OAS was incorporated on June 14, 1969 and offers investment advisory services, in accordance with the terms of an advisory or planning agreement, to individual, small business and institutional clients, including employee benefit plans, most of which it expects to be derived from its current customer base as a SEC registered broker-dealer and Financial Industry Regulatory Authority (“FINRA”) member firm or from its parent company, American United Life Insurance Company (“AUL”), an Indiana insurance company. Those services principally involve suitable financial planning and discretionary asset management services in accordance with the investment objectives, guidelines, and restrictions determined and developed by its clients and, in some cases, with the assistance of the Investment Advisor Representative (“IAR” or “Advisor Representative”). The Firm has a nationwide network of IARs who are typically dually registered representatives of OAS. Due to the independent nature of the Firm’s business model, Advisor Representatives are able to structure the services offered to clients in many different ways, all of which are dependent upon client suitability and investment objectives. For all the Programs described, the Firm may provide customized investment advisory and administrative services to its clients, but it does not maintain custody of the individual funds or other assets owned by each client. Independent Third-Party Investment Advisers OAS has relationships with multiple Third-Party Asset Management Program (“TAMP”) sponsors. IARs gather information about the client and then assist in the selection of the TAMP. Additionally, IARs monitor the activity in the account and meet with the clients to discuss results and update changes in the client’s situation or objectives. OAS receives asset- based fees for referring clients to the independent investment advisors. A separate Form ADV 2 for the selected TAMP is required to be provided to the client by the IAR. Clients wishing to obtain more information about the selected TAMP should consult the Form ADV 2 provided. Portfolio Choice Program OAS offers investors a variety of different investment management programs, each particularly suited to individual needs. These programs are offered through an arrangement with Envestnet Incorporated (“Envestnet”), Sawtooth Solutions, LLC (“Sawtooth”) and Lockwood Advisors, Inc. (“Lockwood”) collectively referred to herein as “Account Managers”. The Account Managers are registered investment advisors who offer investment advisory and investment management programs to the Firm’s clients. Each program listed below has its own official disclosure document, Appendix 1, that describes all fees and services. For additional information, please refer to Appendix 1. Envestnet and Lockwood Discretionary Management Programs OAS sponsors and offers to its clients Discretionary Management Programs through an agreement between OAS and Account Managers. OAS performs the introducing brokerage services and its Advisor Representatives do not have discretionary investment authority in the accounts under this program. The Account Managers have discretionary authority to supervise and direct all monies contributed by the client, but they must act in accordance with the client’s investor profile, which includes, but is not limited, to the consideration of liquidity needs, risk tolerance, and account objectives. Separate disclosure statements for the Account Managers are provided to the client by OAS. Discretionary Management Programs at Envestnet and Lockwood are wrap fee programs, whereby the management fee and the administrative fee are combined. All additional costs, which include but are not limited to costs for custody, clearing, ticket charges, commissions, transactions, and execution (collectively “Brokerage Fees”) charged by the clearing firm, Pershing LLC (“Pershing”), are covered by OAS and are not incurred by the client. Pershing also charges an account maintenance fee that the client will pay on an annual basis. Discretionary Management Programs at Sawtooth may have alternate fee structures. Separately Managed Account (“SMA”) Programs OAS sponsors and offers to its clients Separately Managed Account Programs through agreements between OAS and the Account Managers. OAS performs the introducing brokerage services and its Advisor Representatives do not have discretionary investment authority in the accounts under this program. Such programs include sub-accounts of the client’s account managed by registered investment advisors (“Separate Account Managers”) selected by one of the Account Managers. All Separate Account Managers are entered in sub-advisory contracts with the Account Managers. The Account Managers have discretionary authority to select the Separate Account Managers to be utilized in managing the client’s assets. The Separate Account Managers have discretionary authority to direct the investment of the assets under this program. Separate disclosure statements for the Account Managers and Separate Account Managers are provided to the client by OAS. Separately Managed Account Programs at Envestnet are wrap fee programs whereby the management fee and the administrative fee are combined. Brokerage Fees charged by the clearing firm, Pershing, are covered by OAS and are not incurred by the client. Pershing also charges an account maintenance fee that the client will pay on an annual basis. Separately Managed Account Programs at Sawtooth may have alternate fee structures. Unified Managed Account (“UMA”) Programs OAS sponsors and offers to its clients Unified Managed Account Programs through an agreement between OAS and the Account Managers. OAS performs the introducing brokerage services and its Advisor Representatives do not have discretionary investment authority in the accounts under this program. The Account Managers have discretionary authority to supervise and direct all monies contributed by the client, but they must act in accordance with the client’s investor profile, which includes, but is not limited, to the consideration of liquidity needs, risk tolerance, and account objectives. Separate disclosure statements for the Account Managers are provided to the client by OAS. UMA programs include mutual funds, exchange-traded funds (“ETFs”), stocks, and bonds selected by the Account Managers based on information submitted by the client to OAS. Under this program, the Account Managers act as a Unified Managed Account manager (“UMA Manager”). The Account Managers have arrangements with certain other registered investment advisors who have agreed to act as third-party providers of research services (“Research Providers”). Under the UMA programs managed by the Account Managers, Research Providers provide the Account Managers with purchase and sale recommendations in the form of model portfolios. Generally, the Account Managers manage assets in accordance with the specific investment strategies of the Research Providers that have been

