Oak Harvest Investment Services, LLC
920 Memorial City Way
Suite 150
Houston, TX 77024
Tel: (281) 822-1350
Fax: (281) 822-1355
www.oakharvestfg.com

Form ADV Part 2A Firm Brochure
Version date: October 6, 2023

This brochure provides information about the qualifications and business practices of Oak Harvest Investment
Services, LLC. Please contact us at 281-822-1350, or by email at [email protected] if you have any
questions about the contents of this brochure.
Additional information about Oak Harvest Investment Services, LLC is available on the SEC's website at
www.adviserinfo.sec.gov. Click on the "Investment Adviser Search" link and then search for "Investment
Adviser Firm" using the firm's IARD ("CRD") number, which is 173293.
While the firm and its associates may be registered and/or licensed within a particular jurisdiction, that
registration and/or licensing in itself does not imply an endorsement by any regulatory authority, nor does it
imply a certain level of skill or training on the part of the firm or its associated personnel.

Item 2- Material Changes

The material changes in this brochure from the last annual updating amendment of Oak Harvest Investment
Services, LLC on 03/14/2023 are described below. Material changes relate to Oak Harvest Investment
Services, LLC’s policies, practices, or conflicts of interests.

• Oak Harvest Investment Services, LLC is now managing held away assets through Pontera. (Item 4)
• Oak Harvest Investment Services, LLC has added Tax Preparation Services. (Items 4 and 5)
• Oak Harvest Investment Services, LLC engages or retains unaffiliated third parties to act as solicitors
for Oak Harvest’s advisory services. (Item 14)
• Oak Harvest Investment Services, LLC has updated its financial planning fees. (Item5)

The firm may at any time update this document and either send a copy of its updated brochure or provide
a summary of material changes to its brochure and an offer to send an electronic or hard copy form of the
updated brochure. Clients are also able to download this brochure from the SEC's website at
www.adviserinfo.sec.gov or from our website at www.oakharvestfg.com,or may contact us at (281) 822-
1350 or by email at [email protected] to request a copy at any time.

Item 3 -Table of Contents

Item 1- Cover Page .....................................................................................................................................................1
Item 2- Material Changes...........................................................................................................................................2
Item 3 -Table of Contents...........................................................................................................................................3
Item 4 - Advisory Business..........................................................................................................................................4
Item 5 - Fees and Compensation................................................................................................................................8
Item 6- Performance-Based Fees and Side-By-Side Management ..........................................................................12
Item 7 - Types of Clients...........................................................................................................................................12
Item 8 - Methods of Analysis, Investment Strategies and Risk of loss.....................................................................13
Item 9 - Disciplinary Information..............................................................................................................................16
Item 10- Other Financial Industry Activities and Affiliations ...................................................................................16
Item 11- Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............................17
Item 12 - Brokerage Practices ..................................................................................................................................19
Item 13 - Review of Accounts...................................................................................................................................20
Item 14- Client Referrals and Other Compensation.................................................................................................21
Item 15 – Custody.....................................................................................................................................................22
Item 17 -Voting Client Securities..............................................................................................................................23
Item 18 - Financial Information................................................................................................................................23

 

Item 4 - Advisory Business

Important Information

Throughout this document Oak Harvest Investment Services, LLC shall also be referred to as "the firm," "firm,"
"our," "we" or "us." The client or prospective client may be also referred to as "the client," "client," etc., and
refers to a client engagement involving a single person as well as two or more persons, and may refer to natural
persons and legal entities. The term "advisor" and "adviser" are used interchangeably where accuracy in
identification is necessary (i.e., internet address, etc.).

Our firm maintains a business continuity and succession contingency plan that is integrated within the
organization to ensure it appropriately responds to events that pose a significant disruption to its operations. A
statement concerning the current plan is available separately.
Description of the Advisory Firm

Oak Harvest Investment Services, LLC is a Texas domiciled limited liability company formed in September of
2014. Our firm is a wholly owned subsidiary of Texas-based OHFG Ventures, LP. We may operate under the
trade name of Oak Harvest Investment Services or Oak Harvest Financial Group.
Troy R. Sharpe, CFP® is our advisory firm's Chief Executive Officer. Mr. Sharpe is an owner and majority interest
holder of OHFG Management Inc., the owner of OHFG Ventures, LP. Jessica Cannella Sharpe is also an owner of
OHFG Management Inc.

Types of Advisory Services

Oak Harvest Investment Services offers portfolio management services and financial planning and consulting
services to its clients, as well as educational workshops.

Financial Planning and Consulting

Our financial planning and financial consulting services may include, but are not limited to: investment planning,
portfolio analysis, financial risk management, employee benefits, tax concerns, divorce planning, legacy concerns,
retirement planning, education planning, income and cash flow planning, and debt/credit planning. All financial
planning and consulting advice, recommendations, and plans are developed based on your financial situation, via
information provided by the client, or from the client’s other professionals (accountants, attorneys), with the
client’s authorization. Planning and consulting services provided may be as broad-based or narrowly focused as
you desire. Note that when our planning focuses only on certain areas of your interest or need, your overall
situation or needs may not be fully addressed due to limitations you may have established.

Our financial plans or financial consultations rendered to clients usually include general recommendations for a
course of activity or specific actions to be taken by the clients. For example, recommendations may be made that
the client begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage,
commence or alter retirement savings, or establish education or charitable giving programs. We refer clients to an
accountant, attorney, or other specialist, as necessary for non-advisory related services.

For our financial planning services , we create written financial plans that encompass the use of one or more
financial planning software programs. Clients will be provided either printed reports or online access to the firm’s
created plans via such financial planning programs. In such cases clients can request printed reports at any times.
For financial consultations, we usually do not provide a written financial plan as the process is less formal than our
planning service. The firm’s advice will be delivered verbally via consultation that takes place in-person, on a call,
or virtually. Plans or consultations are typically completed within six (6) months of the client signing a contract with
us, assuming that all the information and documents we request from the client are provided to us promptly.
Implementation of the recommendations will be at the discretion of the client. Generally, both our financial
planning and financial consulting services are provided as parts of our portfolio management services offering (see
directly below).

Portfolio Management Services

Oak Harvest offers the same suite of portfolio management services to all of our portfolio management clients. For
our portfolio management clients, we offer portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client, and also include ongoing financial consulting, coaching,
and planning. Our portfolio management service offering is inclusive of our financial planning and financial
consulting services. Our offering usually includes the development of various deliverables or access to tools such
as online accounts via which clients can view the output of financial planning software or written financial plans,
but the exact planning tools and outputs will differ based on the client’s specific needs.

