Lotus Oak Capital Institute

Investment Management

We provide ongoing investment advice, monitoring, and implementation for accounts held at an independent qualified custodian. Portfolio management is generally provided on a discretionary basis, meaning we have authority to buy and sell securities consistent with your objectives and any reasonable restrictions you provide in writing. Non-discretionary management is available by exception.

Financial Planning

We provide comprehensive and modular financial planning covering cash flow and budgeting, retirement planning, education funding, risk management and insurance analysis, estate and legacy planning, tax-awareness, and investment planning. Planning may be delivered as a one-time project or as part of an ongoing relationship.

Retirement Plan Advisory

We provide advisory and consulting services to plan sponsors and fiduciaries of employer-sponsored retirement plans, including non-discretionary fiduciary advice (ERISA Section 3(21)) and/or discretionary investment management (ERISA Section 3(38)), as agreed in writing.

Ongoing Advice and Monitoring

For clients who engage us for continuing services, we offer ongoing advisory relationships that include periodic review meetings, monitoring of your financial plan and accounts, and advice regarding changes in your circumstances, goals, or markets.

Financial Planning

Fixed project fees typically range from $1,500 to $7,500, depending on scope and complexity. Project fees are generally billed in arrears after delivery of the plan or other agreed-upon milestones.

Portfolio Management

Our annual asset-based fee schedule:

Fees are prorated and billed in arrears (typically quarterly) based on account values as of the last business day of the billing period. Fees are negotiable at our discretion. We do not charge performance-based fees.

Fee Credit Arrangements

Clients who engage us for both financial planning and portfolio management may be eligible for a fee credit arrangement, where some or all of the financial planning fee is applied as a credit against future portfolio management fees until the credit is exhausted.

Ongoing Advice Retainer

For clients who engage us for ongoing advice and monitoring outside of or in addition to portfolio management, we typically charge a flat annual retainer, generally ranging from $3,000 to $12,000 per year, depending on complexity and services requested.

Other Fees and Expenses

You will bear certain third-party fees and expenses charged by custodians and product sponsors, such as brokerage/transaction charges, custodial fees, and internal expenses of mutual funds and ETFs. These fees are separate from our advisory fees.

Lower Fees Disclosure

Similar advisory services may be available from other sources at lower fees or on a different fee basis. You are encouraged to consider the total costs and value of the services you receive when selecting an adviser.

Our Clients

We serve individuals and their families, including trusts, business entities, and retirement plans.

We tailor our advisory services to the individual needs of each client. Before providing investment advice or preparing a financial plan, we gather information about your overall financial situation, goals, investment objectives, risk tolerance, time horizon, liquidity needs, tax circumstances, and any other relevant considerations.

No Formal Minimum

We do not have a formal account minimum. We may impose or waive minimums at our discretion based on the service model.

Independence

Lotus Oak Capital Institute is an independently owned, fee-based investment adviser. We are not a broker-dealer. We do not receive commissions from the sale of securities or investment products in connection with the advisory services we provide.

Our Approach

Lotus Oak Capital Institute employs fundamental analysis as our primary method of evaluating investment opportunities. We review financial statements, competitive positioning, valuation metrics, and macroeconomic conditions to assess each investment on its merits.

Our sources of information include financial publications, SEC filings, independent rating services, and third-party research providers.

Investment Strategies

We build portfolios using a structured approach aligned to each client’s objectives and risk tolerance:

Core Strategies available to all clients include exchange-traded funds (ETFs), mutual funds, U.S. Treasury and government agency securities, and cash equivalents. These form the foundation of most client portfolios.

Individual Securities — for clients with sufficient assets and appropriate objectives, we may recommend individual equities (domestic and international) and individual bonds, including government, municipal, and investment-grade corporate bonds.

Options Strategies — for qualified clients who acknowledge the risks of options, we may employ covered call writing for income, protective puts for downside hedging, and cash-secured puts for tactical entry. We do not engage in speculative options trading, uncovered option writing, or strategies with unlimited loss potential.

Private Securities — for accredited investors where suitable under SEC Regulation D, we may recommend private equity, private real estate, hedge funds, or other securities not registered under the Securities Act of 1933.

