capital, LLC with regard to clients’ respective time horizon and risk tolerance levels. All accounts at Bull Oak are assigned to a Financial Advisor and/or a Portfolio Manager. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. It is the responsibility of the client to verify the accuracy of the calculation of fees presented in such reports as the custodian will not determine whether the fees charged to the client’s account are accurate or have been properly calculated. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Bull Oak does not receive any economic benefit, directly or indirectly, from any third party for advice rendered to our clients. B. Compensation to Non – Advisory Personnel for Client Referrals Bull Oak does not directly or indirectly compensate any person who is not advisory personnel for client referrals. - 13 -  ITEM 15 - CUSTODY When advisory fees are deducted directly from client accounts at client's custodian, Bull Oak will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients should understand that it is their responsibility to ensure that the fee calculation is correct, and not the custodian. Specifically, each time a fee is directly deducted from a client account, Bull Oak will concurrently: • • • send the qualified custodian an invoice or statement of the amount of the fee to be deducted from the client’s account; and send the client an invoice or statement itemizing the fee, including the formula used to calculate the fee, the value of the assets under management on which the fee is based, and the time period covered by the fee. ITEM 16 - INVESTMENT DISCRETION Bull Oak provides discretionary investment management to clients. The Investment Advisory Agreement established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Bull Oak generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. ITEM 17 - VOTING CLIENT SECURITIES (PROXY VOTING) Bull Oak will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Additionally, Bull Oak does not advise or act for Clients with respect to any legal matters, including bankruptcies and class actions, for the securities held in Clients’ accounts. ITEM 18 - FINANCIAL INFORMATION A. Balance Sheet Bull Oak neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Bull Oak nor its management has any financial condition that is likely to reasonably impair Bull Oak’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Bull Oak has not been the subject of a bankruptcy petition in the last ten years. - 14 -  FIRM BROCHURE FORM ADV PART 2B This brochure supplement provides information about Ryan A. Hughes that supplements the Bull Oak Capital brochure. You should have received a copy of that brochure. Please contact Ryan Anthony Hughes if you did not receive Bull Oak Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Ryan Anthony Hughes is also available on the SEC’s website at www.adviserinfo.sec.gov. Individual Disclosure Brochure for Ryan A. Hughes Personal CRD Number: 5430536 Investment Advisor Representative 16236 San Dieguito Rd., Ste 4-22 #675752 Rancho Santa Fe, CA 92067-5752 (858) 999-3550 www.bulloak.com info@bulloak.com VERSION: 2/24/2025 - 1 -  ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Ryan A. Hughes Year of Birth: 1982 Educational Background MBA, Finance - UCLA Anderson School of Management – 2014 J. Fred Weston Award – Academic Excellence in Finance GAP Fellows Award – Top 5% in Class B.S., Business Administration - University of Southern California (USC) – 2007 Business Background 01/2014 – Present Founder & Portfolio Manager Bull Oak Capital San Diego, CA 07/2012 – 03/2014 Graduate Student – MBA Studies UCLA Anderson School of Management Los Angeles, CA 01/2008 - 07/2012 Financial Advisor Charles Schwab / Morgan Stanley / Merrill Lynch Los Angeles, CA 08/2004 - 12/2007 Undergraduate Student University of Southern California (USC) Los Angeles, CA 7/2000 – 7/2004 STG2 / VBSS Team Member US Navy San Diego, CA  ITEM 3 - DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. ITEM 4 - OTHER BUSINESS ACTIVITIES Ryan A. Hughes does not have any outside business activity to report. ITEM 5 - ADDITIONAL COMPENSATION Ryan A. Hughes does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Bull Oak Capital. ITEM 6 - SUPERVISION As the owner and Chief Compliance Officer of Bull Oak Capital, Ryan A. Hughes supervises all activities of the firm. Ryan A. Hughes's response information is on the cover page of this disclosure document.  FIRM BROCHURE FORM ADV PART 2B This brochure supplement provides information about Peter Stuart Campbell that supplements the Bull Oak Capital brochure. You should have received a copy of that brochure. Please contact Peter Stuart Campbell if you did not receive Bull Oak Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Peter Stuart Campbell is also available on the SEC’s website at www.adviserinfo.sec.gov. Individual Disclosure Brochure for Peter Stuart Campbell Personal CRD Number: 6852999 Investment Advisor Representative 16236 San Dieguito Rd., Ste 4-22 #675752 Rancho Santa Fe, CA 92067-5752 (858) 999-3550 www.bulloak.com info@bulloak.com VERSION: 2/24/2025 - 1 -  ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Peter Stuart Campbell Year of Birth: 1985 Educational Background B.A., History - University of California Los Angeles (UCLA) – 2007 Business Background 02/2022 – Present Lead Advisor Bull Oak Capital San Diego, CA 03/2019 – 02/2022 Investment Advisor Representative Wealth Analytics Partners San Diego, CA 09/2017 - 02/2019 Investment Advisor Representative Cambridge Investment Research Advisors San Diego, CA 08/2016 – 11/2019 Head Club Fitter Aviara Golf Academy San Diego, CA 08/2007 – 06/2017 Professional Golfer Sole Proprietor San Diego, CA ITEM 3 - DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business.  ITEM 4 - OTHER BUSINESS ACTIVITIES Peter Stuart Campbell does not have any outside business activity to report. ITEM 5 - ADDITIONAL COMPENSATION Peter Stuart Campbell does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Bull Oak Capital. ITEM 6 - SUPERVISION As a representative of Bull Oak Capital, LLC, Peter Stuart Campbell is supervised by Ryan A. Hughes, the firm’s Chief Compliance Officer. Ryan A. Hughes is responsible for ensuring that Peter Stuart Campbell adheres to all required regulations regarding the activities of an Investment Advisor Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for Ryan A. Hughes is (858) 999-3550.  