Oak Harvest conducts a series of meetings with clients during which we collect information outlining the client’s
current financial situation (income, risk tolerance, objectives, tax concerns, and other information), and seeks to
make investment decisions that are in accordance with the information provided, and in accordance with the
firm’s fiduciary duties owed to all of its clients. In addition to the financial consulting and planning services
described above, portfolio management services include, but are not limited to, the following:

Investment Strategy
Asset Allocation
Personal Client Profile (Risk Tolerance, Investment Objectives, Goals, etc.)
Asset and Security Selection
Regular Portfolio Monitoring

We manage client portfolios on a discretionary or nondiscretionary basis (defined in Item 16). We will generally
request discretionary authority from clients in order to select securities and execute transactions without
permission from the client prior to each transaction.

We will review your accounts at least annually (See Item 13). We want to note that it will remain your
responsibility to promptly notify us if there is any change in your financial situation and/or investment objectives
for the purpose of our reviewing, evaluating, or revising previous account restrictions or firm investment
recommendations. In making its recommendations, Oak Harvest will rely on the information in its possession that
is provided by the client, or from the client’s other professionals (i.e., attorney, accountant), with the client’s
authorization.

Oak Harvest seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to
its accounts and without consideration of Oak Harvest’s economic, investment or other financial interests. To meet
its fiduciary obligations, Oak Harvest attempts to avoid, among other things, investment or trading practices that
systematically advantage or disadvantage certain client portfolios, and accordingly, Oak Harvest’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 our 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.

Participant Account Management (Discretionary)

OHIS uses a third-party platform, Pontera, to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. Pontera allows OHIS to avoid being considered to have
custody of client funds since OHIS does not have direct access to client log-in credentials. OHIS is not affiliated with
the platform in any way and receives no compensation from the platform provider for using the platform. A link
will be provided to the client allowing them to connect accounts to the platform. Once client accounts are
connected to the platform, OHIS will review the current account allocations. When deemed necessary, OHIS will
rebalance the account considering client investment goals, risk tolerance and market conditions.

Types of Investments and Client Imposed Restrictions

Oak Harvest generally limits its investment advice to mutual funds, exchange traded funds (ETFs), fixed income
securities, real estate investment trusts (REITS), and equities. Oak Harvest will incorporate any reasonable account
restraints you may have for the portfolio. For example, you have the right to exclude certain securities (e.g., single
stocks, single bonds, mutual funds, ETFs, etc.) at your discretion. However, if the restrictions prevent Oak Harvest
from properly servicing the client account, or if the restrictions would require Oak Harvest to deviate from its
standard suite of services, Oak Harvest reserves the right to end the relationship.

Educational Workshops

We offer periodic complimentary educational seminar sessions for those desiring general advice on personal
finance and investing. Topics may include issues related to general financial planning, educational funding,
retirement strategies, implications involving changes in marital status, and various other current economic or
investment topics.

Our workshops are educational in nature and do not involve the sale of insurance or investment products.
Information presented will not be based on any one person's need nor do we provide individualized
investment advice to attendees during our general sessions.

Written Acknowledgement of Fiduciary Status

When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we
make money creates some conflicts with your interests, so we operate under a special rule that requires us to
act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:

• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.

Assets Under Management

As of December 2022, our firm has $ 555,008,461 of reportable client assets directly under
management on a discretionary basis.

Wrap Fee Programs
The firm does not sponsor or serve as a portfolio manager in an investment program involving wrapped
(bundled) fees.

General Information

Limitations of Financial Planning Services

We do not provide legal or accounting services, but with your consent we will work with your attorneys,
accountants, or other professionals to assist with the coordination and implementation of various accepted
strategies. If requested, we may also recommend the services of other professional services (i.e., attorneys,
accountants). The firm receives no compensation for such recommendations and the client is under no obligation
to engage the services of any recommended professional. The client retains absolute discretion over all
implementation decisions and is free to accept or reject any recommendation from Oak Harvest or its
representatives. You should be aware that other professionals will charge you separately for their services and
these fees will be in addition to our own fees.

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 Oak Harvest recommends that a client roll over their retirement plan assets into an account to be managed by
Oak Harvest, such a recommendation creates a conflict of interest since Oak Harvest will earn new (or increase its
current) compensation as a result of the rollover. No client is under any obligation to rollover retirement plan
assets to an account managed by Oak Harvest, and we address this conflict of interest by basing our
recommendations off of each client’s personal financial situation. Oak Harvest always seeks to act in the best
interest of each of our clients.

If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:

1. Determine whether the investment options in your employer's retirement plan address your needs or
whether you might want to consider other types of investments.

a) Employer retirement plans generally have a more limited investment menu than IRAs.
b) Employer retirement plans may have unique investment options not available to the public such as
employer securities, or previously closed funds.

2. Your current plan may have lower fees than our fees.

a) If you are interested in investing only in mutual funds, you should understand the cost structure of the
share classes available in your employer's retirement plan and how the costs of those share classes
compare with those available in an IRA.
b) You should understand the various products and services you might take advantage of at an IRA
provider and the potential costs of those products and services.

3. Our strategy may have higher risk than the option(s) provided to you in your plan.

4. Your current plan may also offer financial advice.

5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required
minimum distribution.

6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a) Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have
been generally protected from creditors in bankruptcies. However, there can be some exceptions to
the general rules so you should consult with an attorney if you are concerned about protecting your
retirement plan assets from creditors.

7. You may be able to take out a loan on your 401k, but not from an IRA.

8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may
also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability,
higher education expenses or the purchase of a home.

9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains
tax rate.

10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is
important that you understand the differences between these types of accounts and to decide whether a
rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser
representative, or call our main number as listed on the cover page of this brochure.

Use of Mutual Funds, Exchange Traded Funds, Single Stocks and Bonds

Most mutual funds, exchange traded funds, and single stocks and bonds are available directly to the public. Thus, a
prospective client can obtain many of the funds, stocks, or bonds that may be used by Oak Harvest independent of
engaging Oak Harvest as an investment adviser. However, if a prospective client determines to do so, they will not
receive Oak Harvest’s initial and ongoing investment advisory services.