Currency and Commodity Exposure — international holdings may carry currency risk; we may use currency-hedged ETFs to manage this exposure. Commodity exposure is indirect, through commodity-related equities or focused ETFs. We do not currently use futures contracts as a primary strategy.

Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear.

All investments carry risk, including the potential loss of principal. Material risks associated with the strategies and instruments described above include:

• Market risk — the value of investments may decline due to broad market movements
• Interest-rate risk — changes in interest rates affect bond prices and fixed-income returns
• Credit risk — issuers of debt securities may default on interest or principal payments
• Inflation risk — rising costs may erode purchasing power of investment returns
• Liquidity risk — some investments may be difficult to sell quickly at a fair price
• Concentration risk — portfolios concentrated in fewer holdings or sectors may experience greater volatility
• Options risk — options strategies involve unique risks including time decay and the potential for loss of the entire premium paid
• Private securities risk — private investments may be illiquid, difficult to value, subject to leverage, and may involve lock-up periods and higher fees
• Currency risk — international investments are subject to fluctuations in foreign exchange rates
• Model risk — quantitative models used in analysis may contain errors or may not perform as expected
• Cybersecurity and operational risk — technology failures or security breaches may disrupt operations and affect asset values

Past results do not indicate future performance. There is no assurance that any investment strategy will achieve its objectives.

For complete disclosure of our methods, strategies, and risks, please refer to our Form ADV Part 2A, filed with the California Department of Financial Protection and Innovation.

The oak stands firm, while the lotus blooms—swiftly fades.

Endurance and ephemerality, a dance of strength and grace.

Neither wholly masculine nor feminine, their virtues transcend boundaries.

Rooted in the wisdom of ages, East and West, ancient and modern—echoing the eternal Tao.

This is the foundation of Lotus Oak: complementary opposites in harmony. We do not chase returns through speed. We seek wealth through stillness, discipline through time, value through patience.

The oak does not announce its strength. The lotus does not mourn its passing. Together, they teach us: endure what must be endured, release what must be released.

This is not passive investing. This is intentional balance.

A tree does not grow faster when watched. A portfolio does not compound faster when checked. The greatest returns come to those who plant seeds and step away.

Ten years feels long to the anxious. Ten years feels short to the patient. Both experience the same decade.

The market rewards those who can endure its noise. Every day brings headlines designed to inspire action. The wise investor recognizes that most action destroys value. Stillness is a strategy. Patience is an edge.

Consider the oak: it grows slowly, but it grows strong. It bends with the wind but does not break. After a hundred years, it provides shelter to generations. This is the way of the long-term investor.

Compounding is the eighth wonder not because it is complex, but because it is simple. A small thing, repeated with consistency, becomes an extraordinary thing. This is the nature of exponential growth.

One percent, daily, for a year: not twelve percent, but thirty-seven times. Such is the mathematics of patience.

The investor who understands compounding does not seek large returns. They seek consistent returns. They know that interruption is the enemy, that transaction is friction, that activity is cost.

Time is the multiplier. Every day the portfolio exists is a day of compounding. Every day of trading is a day of interruption. The wise investor protects their time in market above all else.

The greatest fortunes are built slowly. The greatest fortunes are lost quickly. Speed serves the latter, never the former.

Discovery

We begin by understanding your complete financial picture: goals, values, risk tolerance, time horizon, and any unique circumstances. This conversation is the foundation of everything we build together.

Plan

Based on what we learn, we develop a comprehensive strategy tailored to your situation. For financial planning clients, this results in a written plan with specific recommendations. For portfolio management clients, this shapes your investment policy and asset allocation.

Implement

We put the plan into action. For managed accounts, we handle the portfolio construction and ongoing trading. For financial planning, we provide the roadmap and can coordinate with your other professionals to execute recommendations.

Review

Financial planning is not a one-time event. We conduct periodic reviews to ensure your strategy remains aligned with your evolving goals, life changes, and market conditions. Adjustments are made thoughtfully and with your full understanding.

What does it mean that you are a fiduciary?

As a registered investment adviser, we are legally obligated to act in your best interest, provide full disclosure of all material facts, and avoid or disclose any conflicts of interest.

How are your fees structured?

We charge an asset-based advisory fee, billed quarterly in arrears. See our Fees and Compensation page for details. We do not receive commissions — our only compensation comes from advisory fees paid by clients.

