Item 5: Fees & Compensation ..................................................................................................................... 6 Item 6: Performance-Based Fees & Side-By-Side Management .............................................................. 7 Item 7: Types of Clients & Account Requirements ................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................ 8 Item 9: Disciplinary Information .............................................................................................................. 13 Item 10: Other Financial Industry Activities & Affiliations .................................................................... 13 Item 11: Code of Ethics, Participation, or Interest in ............................................................................. 13 Item 12: Brokerage Practices ................................................................................................................... 15 Item 13: Review of Accounts or Financial Plans ..................................................................................... 19 Item 14: Client Referrals & Other Compensation ................................................................................... 20 Item 15: Custody ....................................................................................................................................... 21 Item 16: Investment Discretion ............................................................................................................... 22 Item 17: Voting Client Securities .............................................................................................................. 22 Item 18: Financial Information ................................................................................................................ 22 We specialize in the following types of services: Comprehensive Portfolio Management, and Pension Consulting. A. Description of our advisory firm, including how long we have been in business and our principal owner(s). We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a corporation formed in the State of Oklahoma. Our firm has been in business as an investment adviser since 2003 and is owned wholly by Burnett Family Trust dtd 05/14/2015, for which Ralph Burnett & Jennifer Burnett are Co-Trustees. B. Description of the Types of Advisory Services We Offer. (i) Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the

use of financial investments. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone conference) with clients to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. (iii) Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to clients utilizing our Comprehensive Portfolio Management service. Additionally, we offer general investment advice to clients utilizing our firm’s Pension Consulting Service. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Comprehensive Portfolio Management service. We do not manage assets through our other services. D. Participation in Wrap Fee Programs. Our firm does not offer or sponsor a wrap fee program. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis as of December 31st, 2022. We manage1 $131,593,680 on a discretionary basis and $16,974,952 on a non-discretionary basis.