Portfolio Activity or Inactivity

Oak Harvest will review client investment portfolios on an ongoing basis to determine if any changes are necessary
based upon various factors, which may include but are not limited to investment performance, investment or
market outlook, economic outlook, changes in company or fund management, fund manager tenure, style drift,
account additions/withdrawals, changes in the client’s situation, or results of an annual account review. There may
be periods of time, which may be substantial, when Oak Harvest determines that changes to a client’s portfolio are
not necessary. Notwithstanding, we will continue to charge fees on the value of the client’s account.

Non‐Discretionary Service Limitations

Oak Harvest will generally request discretionary authority for client accounts. However, if a client determines to
engage Oak Harvest on a non‐discretionary investment advisory basis must be willing to accept that Oak Harvest
cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client.
Thus, in the event that Oak Harvest would like to make a transaction for a client’s account, and client is
unavailable, Oak Harvest will be unable to affect the account transaction (as it would for its discretionary clients)
without first obtaining the client’s consent.

Investment Risk

Different types of investments involve varying degrees of risk, and it should not be assumed that future
performance of any specific investment or investment strategy (including the investments and/or investment
strategies recommended or undertaken by Oak Harvest) will be profitable or equal any specific performance levels.
Past performance is not indicative of future returns.

Item 5 - Fees and Compensation

Asset-Based Fees for Portfolio Management Service Offering

Oak Harvest collects a fee for the advice we provide. We manage assets and provide financial consulting, coaching,
and planning services (our portfolio management service offering is inclusive of our financial planning and
consulting services) for an advisory fee based on the following fee schedule. Clients are assessed an asset-based
advisory fee which includes all of our advisory services and that is based on the end of quarter account value in the
client’s account(s). Advisory fees for portfolio management services are generally non-negotiable. Clients are billed
quarterly, in arrears. Fees are paid by withdrawal from your investment account held at the custodian of record. All

fees withdrawn from your account will be noted in the account statement you will receive from the custodian.
Our advisory fee is based on the following tiered structure. We bill on a quarterly basis, in arrears, per the
following fee schedule:

Assets Under Management Annualized Asset-Based Fee

$0-$999,999 1.37% (137 basis points)
$1,000,000 – $1,499,999 1.22% (122 basis points)
$1,500,000 – $1,999,999 1.12% (112 basis points)
$2,000,000 – $2,999,999 1.07% (107 basis points)
$3,000,000 – $3,999,999 .97% (97 basis points)
$4,000,000 – $4,999,999 .89% (89 basis points)
$5,000,000 – $9,999,999 .81% (81 basis points)
$10,000,000 – $24,999,999 .75% (75 basis points)
$25,000,000 and Over .62% (62 basis points)

Aggregating Fees

For the benefit of discounting your asset-based fee, we will attempt to aggregate multiple investment accounts
belonging the same individual, or two or more accounts within the same family, or accounts where a family
member has power of attorney over another family member's or incompetent person's account when possible.

Account Valuations

Oak Harvest uses the end of quarter account value in the client’s account(s) for purposes of determining the
market value of the assets upon which the advisory fee is based. Our billing platform uses values taken from the
Custodian of Record for each of your accounts to determine the end of quarter value upon which we will bill.

Billing Exclusions

The firm does not invest in or manage securities which are not traded, or other “hard to value” assets. However,
on occasion, a client elects to transfer such assets into their investment account held at Oak Harvest. In the event a
client elects to transfer such assets into their account held with Oak Harvest, such assets shall not be included in
the calculation of the end-of-quarter account value calculation for billing purposes, unless an accurate valuation is
provided by the custodian of record. With the exception of such non-traded, or other “hard to value” assets, the
firm does not exclude any other type of assets from billing, including cash and cash equivalents.

Advisory Fee Withdrawals

Your first billing cycle will begin once your agreement is executed with our firm and an initial deposit or transfer of
assets has been made into your account held by the custodian of record. Our fees are pro-rated based on the date
of initial funding of each of your accounts. It is important to understand that cash flows in and out of the account
subsequent to initial funding, or additional deposits of securities, are not pro-rated, regardless of the size of the
deposit or transfer. This means that if you are an existing client and you deposit additional funds into an already
existing account that has already been open for a full billing cycle, the additional deposit will not be billed on a prorated basis. The entire account, including the deposit made midway through the billing period, will be billed for the
full billing period, based on the value of the account on the last day of the quarter. Fees will generally be
withdrawn from your account(s) within the first 15 days of each billing cycle.

By signing our firm's engagement agreement, as well as the custodian’s account opening documents, you will
be authorizing the withdrawal of our advisory fees from your account. Your written permission is required
before we withdraw any fees from your account. The withdrawal will be accomplished by the custodian of
record at the request of our firm, and the custodian will remit our fee directly to our firm. All fees deducted
will be noted on account statements that you will receive directly from the custodian of record on a monthly
basis. It is important that you verify the accuracy of fee calculations; the custodian will not verify the accuracy
of advisory fee assessments for you.

Financial Planning and Consulting Fees (Stand-Alone Services)

In certain circumstances and solely at the discretion of the firm, we also may choose to provide planning and
consulting services as stand-alone services that do not require clients to give us assets to manage. As a standalone service, we charge an hourly fee for Financial Consulting services, with a minimum of one hour required.

Financial Planning Fees consist of a fixed fee that is paid in advance, but never more than 6 months in advance.
Clients may also engage the firm to further review and update the plan, and to monitor your progress for an
ongoing fee that is paid annually. The total estimated fee, as well as the ultimate fee that we charge, is based on
the scope and complexity of the engagement.

Clients are under no obligation to engage the firm to develop a written plan. Clients are under no obligation to
engage the firm for further review or monitoring of a completed financial plan. Planning and Consulting services
provided may be as broad-based or narrowly focused as you desire. Note that when our planning focuses only on
certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations
you may have established.

Fees for Financial Consulting (Stand-Alone Service)

An Oak Harvest advisor or specialist will render one or more consultations with you to provide advice,
recommendations, or coaching on matters relevant to your situation. Our hourly fees range between $150 to
$450 an hour for advice delivered via financial consultations. Financial consultations can be as limited or as broad
as each client desires, and the hourly fee is generally based on the scope, complexity and level of expertise
required to provide advice for each consultation. Financial Consulting fees are generally negotiable based on these
factors. The negotiated fee will be documented and attached to the client’s engagement agreement with the firm
via the appropriate signed addendum.