What are the minimum requirements to become a client?

We have no formal account minimum. We work with individuals, families, trusts, and retirement plans, and may adjust minimums based on the advisory relationship. See Who We Serve.

Who holds my money?

Your assets are held by an independent qualified custodian, not by us. We never take possession of client funds or securities. You receive statements directly from your custodian.

How do I get started?

Begin with a discovery conversation about your goals and financial situation. See Our Process or Contact to schedule an introductory call.

Regulatory Documents

Lotus Oak Capital Institute is a registered investment adviser with the California Department of Financial Protection and Innovation.

• Form ADV Part 2A (Firm Brochure) — Our firm brochure describes our services, fees, conflicts of interest, and other important information.
• Form ADV Part 2B (Brochure Supplement) — Provides information about the qualifications and business practices of our advisory personnel.

You may also obtain our most current Form ADV from the SEC’s Investment Adviser Public Disclosure website.

Important Information

This website is for informational purposes only and does not constitute personalized investment advice. Investing involves risk, including the possible loss of principal. Past performance is not indicative of future results. Our privacy practices comply with Regulation S-P.

Business Continuity

We maintain a business continuity plan to address events that could significantly disrupt our operations. In the event of a significant business disruption, we will make every effort to contact you and resume normal business operations as quickly as possible.

Effective Date: February 2026 | Annual Review: February 2027

Lotus Oak Capital Institute (“L0CI,” “we,” “us”) is a registered investment adviser with the California Department of Financial Protection and Innovation (CRD #339053). This privacy policy describes how we collect, use, and protect personal information from both advisory clients and website visitors.

Scope: Client Data vs. Website Visitor Data

This policy addresses two distinct categories of personal information:

• Client financial data is governed by the Gramm-Leach-Bliley Act (GLBA) and Regulation S-P (17 CFR Part 248). As a state-registered investment adviser, L0CI is subject to California’s implementation of these federal privacy requirements.
• Website visitor data is governed by the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA, Cal. Civ. Code §1798.100 et seq.) and the California Financial Information Privacy Act (FIPA, Cal. Fin. Code §4050-4060).

Information We Collect

We may collect: identity information (name, address, email, phone, date of birth), financial information (income, net worth, investment objectives, risk tolerance, account numbers), website usage data (pages visited, browser type, IP address), and communication records related to advisory services.

How We Collect Information

• Directly from you: When you engage us for advisory services, submit inquiries, or communicate with us
• From third parties: Custodians, broker-dealers, or other financial institutions involved in your accounts
• Automatically: Through standard web server logs when you visit our website
• Through authorized third-party data aggregators: With your explicit consent, we use Plaid to obtain read-only access to your financial accounts (see “Third-Party Data Aggregation” below)

Third-Party Data Aggregation

Authorized Aggregator

L0CI engages Plaid Inc. (“Plaid”) as our authorized third-party data aggregator. With your explicit consent through Plaid’s connection flow, Plaid provides L0CI with read-only access to your bank, credit card, brokerage, and lending account data so that we can deliver investment-advisory services. Plaid is the only aggregator authorized at the time of this notice.

L0CI does not engage in screen-scraping. All data aggregation is performed via Plaid’s API integrations, including OAuth-based connections to participating financial institutions.

Scope of Data Accessed

With your explicit consent through the Plaid Link flow, L0CI may access:

• Transactions — historical and ongoing account transaction history
• Account verification (Auth) — account and routing numbers, only when needed for funding workflows you specifically request
• Balance — current account balances
• Investments — investment-account holdings, transactions, and securities metadata
• Liabilities — student-loan, mortgage, and credit-card liability detail

You control which financial institutions and accounts are connected through the Plaid Link consent screen. You may decline any institution and may revoke any specific connection at any time.

Purpose Limitation

Plaid-aggregated data is used solely to provide investment-advisory services to you, including financial planning, cash-flow analysis, portfolio reconciliation, fee billing, and performance reporting.

