Oak Crest Advisory, LLC (“Oak Crest” or the “firm”) is a state-registered investment advisor and corporation formed under the laws of the State of New York.
• Oak Crest Advisory, LLC has been registered as an investment advisor since May 2019.
• The firm’s principal owners are Mulbury Capital Advisors, LLC, Bryan M. Gray, CPA PC, and Strong Financial Management, LLC. The firm’s officers are Gregory Mulbury, Managing Member, Bryan Gray, Member and Director of Financial Planning, and Michael Strong, Member and Chief Compliance Officer.
• The firm offers and specializes in providing personalized investment advisory services through its Asset Management Services. Description of Advisory Services Asset Management Services. Investment management services include asset allocation, portfolio construction, and ongoing monitoring and management of the client’s account based on the individual needs, return objectives, and risk tolerance of the client. We will continuously monitor a client’s account and make trades in client accounts when necessary. Through this service, Oak Crest Advisory, LLC implements a customized and individualized investment program for clients by applying our investment strategy and philosophy. Client accounts are maintained at broker/dealers selected by the client. The client’s broker-dealer will serve as the client’s qualified custodian and maintain physical possession of all client funds and securities (see additional information regarding custody at Item 15). Oak Crest Advisory, LLC is granted limited power of attorney on the client’s account in order to implement transactions within the account (see additional information at Item 16 – Investment Discretion). Clients are always responsible for notifying Oak Crest Advisory, LLC of any changes to their financial situation or investment objectives. At least annually, we will contact each client for the specific purpose to determine whether the client’s financial situation or investment objectives have changed, or if the client would like to impose and/or modify any reasonable restrictions on the management of their accounts. We are always reasonably available to consult with clients relative to the status of their accounts. A client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian, but rather represents a direct and beneficial interest in the securities which comprise the accounts. A separate account is always maintained for each client with the broker-dealer/custodian and the client retains all rights of ownership to their accounts (e. g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive transaction confirmations). It is important that you understand that Oak Crest Advisory, LLC manages investments for other clients and can give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own personal accounts. Conflicts arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Financial Planning & Consulting Services Oak Crest Advisory offers financial planning services, which involve preparing a written financial plan and/or consultative meetings covering specific or multiple topics. We provide holistic financial plans (written or verbal), which typically address the following topics:
• Asset Allocation,
• Budgeting,
• Cash Flow Analysis,
• College/Education Planning,
• Insurance Planning,
• Retirement Planning, and
• Risk Management. When providing financial planning and consulting services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and us. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that there are important issues that may not be taken into consideration when your investment adviser representative develops his or her analysis and recommendations under a modular written financial plan. Written financial plans prepared by us do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Oak Crest Advisory does not charge separate fees for financial planning and consulting services. Because our active clients pay an asset management fee, they will not pay a separate or stand-alone fee for financial

planning and consulting services. The provision of financial planning and consulting services is considered when determining the annual fee for Asset Management Services (see Item 5 of this brochure). Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. Where contracted, we will also provide discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. Otherwise, pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. To the extent agreed upon and as set forth in the agreement, we will typically:
• Instruct or direct the Custodians to transfer funds or securities on behalf of the Account;
• Review the plan investment choices and make changes thereto when appropriate;
• Recommend brokers, dealers, custodians, and/or investment managers to be utilized for the Account;
• Take all such other actions, which we consider necessary or advisable to carry out its duties under the agreement between the plan sponsor and us;
• Provide an initial group enrollment meeting for all employees;
• Provide individual counseling sessions for each employee semiannually;
• Attend meetings with the plan sponsor semiannually to review the investment performance of the plan and perform such other functions as the Client may reasonably request; and
• We will be available for consultation and review on an as-needed basis. These engagements are typically regulated under the Employee Retirement Income Securities Act ("ERISA"). All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and shall be consistent with the parameters set forth in the plan documents. We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
• Diversification
• Asset allocation
• Risk tolerance
• Time horizon Our educational seminars may include other investment-related topics specific to the particular plan. There is no separate fee arrangement for educational seminars. We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. No Participation in Wrap Fee Programs –A wrap-fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management and/or advice concerning the selection of other investment advisers) and the execution of client transactions. We do not offer or participate in wrap-fee programs. All of our services are provided on a non-wrap fee basis which means fees and expenses for execution of client transactions charged by the client’s broker-dealer and/or custodian are billed directly to the client’s account separately from our advisory fees. Types of Investments. We are willing to offer advice on most types of investments owned by a client and, at the specific request of a client we will explore investment options not currently owned by a client. The following are some of the general categories of securities that we will advise.
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issues
• Exchange Traded Funds (ETFs)
• Warrants
• Bonds
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States government securities
• Options contracts on securities Oak Crest Advisory, LLC does not provide advice on variable life insurance products, variable annuities, futures, commodities, and interests in partnerships investing in real estate, oil, and gas. We also do not provide advice on private offerings and other unregistered securities. When providing Asset Management Services, we typically construct each client’s account holdings using equities, fixed income, money market funds and cash-positions to build diversified portfolios. We do not typically use mutual funds but may do so depending on the client’s particular situation and needs. We do not typically attempt to time the market, but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. Tailor Advisory Services to Individual Needs of Clients Our services are always provided based on the individual needs of the individual client. Clients are given the ability to impose restrictions on their accounts including specific investment selections and sectors. We work with clients through the use of questionnaires and interviews to determine their investment mandates. Client Assets Managed by Oak Crest Advisory, LLC Oak Crest Advisory has $51,737,420 in discretionary assets under management and no non-discretionary assets under management. Assets under management were calculated as of December 31, 2023.