Fees for Creation of Financial Plan (Stand-Alone Service)

Oak Harvest will develop a written financial plan for you, utilizing various financial planning programs and
applications. Since the scope of each client’s financial plan can be as limited or broad as each client desires,
Financial Planning Fees are generally negotiated on a case-by-case basis, based on the complexity of your
situation, needs, and the time and resources the firm believes will need to be deployed. The negotiated cost for
the completion of a financial plan is typically between $6850 and $25,000 . The negotiated fee will be documented
and attached to the client’s engagement agreement with the firm via the appropriates signed addendum.
Fees for Further Review and Monitoring and Updates (Stand-Alone Service)

If the client elects to engage the firm for further review, updates, and monitoring of a completed financial plan,
the firm will charge an ongoing fee that is paid annually.

As with the creation of the initial financial plan, the annual fee for further services provided depends on the scope
of each client’s engagement, and the time and resources that will be deployed. Since the scope of each client’s
financial planning service can be as limited or broad as each client desires, the annual fee for further review,
assistance and monitoring is generally negotiated annually on a case-by-case basis, based on the complexity of
your situation, needs, and the time and resources the firm believes will need to be deployed for the year in
question. The negotiated annual cost for additional review, assistance, and monitoring is between $150 and
$5,000 per year. The negotiated fee will be documented and attached to the client’s engagement agreement with
the firm via the appropriates signed addendum.

Financial Planning and Consulting Fee Payment (Stand-Alone Service)

Fees for financial planning and consulting services will be paid by check or wire from US-based financial
institutions or through a qualified, unaffiliated third-party processor. Our firm does not accept cash, money
orders or similar forms of payment for its engagements.

Fees for the creation of a financial plan may be entirely paid in advance, but never more than six months in
advance, or on agreed on monthly basis within a period of no more than 12 months. The plan may also be paid
for by provision of a 50% payment of the expected total in advance, and any remainder on the completion and
delivery of the plan.

Fees for additional assistance, review, and monitoring of a completed financial plan are paid annually, in
advance, but never more than six months in advance, or on an agreed on monthly basis within a period of no
more than 12 months. The annual fee for additional assistance, review, and monitoring may also be paid for by
provision of a 50% payment of the expected total in advance, and any remainder on the completion and
delivery of agreed on deliverables or plan updates.

Fees for financial consulting are billed at the conclusion of a consultation. Consulting fees may be billed at the
conclusion of each financial consultation, or if a series of consultations is necessary, clients will be billed the
total fee at the conclusion of the consultations. In the event of an expected series of consultations, the firm
may ask for 50% of the planned total fee to be paid in advance, but never more than six months in advance,
and the remainder of any fees owed to be paid on completion of the financial consultations.

Educational Workshops Fees

Workshop sessions are complimentary; no fee is assessed by our firm.

Discounting Fees

The advisory services to be provided and their fees, along with any other fee assessed by the company (see
“Additional Client Fees” below), will be detailed in the client engagement agreement. Published fees may be
discounted at the discretion of our firm.

Additional Client Fees

The firm will assess a technology service fee from its portfolio management clients that covers the use of the
technology platform that provides client reporting, the Oak Harvest Client Portal, and Oak Harvest mobile app. This
fee will be delineated in your engagement agreement with Oak Harvest. Though this fee is required and the
amount non-negotiable, it may be waived at the discretion of the firm. As of 2020, the technology service fee is
$40 per year, per custodial account. The technology service fee is withdrawn from your investment account(s) on a
pro-rated, quarterly basis.

Client Responsibility for Third-Party Fees

Clients are responsible for all account fees, including but not limited to, mutual fund fees, transactional fees or
custodian asset-based pricing fees, individual retirement account fees, account termination fees, or wire transfer
fees. Advisory fees paid by our client to our firm for our services are separate from any of these fees or other
similar charges, as well as internal costs associated with certain mutual funds, exchange-traded funds (ETFs), or
other instruments.

External Compensation for the Sale of Securities to Clients

Neither Oak Harvest 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.

Mr. Sharpe and other firm associates are licensed insurance agents and appointed with various unaffiliated
insurance carriers via our insurance agency Oak Harvest Insurance Services, LLC. Further information with regard
to these other activities may be found in each associate's accompanying Form ADV Part 2B brochure supplement.
See also Items 10 and 14 below.

These activities create a conflict of interest as there is an incentive to recommend insurance products based on the
compensation received from the insurance company for the sale of an insurance product, rather than on the
client’s needs. Additionally, the offer and sale of insurance products by representatives of Oak Harvest Investment
Services are not made in the representatives’ capacity as a fiduciary and are limited to insurance providers that
have agreements to sell with Oak Harvest Insurance Services.

Oak Harvest Investment Services addresses this conflict of interest by requiring all of its representatives to act in
the best interest of the client at all times, including permitting its representatives who are insurance agents to
recommend insurance products only in the best interests of the client. Oak Harvest representatives will disclose
in advance how they are being compensated and all conflicts of interest involving any advice or service being
provided. At no time will there be tying between business practices and/or services; a condition where a client or
prospective client would be required to accept one product or service which is conditional upon the selection of a
second, distinctive tied product or service.

No client is ever under any obligation to purchase any insurance product. Insurance products recommended by
Oak Harvest representatives may also be available from other providers on more favorable terms, and clients can
purchase insurance products recommended by Oak Harvest through other, non‐affiliated insurance agencies. OHIS
will always act in the best interest of the client.

Termination of Services

Either party may terminate the agreement for portfolio management, financial consulting, or financial planning at
any time upon written notice.

If you terminate your investment management accounts, we will not be responsible for investment allocation,
advice, or transactional services (except for limited closing transactions). If the Client did not receive the Firm’s
Form ADV Part 2 brochure at least 48 hours prior to entering into the Agreement, then the Client will have the
right to terminate the engagement without fee or penalty within five business days after entering into the
Agreement. If the client did receive the firm’s Form ADV Part 2, or after the five-day period noted above, the Client
will be assessed fees on a prorated basis for services incurred from either (i) as a new Client, the date of the
engagement to the date of account termination or receipt of notice of termination, or (ii) all other accounts, the
last billing period to the date of account termination or receipt of notice of termination.

Financial Planning and Consulting: Clients may terminate the agreement without penalty for a full refund of Oak
Harvest’s fees within 5 business days of signing the Financial Planning Agreement. Beyond that period, upon
termination, the client will be responsible for paying the pro-rated fee for work completed but unpaid (if any) at
the time the termination becomes effective.