FIRM BROCHURE FORM ADV PART 2B information about Michael Thomas Stoner is also available on This brochure supplement provides information about Michael Thomas Stoner that supplements the Bull Oak Capital brochure. You should have received a copy of that brochure. Please contact Michael Thomas Stoner if you did not receive Bull Oak Capital’s brochure or if you have any questions about the contents of this supplement. Additional the SEC’s website at www.adviserinfo.sec.gov. Individual Disclosure Brochure for Michael Thomas Stoner Personal CRD Number: 7867144 Investment Advisor Representative 16236 San Dieguito Rd., Ste 4-22 #675752 Rancho Santa Fe, CA 92067-5752 (858) 999-3550 www.bulloak.com info@bulloak.com VERSION: 2/24/2025 - 1 -  ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Michael Thomas Stoner Year of Birth: 1991 Educational Background B.A., Business Administration – San Diego State University – 2023 Business Backgrounds 01/2024 – Present Wealth Advisor Bull Oak Capital San Diego, CA 08/2023 – 01/2024 Preparing for CFP Exam Exam Preparation San Diego, CA 07/2021 - 08/2023 Full-Time Student San Diego State University San Diego, CA 08/2011 – 05/2021 Naval Special Warfare Operator (SEAL) US Navy Coronado, CA ITEM 3 - DISCIPLINARY INFORMATION There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. ITEM 4 - OTHER BUSINESS ACTIVITIES Michael Thomas Stoner does not have any outside business activity to report.  ITEM 5 - ADDITIONAL COMPENSATION Michael Thomas Stoner does not receive any economic benefit from any person, company, or organization, in exchange for providing clients advisory services through Bull Oak Capital. ITEM 6 - SUPERVISION As a representative of Bull Oak Capital, LLC, Michael Thomas Stoner is supervised by Ryan A. Hughes, the firm’s Chief Compliance Officer. Ryan A. Hughes is responsible for ensuring that Michael Thomas Stoner adheres to all required regulations regarding the activities of an Investment Advisor Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for Ryan A. Hughes is (858) 999-3550.  PRIVACY POLICY 1 6 2 3 6 S a n D i e g u i t o R d . , S t e 4 - 2 2 R a n c h o S a n t a F e , C A 9 2 0 6 7 - 5 7 5 2 ( 8 5 8 ) 9 9 9 - 3 5 5 0 i n f o @ b u l l o a k . c o m DATA RETENTION Investment advisers are required by law to inform their clients of their policies regarding the privacy of client information. At Bull Oak Capital, We retain your personal information for as long as necessary to fulfill LLC, we are committed to maintaining the confidentiality of your our contractual and legal obligations. After that period, we securely personal information and complying with federal, state, and destroy your data in compliance with applicable laws and industry international privacy laws. This notice explains how we collect, use, standards. share, and protect your information. BREACH NOTIFICATION TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE In the unlikely event of a data breach, we will notify affected clients COLLECT promptly, in accordance with applicable federal and state laws. We collect nonpublic personal information (NPI) about you that is Notifications will include information about the breach and steps to either provided by you or obtained with your authorization. This protect your information. information may include, but is not limited to: social security number, RIGHTS UNDER STATE AND FEDERAL LAWS date of birth, banking information, financial account numbers and/or • balances, sources of income, credit card information, device Federal Rights: You have the right to limit sharing of your NPI as information, and online identifiers (e.g., IP addresses, cookies). When follows: Sharing with affiliates about your creditworthiness, you are no longer our customer, we will continue to handle your sharing with affiliates or non-affiliates for marketing purposes, information only as described in this policy. sharing with non-affiliates for business purposes beyond legal or regulatory requirements. HOW WE USE YOUR INFORMATION • California Residents: Under the California Consumer Privacy Act We use your personal information to: (CCPA) and California Privacy Rights Act (CPRA), you have the • right to: Know what personal information we collect and how we Process transactions and manage your account(s) use it, request deletion or correction of your personal information, • Comply with legal obligations and respond to court orders or investigations opt out of the sale or sharing of your personal information, limit • the use of sensitive personal information. To exercise your rights, Provide personalized financial advice and services • email us at info@bulloak.com. Improve our cybersecurity measures and safeguard your information • Nevada Residents: Nevada law allows residents to opt out of the sale of their personal information. To request placement on our PARTIES TO WHOM WE DISCLOSE INFORMATION “Do Not Sell” list, email us or call 858-999-3550. • We may share your personal information for the following purposes: Vermont Residents: We limit the information disclosed to non- • affiliated third parties to your name, address, contact information, Everyday Business Purposes: Processing transactions, maintaining accounts, and fulfilling legal requirements. and transaction details, as permitted by Vermont law. • Affiliates’ Everyday Business Purposes: Information about your UPDATES TO THIS POLICY transactions and experiences. We may update this policy from time to time to reflect changes in legal We do not share your personal information with non-affiliated third requirements or our business practices. We will notify you of significant changes through our website or other communication methods. parties for their marketing purposes. PROTECTING YOUR INFORMATION CONTACT US To protect your personal information from unauthorized access and If you have questions or would like to exercise your privacy rights, use, we implement security measures that comply with federal and please contact us at info@bulloak.com, 858-999-3550, and/or www.bulloak.com. state law, including: encryption of sensitive data, multi-factor authentication for access to systems, secure physical storage and access protocols, and regular cybersecurity audits and penetration testing.