L0CI commits in writing that we:

• Do not sell, lease, license, or otherwise monetize Plaid-aggregated data to any third party
• Do not use Plaid-aggregated data for credit decisioning, employment decisioning, insurance underwriting, or any “Furnisher” activity governed by the Fair Credit Reporting Act (FCRA)
• Do not use Plaid-aggregated data for marketing or for cross-promotion of non-advisory services
• Do not disclose Plaid-aggregated data to affiliates for non-advisory marketing purposes

These commitments are enforced contractually through our Plaid Master Services Agreement.

Data Retention for Plaid-Aggregated Data

• Operational data (transaction records, balances, holdings) — retained while your advisory relationship with L0CI is active and for 7 years thereafter, in compliance with California’s records-retention requirement for state-registered investment advisers (10 CCR 260.241.3)
• Audit and access-log data — retained 7 years per the same regulatory floor
• Plaid access credentials — encrypted at rest using AES-256-GCM with a domain-separated encryption key; revoked and zeroed when you disconnect an institution or terminate the advisory relationship

When you terminate the advisory relationship, your Plaid access tokens are revoked and zeroed. Operational and audit data are retained for the 7-year regulatory window unless your deletion request applies (see “Your Privacy Rights” in our Privacy Rights page).

Data Flow Summary

When you connect a financial account via Plaid Link:

1. Your bank or financial institution authenticates you (typically via OAuth at the bank’s own login page)
2. Plaid receives your authorization to share account data with L0CI
3. Plaid relays the authorized data to L0CI over an encrypted (TLS 1.3) connection, with cryptographically signed webhooks for ongoing updates
4. L0CI stores the data in our advisory platform and uses it solely for the purposes listed above

Your Plaid Connection Rights

You may at any time:

• Revoke a Plaid connection — via the Plaid Portal at https://my.plaid.com/ OR by written request to the CCO
• View what we have — request a copy of the Plaid-aggregated data L0CI holds about you (we respond within 45 days per CCPA §1798.110)
• Request deletion — subject to records-retention obligations under 10 CCR 260.241.3, which may require retention of audit and access-log data for the 7-year regulatory window; in such cases the data is restricted from any further use
• Correct your data — corrections of bank-side data must be raised with the originating institution; L0CI will correct any L0CI-generated derivative data upon written request

Requests should be sent to the Chief Compliance Officer at the contact channel published in our Form ADV Part 2A.

Compliance Framework

L0CI’s Plaid integration complies with:

• 17 CFR Part 248 (Regulation S-P) — Safeguards Rule; initial and annual privacy notice
• California Consumer Privacy Act (CCPA / CPRA) — Cal. Civ. Code §1798.100 et seq.
• California Financial Information Privacy Act (FIPA) — Cal. Fin. Code §4050-4060
• Dodd-Frank §1033 (CFPB Open Banking Rule) — consumer financial data access
• California IA records retention rule — 10 CCR 260.241.3 (7-year retention)
• Plaid Master Services Agreement — including its breach-notification, FCRA-non-applicability, and screen-scraping-prohibition obligations

How We Communicate With You

L0CI communicates with clients through secure, supervised channels that we can retain in compliance with our recordkeeping obligations: firm email (@lotusoak.capital), our encrypted document portal, telephone, scheduled video conference, and postal mail where required.

We do not communicate with clients via SMS or text message. L0CI does not initiate, solicit, or conduct advisory communications over SMS or consumer text-messaging applications. Please use the channels above — or contact the Chief Compliance Officer — for any advisory communication. This protects the security and confidentiality of your information and ensures your communications with us are properly retained.

Financial Information Privacy Act (FIPA)

Under the California Financial Information Privacy Act (Cal. Fin. Code §4050-4060), we will not share your nonpublic personal financial information with nonaffiliated third parties unless:

1. We provide you with a clear and conspicuous notice describing the proposed sharing
2. You provide opt-in consent through an affirmative action authorizing the sharing
3. You are given a reasonable opportunity to withdraw consent before sharing occurs

Your FIPA rights: You have the right to control whether and how your financial information is shared with nonaffiliated third parties. We will never share your financial information without your prior affirmative consent.

CCPA/CPRA Consumer Rights

If you are a California resident, you have the following rights under the CCPA/CPRA:

• Right to know: Request disclosure of the categories and specific pieces of personal information we have collected, its sources, business purposes, and third-party recipients.
• Right to delete: Request deletion of personal information, subject to certain exceptions including regulatory retention requirements.
• Right to correct: Request correction of inaccurate personal information.
• Right to opt-out: Opt out of the sale or sharing of your personal information. L0CI does not sell personal information.
• Right to non-discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise these rights, contact us at the address below. We will respond to verifiable consumer requests within 45 days.