Financial Consulting clients who have signed the agreement but not yet engaged in any financial consultations are
entitled to have the full amount of any paid fees refunded. If the client has already received a financial
consultation, the client will owe fees only for completed consultation(s). If any fees were paid in advance, the
client is only responsible for paying the pro-rated fee for consultations completed at the time the termination
becomes effective. Any further fees will be refunded as described below.

Oak Harvest will determine, in good faith, an amount equal to the unearned fees, if any, and shall promptly refund
such amount to you. “Unearned fees” means the portion of any fees that we determine are attributable to services
that had not been performed by us prior to receipt of notice of termination from you. In the case of the annual fee
for additional assistance, review, and monitoring, fees due will be pro-rated and any unearned fee will be refunded
to the client. Refunds for fees paid in advance will be returned within 14 days to the client via check.

Item 6- Performance-Based Fees and Side-By-Side Management

Our firm's advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any
portion of managed funds, also known as performance-based fees. Our fees will also not be based on side-byside management, which refers to a firm simultaneously managing accounts that do pay performance-based
fees (such as a hedge fund) and those that do not.

Item 7 - Types of Clients

Oak Harvest provides advisory services to generally the following types of clients:
• Individuals
• Families
• High Net Worth Individuals
• High Net Worth Families

The firm is willing to expand our advisory services to other types of clients.

Minimum Account Size for Portfolio Management Services

Our minimum requirement for opening or maintaining an account for our portfolio management services is
generally $500,000. Generally, this minimum may be waived or reduced at the Advisor’s discretion.
We reserve the right to waive or discount any of the firm’s fees based on unique individual circumstances,
special arrangements, or pre-existing relationships. However, we may decline services to a prospective client
for any non-discriminatory reason.

Item 8 - Methods of Analysis, Investment Strategies and Risk of loss

Investing in securities involves risk of loss that clients should be prepared to bear.
Oak Harvest Investment Services utilizes a series of meetings and questionnaires to determine your investment
goals, risk tolerance, time horizon, and other information related to your financial situation in an effort to
determine investment strategies and allocations that are best suited to fit the Client’s needs. After Oak Harvest
evaluates the Client’s financial needs, we will design investment programs to assist the Client to achieve their
financial goals.

Analysis Methods

Security analysis used by Oak Harvest may include the following:

Fundamental Analysis
Fundamental analysis involves analyzing a business’s financial statements and health, management and
competitive advantages, and competitors and markets.

Technical Analysis
Technical analysis is a discipline for forecasting the direction of prices through the study of past market data,
primarily price and volume.

Cyclical and Value Analysis
Cyclical analysis is an analysis of recurring periods of expansion and contraction that can impact a company’s
profitability and cash flow to find favorable conditions for buying and/or selling a security. Value-based analysis
seeks to find securities that are undervalued relative to the market as a whole, or a particular economic sector
or industry group.

Sources of Information

Our research is drawn from sources that include:
• Financial Periodicals
• Reports from economists and other industry professionals
• Corporate Ratings Services
• Company Annual Reports
• Conference Calls
• Press Releases
• Prospectuses and other regulatory filings
• World Wide Web
• Research materials prepared by others
• Investor Business Daily’s MarketSmith
• Historical Data from Securities Exchanges

Investment Strategies

Oak Harvest uses:
• Long Term Purchases which are investments held at least a year
• Short Term Purchases which are investments sold within a year

Portfolios will hold investments including mutual funds (including Real Estate mutual funds), ETFs, individual
equities (Including REITs), and fixed income (bond) positions.

Material Risk Involved

Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients (including you) should never assume that future performance of any specific investment or
investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds) involves
risk of loss.

Further, depending on the different types of investments there may be varying degrees of risk. Clients and
prospective clients should be prepared to bear investment loss including loss of original principal. Because of the
inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our
services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or
insulate you from losses due to market corrections or declines. There are certain additional risks associated when
investing in securities through my investment management program.

Risks of Methods of Analysis

Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings.
This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their
perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption
is that the market follows discernible patterns and if these patterns can be identified then a prediction can be
made. The risk is that markets do not always follow patterns and relying solely on this method may not take
into account new patterns that emerge over time.

Cyclical and value analysis assumes that the markets react in cyclical patterns which, once identified, can be
leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always
repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very
cycles these investors are trying to exploit. Risk related to value analysis include the mis-valuing of securities
relative to the market as a whole, sectors, or competitors, and risks that the share price of under-valued
security may not increase in value for longer than expected or at all.

Risks of Investment Strategies

Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term
investment strategy can expose clients to various types of risk that will typically surface at various intervals
during the time the client owns the investments. These risks include but are not limited to inflation (purchasing
power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.

Short term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading
risks listed above. Frequent trading can affect investment performance, particularly through increased
brokerage and other transaction costs and taxes.

Risks of Specific Securities Utilized

Clients should be aware that there is a material risk of loss using any investment strategy. The investment types
listed below are not guaranteed or insured by the FDIC or any other government agency.

Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing
in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed
income” nature (lower risk) or stock “equity” nature.

Equity investment generally refers to buying shares of stocks in return for receiving a future payment of
dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in
response to specific situations for each company, industry conditions and the general economic environments.
Fixed Income investments generally pay a return on a fixed schedule, though the amount of the payments can
vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield,
and investment grade debt and structured products, such as mortgage and other asset-backed securities,
although individual bonds may be the best-known type of fixed income security. In general, the fixed income
market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually
fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities
also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties.

The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury
defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather
minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing
described below.

Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks.
Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding
bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts
of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or
Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by
several unique factors, among them (1) large sales by the official sector which own a significant portion of
aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by
producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors.
Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which
historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be
adversely affected by: changes in local real estate market conditions due to changes in national or local
economic conditions or changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt and equity credit
markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating
expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact
of present or future environmental legislation and compliance with environmental laws.
Past performance is not indicative of future results. Investing in securities involves a risk of loss that
you, as a client, should be prepared to bear.

Item 9 - Disciplinary Information

Neither the firm nor its management has been involved in a reportable criminal or civil action in a domestic,
foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization
proceeding per current guidelines.

Item 10 - Other Financial Industry Activities and Affiliations

Oak Harvest and its representatives may refer clients to other third parties, which could include accounting firms,
law firms, real estate brokers, and banking firms. Oak Harvest and our associated persons will not receive any
compensation for such referrals.