selected by the UMA Manager for use in its various UMA Programs. Unified Managed Account Programs at Envestnet are wrap fee programs whereby the management fee and the administrative fee are combined. Brokerage Fees charged by the clearing firm, Pershing, are covered by OAS and are not incurred by the client. Pershing also charges an account maintenance fee that the client will pay on an annual basis. Unified Managed Account Programs at Sawtooth may have alternate fee structures. AssetMark Advisor Managed Portfolios (“AMP”) OAS offers the AMP platform to its clients. AMP is an open architecture, discretionary program for which OAS IARs serve as the Account Managers on a discretionary basis. OAS IARs have discretionary authority to supervise and direct all monies contributed by the client, but they must act in accordance with the client’s investor profile, which includes, but is not limited to, the consideration of liquidity needs, risk tolerance, and account objectives. AMP programs include stocks, bonds, mutual funds, and ETFs selected by OAS IARs based on information submitted by the client to OAS. AMP is a wrap fee program whereby the management fee and the administrative fee are combined. Depending on the account registration and/or the investments held within the account, Brokerage Fees may be charged by the custodian selected by the client through consultation with the IAR. The custodian may also charge an account maintenance fee that the client will pay on an annual basis. The wrap program has its own official disclosure document (Appendix 1) that describes all fees and services. For additional information, please refer to the Appendix 1. Financial Planning Financial planning services offered through OAS include the creation of financial plans and consultations. Following a thorough financial review, a plan will include a detailed analysis and recommendations. Consultations are provided for specific, targeted areas and include a written statement of observations and/or recommendations. Employer-Sponsored Retirement Plan Consulting Services OAS offers consulting and advisory services to employer-sponsored retirement plans. It may also assist employers by providing plan enrollment and investment education to plan participants and beneficiaries. Prior to opening a Retirement Plan account, a Retirement Plan Consulting Agreement (“Agreement”) must be completed by the plan sponsor (“Sponsor”). The purpose of the Agreement is to collect certain information concerning plan design, plan objectives and third-party service providers. Once completed, OAS will deliver a copy of the Agreement and applicable disclosures to the Sponsor. The Sponsor must indicate the desired services in the Agreement and review the Agreement and disclosures to determine the services are necessary and the compensation is reasonable prior to executing the Agreement. Under limited circumstances and pursuant to a written agreement, OAS will provide certain services as a fiduciary under the Employer Retirement Income Security Act of 1974, as amended (“ERISA”) to employer-sponsored retirement plans. ERISA fiduciary services offered by OAS are limited to only include: Investment Manager Selection and Monitoring Support Services: OAS may provide recommendations and advice designed to assist the Sponsor in selecting and monitoring a discretionary investment manager (“Manager”) as defined under Section 3(38) of ERISA. The Manager, and not OAS, will be solely responsible to work with the Sponsor to develop an appropriate investment policy statement (“IPS”) and to select and monitor the plan’s designated investment alternatives that are consistent with the objectives of the IPS. The Manager may also make available model asset allocation portfolios for plan participants. In assisting the Sponsor, OAS may make recommendations that are, among other things, based upon the Manager’s style, process and investment guidelines; manager specific impact; survey data; and fee analysis. The Sponsor will have the final approval on the hiring and/or retention of any Manager recommended by OAS. Upon request, OAS may further assist the Sponsor with collecting and evaluating information relating to the ongoing monitoring of the Manager, including the reasonableness of the Manager’s fees and to benchmark the Manager’s overall performance vis-à-vis applicable, recognized industry indices. OAS may also provide the following administrative and/or ministerial functions to employer sponsored retirement plans, for which it will not be considered to be a fiduciary under ERISA: Plan Governance Review and Committee Support: OAS may assist the Sponsor with the establishment and maintenance of the plan committee and will recommend protocols designed to help the Sponsor manage and administer the plan. The Sponsor is solely responsible for appointing or removing plan committee members; however, OAS may educate plan committee members about their fiduciary duties, help the plan committee coordinate regular meetings and assist the plan committee with maintaining a fiduciary audit file. Vendor Management: OAS may assist the Sponsor with selecting and monitoring the plan’s service providers. OAS may use third-party tools and publicly available data to assist the Sponsor with benchmarking the fees charged by a service provider. The Sponsor retains decision-making authority to select, remove and/or replace the plan’s service providers. Employee Enrollment and Investment Education: OAS may conduct periodic group enrollment and education meetings with employees and educational meetings with plan participants and beneficiaries. OAS will utilize standardized materials that are consistent with “investment education,” as that term is defined in Department of Labor Interpretative Bulletin 96-1, in connection with providing Employee Enrollment and Investment Education services. Such information may include information about the benefits of plan participation, investment objectives of plan investment options, general financial and investment information, asset allocation portfolios of hypothetical individuals with different time horizons and risk profiles and interactive investment materials such as questionnaires to assess the impact of different allocations on retirement income. OAS may also provide interactive investment materials to assist participants in assessing their future retirement income needs. In providing Employee Enrollment and Investment Education services, OAS will not provide any “investment advice” as that term is defined in ERISA and will, therefore, not be acting as an ERISA fiduciary in rendering such services. Self-Directed Brokerage Account (“SBDA”) Education Where a qualified retirement plan contains a company stock or SDBA investment option, OAS will not be required to take such investment options into account with respect to its determinations or recommendations. Plan fiduciaries will retain sole fiduciary responsibility with respect to such company stock or SDBA option.