Registration as a Broker/Dealer or Broker/Dealer Representative

Neither Oak Harvest nor its representatives are registered as, or have pending applications to become, a
broker/dealer or a representative of a broker/dealer.

Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading
Advisor

Neither Oak Harvest 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.

Registration Relationships Material to this Advisory Business and Conflicts of Interests

Mr. Sharpe and other firm associates are licensed insurance agents and appointed with various unaffiliated
insurance carriers via our insurance agency Oak Harvest Insurance Services, LLC. Further information with regard
to these other activities may be found in each associate's accompanying Form ADV Part 2B brochure supplement.
These activities create a conflict of interest as there is an incentive to recommend insurance products based on the
compensation received from the insurance company for the sale of an insurance product, rather than on the
client’s needs. Additionally, the offer and sale of insurance products by representatives of Oak Harvest Investment
Services are not made in the representatives’ capacity as a fiduciary, and are limited to insurance providers that
have agreements to sell with Oak Harvest Insurance Services.

Oak Harvest Investment Services addresses this conflict of interest by requiring all of its representatives to act in
the best interest of the client at all times, including permitting its representatives who are insurance agents to
recommend insurance products only in the best interests of the client. Oak Harvest representatives will disclose
in advance how they are being compensated and all conflicts of interest involving any advice or service being
provided. At no time will there be tying between business practices and/or services; a condition where a client or
prospective client would be required to accept one product or service which is conditional upon the selection of a
second, distinctive tied product or service.

No client is ever under any obligation to purchase any insurance product. Insurance products recommended by
Oak Harvest representatives may also be available from other providers on more favorable terms, and clients can
purchase insurance products recommended by Oak Harvest through other, non‐affiliated insurance agencies. OHIS
will always act in the best interest of the client.

Selection of Other Advisers or Managers and How This Advisor is Compensated for Those Selections
Oak Harvest does not utilize nor select third-party investment advisers. All assets are managed by Oak Harvest
Investment Services.

Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Code of Ethics

Oak Harvest has adopted a Code of Ethics for all supervised persons of the firm describing its high
standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the
confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions
on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and
personal securities trading procedures, among other things. All supervised persons at Oak Harvest must
acknowledge the terms of the Code of Ethics annually, or as amended. Oak Harvest’s Code of Ethics is available
free upon request to any client or prospective client.

Recommendations Involving Material Financial Interests

Oak Harvest does not recommend that clients buy or sell any security in which a related person to Oak Harvest or
Oak Harvest has a material financial interest.
Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Oak Harvest may buy or sell securities for themselves that they also
recommend to clients. This may provide an opportunity for representatives of Oak Harvest to buy or sell the same
securities before or after recommending the same securities to clients resulting in representatives profiting off the
recommendations they provide to clients. Such transactions may create a conflict of interest. Oak Harvest
employee trading is monitored and reviewed on at least a quarterly basis. We will document any transactions that
could be construed as conflicts of interest and will never engage in trading that operates to the client’s
disadvantage when similar securities are being bought or sold.

Trading Securities At/Around the Same Time as Clients’ Securities

From time to time, representatives of Oak Harvest may buy or sell securities for themselves at or around the same
time as clients. This may provide an opportunity for representatives of Oak Harvest to buy or sell securities before
or after recommending securities to clients resulting in representatives profiting off the recommendations they
provide to clients. Such transactions may create a conflict of interest; however, Oak Harvest will never engage in
trading that operates to the client’s disadvantage if representatives of Oak Harvest buy or sell securities at or
around the same time as clients.

Privacy Policy Statement

We respect the privacy of all clients and prospective clients (collectively termed "customers" per federal
guidelines), both past and present. It is recognized that customers have entrusted our firm with non-public
personal information, and it is important that both access persons and customers are aware of firm policy
concerning what may be done with that information. Federal law gives the customer the right to limit some but
not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your
personal information. The firm provides customers with the privacy policy on an annual basis, and at any time,
in advance, if the privacy policy is expected to change. The firm collects personal information about customers
from the following sources:

• Information provided to us complete their plan or investmentrecommendation;
• Information provided via engagement agreements and other documents completed in connection
with the opening and maintenance of an account;
• Information customers provide verbally; and
• Information received from service providers, such as custodians, about accounttransactions.

Types of Nonpublic Personal Information We Collect:

We collect nonpublic personal information about you that is either provided by you or obtained by us with
your authorization. This can include but is not limited to: your Social Security Number, Date of Birth, Banking
Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or
Information. When you are no longer our customer, OHIS will continue to adhere to this Privacy Policy with
your information.

The firm does not disclose non-public personal information about our customers to anyone, except in the
following circumstances:

• When required to provide services our customers have requested
• When our customers have specifically authorized us to do so;
• When required during the course of a firm assessment (i.e., independent audit); or
• When permitted or required by law (i.e., periodic regulatory examination).
• For marketing by OHIS – to offer OHIS’s products and services to clients;
• For joint marketing with other financial companies;
• For affiliates’ everyday business purposes – information about client transactions and experience; or
• For non-affiliates to market to clients (only where allowed).

If you are a new customer we may begin sharing your information on the day you sign our agreement. If a
client decides to close his or her account(s) or becomes an inactive customer, OHIS will adhere to the privacy
policies and practices as described in this Privacy Policy. However, you can contact us at any time to limit our
sharing.

Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for
non-affiliates’ everyday business purposes – information about your creditworthiness; or sharing with affiliates
or non-affiliates who use your information to market to you. State laws and individual companies may give you
additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of
sharing.

OHIS restricts access to clients’ personal and account information to those employees who need to know that
information to provide products or services to its clients. OHIS maintains physical, electronic, and procedural
safeguards to guard clients’ non-public personal information.

In addition to OHIS’s listed access persons, any IT persons or other technical consultants employed at the firm
may also have access to non-public client information at any time. An on-site or off-site server that stores client
information, third-party software that generates statements or performance reports, or third-party client
portals designed to store client files all hold the potential for a breach of non-public client information.
To mitigate a possible breach of the private information, OHIS uses encryption software on all computersand
evaluates any third-party providers, employees, and consultants with regard to their security protocols, privacy
policies, and/or security and privacy training.

Item 12 - Brokerage Practices

Factors Used to Select Custodians and/or Broker Dealers

Custodians/broker-dealers will be recommended based on our duty to seek “best execution,” which is the
obligation to seek execution of securities transactions for a client on the most favorable terms for the client under
the circumstances.

To address its best execution obligation, Oak Harvest (i) maintains best execution policies and procedures designed
to address our current business; (ii) monitors qualitative factors related to our Custodians, including execution
capability, financial responsibility and responsiveness, the execution performance; and (iii) conducts ongoing due
diligence of the Custodians execution to verify that that prices received were favorable under prevailing market
conditions.

Clients will not necessarily pay the lowest commission or commission equivalent, and Oak Harvest may also
consider the market expertise and research access provided by the broker-dealer/custodian, including but not
limited to access to written research, oral communication with analysts, admittance to research conferences and
other resources provided by the brokers that may aid in Oak Harvest’s research and portfolio management efforts.
Oak Harvest will never charge a premium or commission on transactions, beyond the actual cost imposed by the
broker-dealer/custodian.

Oak Harvest recommends Charles Schwab & Co., Inc., and Fidelity Brokerage Services LLC.

Research and Other Soft Dollar Benefits

While the firm has no formal soft dollars program in which soft dollars are used to pay for third party services, Oak
Harvest receives research, products, or other services from custodians and broker-dealers in connection with client
securities transactions (“soft dollar benefits”). Oak Harvest may enter into soft-dollar arrangements consistent
with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as
amended.

There can be no assurance that any particular client will benefit from soft dollar research, whether or not the
client’s transactions paid for it, and Oak Harvest does not seek to allocate benefits to client accounts proportionate
to any soft dollar credits generated by the accounts. Oak Harvest benefits by not having to produce or pay for the
research, products or services, and Oak Harvest will have an incentive to recommend a broker-dealer based on
receiving research or services. Clients should be aware that Oak Harvest’s acceptance of soft dollar benefits may
result in higher commissions charged to the client.

Brokerage for Client Referrals

Oak Harvest receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or
third party.

Clients Directing Which Broker/Dealer/Custodian to Use

Our firm does not engage in directed brokerage. As a result, they may pay higher commissions or other
transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions
for their account than would otherwise be the case if they had the opportunity to direct brokerage.
Our operational relationship with our custodian requires client accounts custodied with them to have trades
executed per their order routing requirements. We do not direct which executing broker should be selected for
client account trades; whether that is an affiliate of our preferred custodian or another executing broker of a
custodian's choice. As a result, a client may pay higher commissions or other transaction costs, experience
greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In
addition, since we routinely recommend a custodian for our advisory clients, and that custodian may choose to
use the execution services of its broker affiliate for some or all of our client account transactions, there is an
inherent conflict of interest involving our recommendation since our advisory firm receives various products or
services described in this section from that custodian. Note that we are not compensated for trade
routing/order flow, nor are we paid commissions on such trades. We do not receive interest on our client
accounts' cash balances.

Aggregating (Block) Trading for Multiple Client Accounts

Transactions for each client account generally will be affected independently, unless Oak Harvest decides to
purchase or sell the same securities for several clients at approximately the same time. If Oak Harvest buys or sells
the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate
or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower
brokerage commissions, or more efficient execution.

In such case, Oak Harvest would place an aggregate order with the broker on behalf of all such clients in order to
ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that
accounts are not systematically disadvantaged by this policy. Oak Harvest would determine the appropriate
number of shares for each account. Oak Harvest shall not receive any additional compensation or remuneration as
a result of such aggregation.

Item 13 - Review of Accounts

Frequency and Nature of Periodic Reviews and Who Makes Those Reviews

All client accounts for Oak Harvest’s advisory services provided on an ongoing basis are reviewed at least annually
by the advisor with consultation from the firm’s in-house Investment Team as needed. Your advisor will schedule
at least an annual meeting or conference call with you each year. The purpose of these reviews is to evaluate each
clients’ respective investment objectives, risk tolerance levels, and other information and ensure it remains up to
date. If a client does not attend a scheduled meeting, it is the client’s responsibility to reschedule.

Financial planning accounts are reviewed upon financial plan creation and plan delivery by the client’s investment
advisor representative, and by Troy Sharpe, Chief Executive Officer. All financial plans will undergo a total review of
the financial plan at the time of creation and delivery by the firm by the client’s investment advisor representative.
If the client has elected to engage the firm for additional assistance, review, and monitoring of a financial plan, the
investment advisor representative will conduct reviews on the agreed upon basis, which will be notated in the
client’s agreement with the firm, or at least annually.

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).

With respect to financial plans, Oak Harvest’s services will generally conclude upon delivery of the financial plan. If
the client has elected to engage the firm for additional assistance, review, and monitoring of the financial plan, the
investment advisor representative will conduct reviews at the agreed upon basis, and changes in the client’s
financial situation (such as retirement, termination of employment, physical move, or inheritance) may also trigger
a review of the financial plan. For financial consulting clients, Oak Harvest’s services generally conclude upon
completion of the financial consultation.

We contact financial consulting clients and clients with a completed plan but who have not previously engaged the
firm for further review and update of their plan only upon request, to provide additional consulting services,
discuss changes in their situations, and render further updates to their plan. These clients do not receive written or
verbal updates to their completed financial plans, or additional consultations unless they re-engage the firm for
these services, with an updated engagement agreement as needed.

Content and Frequency of Regular Reports Provided to Clients

Each client who receives Oak Harvest’s portfolio management services provided on an ongoing basis will receive a
monthly report detailing the client’s account and all activity in the client’s account, including assets held, asset
value, and fees. This written report will be provided by the custodian. Additionally, Oak Harvest will provide the
client with 1.) a monthly household performance report regarding the client’s investment accounts and 2.) a
performance report regarding the client’s investment accounts at the time of the client’s annual review, or on an
as-needed or as-requested basis.

Each financial planning client will receive the financial plan upon completion; there are no reports beyond the
written financial plan. If the client has engaged the firm for further review and updates to the financial plan, then
updates made based on future reviews will be documented and included in the financial plan. Financial consulting
clients generally do not receive reports or other written deliverables from Oak Harvest.

Trade Errors

In the event of a trade error in a client account, our policy is to attempt to promptly correct the error.
Corrective actions may include: canceling the trade, adjusting the allocation, or reimbursement to the account.
Oak Harvest bears responsibility for all trading losses for which it is found to be responsible. Trading error
gains are either retained by the client or swept to a designated account and donated to a 501(c)(3) charity of
our custodian's choice, and the custodian will be obligated to disclose in their own literature to account
holders whether such recipients' receipt of such donations presents a material conflict of interest.

Item 14 - Client Referrals and Other Compensation

Other than soft dollar benefits discussed in Item 12 above, Oak Harvest does not receive any economic benefit
directly or indirectly from any third party for advice rendered to its clients.

From time to time, Oak Harvest engages or retains unaffiliated third parties to act as solicitors for Oak Harvest’s
advisory services. Oak Harvest currently employs SmartAsset and Qualified Appointment Setting Services (“QASS”)
to screen prospective clients and set appointments for an Oak Harvest consultation. Oak Harvest pays a fee up per
prospective client. This cost is never billed to a client or prospective client. If required, Oak Harvest will ensure
each employed solicitor is properly registered in all appropriate jurisdictions.

Oak Harvest operates a YouTube channel called “Oak Harvest Financial Group.” Firm associates upload educational
videos related to financial topics on this channel. YouTube displays ads on the videos produced by Oak Harvest,
and Oak Harvest receives a share of revenue generated by such ads. All videos uploaded to the channel are for
educational purposes only and are not financial advice, or an offer or solicitation to buy or sell securities.

Oak Harvest provides compensation in the form of gifts, gift baskets, and non-cash prizes to clients in exchange for
referrals provided in order solicit new clients. In addition, Oak Harvest provides compensation to existing clients in
exchange for testimonials. All such compensation adheres to all applicable regulations.

Charles Schwab & Co., Inc. Advisor Services provides Oak Harvest with access to Charles Schwab & Co., Inc. Advisor
Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc.
Advisor Services retail investors. These services generally are available to independent investment advisers on an
unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are
maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services
includes brokerage services that are related to the execution of securities transactions, custody, research,
including that in the form of advice, analyses and reports, and access to mutual funds and other investments that
are otherwise generally available only to institutional investors or would require a significantly higher minimum
initial investment. For Oak Harvest client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor
Services generally does not charge separately for custody services but is compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are executed through
Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts.
Charles Schwab & Co., Inc. Advisor Services also makes available to Oak Harvest other products and services that
benefit Oak Harvest but may not benefit its clients’ accounts. These benefits may include national, regional or Oak
Harvest specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services.
Other potential benefits may include occasional business entertainment of personnel of Oak Harvest by Charles
Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other
of these products and services assist Oak Harvest in managing and administering clients’ accounts. These include
software and other technology (and related technological training) that provide access to client account data (such
as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade
orders for multiple client accounts, if applicable), provide research, pricing information and other market data,
facilitate payment of Oak Harvest’s fees from its clients’ accounts (if applicable), and assist with back-office training
and support functions, recordkeeping and client reporting. Many of these services generally may be used to service
all or some substantial number of Oak Harvest’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes
available to Oak Harvest other services intended to help Oak Harvest manage and further develop its business
enterprise. These services may include professional compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory compliance,
employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab
& Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered
to Oak Harvest by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive
fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing
these services to Oak Harvest. Oak Harvest is independently owned and operated and not affiliated with Charles
Schwab & Co., Inc. Advisor Services.

Other Compensation – Insurance Company

Mr. Sharpe and other firm associates are licensed insurance agents and appointed with various unaffiliated
insurance carriers via our insurance agency Oak Harvest Insurance Services, LLC. Further information with regard
to these other activities may be found in each associate's accompanying Form ADV Part 2B brochure supplement.
To the extent insurance products are offered to advisory clients of Oak Harvest Investment Services, Oak Harvest
Insurance Services will be paid a commission by the insurance company who issues the policy. In addition,
representatives receive benefits from an Insurance Marketing Organization (IMO) such as operation and marketing
support, and invitations to conferences.

These activities create a conflict of interest as there is an incentive to recommend insurance products based on the
compensation received from the insurance company, rather than on the client’s needs. Additionally, the offer and
sale of insurance products by representatives of Oak Harvest Investment Services are not made in the
representatives’ capacity as a fiduciary, and are limited to insurance providers that have agreements to sell with
Oak Harvest Insurance Services.

Oak Harvest Investment Services addresses this conflict of interest by requiring all of its representatives to act in
the best interest of the client at all times, including permitting its representatives who are insurance agents to
recommend insurance products only in the best interests of the client. Oak Harvest representatives will disclose in
advance how they are being compensated and all conflicts of interest involving any advice or service being
provided. At no time will there be tying between business practices and/or services; a condition where a client or
prospective client would be required to accept one product or service which is conditional upon the selection of a
second, distinctive tied product or service.

No client is ever under any obligation to purchase any insurance product. Insurance products recommended by
Oak Harvest representatives may also be available from other providers on more favorable terms, and clients can
purchase insurance products recommended by Oak Harvest through other, non‐affiliated insurance agencies. OHIS
will always act in the best interest of the client.

Item 15 – Custody

When advisory fees are deducted directly from client accounts at client's custodian, Oak Harvest 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.

Custody is also disclosed in Form ADV because Oak Harvest Investment Services has authority to transfer
money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, Oak
Harvest Investment Services will follow the safeguards specified by the SEC rather than undergo an annual
audit.

Item 16 -Investment Discretion

Oak Harvest offers discretionary and non-discretionary investment advisory services to clients. Oak Harvest
will generally request discretionary authority from clients. The Engagement Agreement established with each
client sets forth the discretionary authority for trading. Where investment discretion has been granted, Oak
Harvest 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.

Clients with discretionary accounts will execute a limited power of attorney to evidence discretionary
authority. Clients may, but typically do not, impose restrictions in investing in certain securities or types of
securities in accordance with their values or beliefs.

Item 17 - Voting Client Securities

Oak Harvest 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.

Item 18 - Financial Information

We are required to provide you with certain financial information or disclosures about financial conditions which
would impede our ability to provide the advisory services described herein. Oak Harvest has not been the subject
of a bankruptcy proceeding, nor do we require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance.

In light of the COVID-19 coronavirus and historic decline in market values, Oak Harvest elected to participate in the
CARES Act’s Paycheck Protection Program (“PPP”) to strengthen its balance sheet. Oak Harvest used this loan
predominantly to continue payroll for the firm and may ultimately seek loan forgiveness per the terms of the PPP.
Due to this and other measures taken internally, Oak Harvest has been able to operate and continue serving its
clients.