Note: Certain personal information is exempt from CCPA/CPRA deletion requests when subject to regulatory retention requirements. For example, advisory agreement records must be retained for 7 years per California Code of Regulations Title 10, Section 260.241.3.

Information Sharing Practices

We do not sell your personal information. We may share information only with service providers contractually required to protect it, regulatory authorities when required by law, and with your affirmative consent.

We require all service providers to maintain confidentiality and implement appropriate security measures.

Security of Your Information

We implement administrative, technical, and physical safeguards to protect your personal information, including encryption at rest (AES-256) and in transit (TLS 1.3), multi-factor authentication, least-privilege access controls with quarterly reviews, and continuous monitoring.

Data Retention

We retain personal information per applicable regulatory requirements. Most client records are retained for 7 years per 10 CCR §260.241.3. Website usage data is retained for 1 year minimum.

Contact Us

To exercise your privacy rights, ask questions about this policy, or file a complaint:

Lotus Oak Capital Institute Attention: Chief Compliance Officer Email: [email protected]

We will acknowledge your request within 10 business days and provide a substantive response within 45 days.

This policy is reviewed annually and updated as regulatory requirements change.

Version: 1.0 | Last Reviewed: 2026-03-03

DRAFT — NOT YET EFFECTIVE | Requires legal counsel review before publication.

Version: 0.1-DRAFT | Created: 2026-03-03

Lotus Oak Capital Institute (“L0CI,” “we,” “us”) is a registered investment adviser with the California Department of Financial Protection and Innovation (CRD #339053). These Terms of Service govern your use of our website and the Fact Finder application.

1. Acceptance of Terms

By accessing or using our services, you agree to be bound by these Terms of Service. If you do not agree, you may not access or use our services.

2. Description of Services

L0CI provides investment advisory services and related technology tools, including:

• Fact Finder: A financial data collection application used to gather information necessary for investment advisory services
• Website: Information about L0CI’s advisory services, disclosures, and compliance documentation

3. User Obligations

When using our services, you agree to:

• Provide accurate and complete information
• Maintain the confidentiality of any account credentials
• Notify us immediately of any unauthorized access to your account
• Use our services only for lawful purposes and in accordance with these Terms
• Not attempt to gain unauthorized access to our systems or data

4. Investment Advisory Relationship

Use of the Fact Finder or website does not establish an investment advisory relationship. An advisory relationship is established only through execution of a written advisory agreement.

5. Intellectual Property

All content, features, and functionality of our services are owned by L0CI and are protected by applicable intellectual property laws. You may not reproduce, distribute, or create derivative works without our prior written consent.

6. Privacy

Your use of our services is also governed by our Privacy Policy. Please review it to understand our data collection and use practices.

7. Disclaimer of Warranties

Our services are provided “as is” and “as available” without warranties of any kind, either express or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, and non-infringement.

8. Limitation of Liability

To the maximum extent permitted by law, L0CI shall not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to your use of our services.

9. Indemnification

You agree to indemnify and hold harmless L0CI, its officers, directors, employees, and agents from any claims, damages, losses, liabilities, and expenses arising out of your use of our services or violation of these Terms.

10. Governing Law

These Terms are governed by the laws of the State of California, without regard to its conflict of law provisions. Any disputes shall be resolved in the state or federal courts located in California.

11. Dispute Resolution

Any dispute arising from these Terms or your use of our services shall first be attempted to be resolved through good-faith negotiation. If negotiation fails, disputes shall be resolved through binding arbitration in accordance with the rules of the American Arbitration Association, conducted in California.

12. Termination

We may terminate or suspend your access to our services at any time, with or without cause, and with or without notice. Upon termination, your right to use our services ceases immediately.

13. Changes to Terms

We reserve the right to modify these Terms at any time. Material changes will be communicated via the website or direct notification. Continued use of our services after changes constitutes acceptance of the modified Terms.

14. Severability

If any provision of these Terms is held to be unenforceable, the remaining provisions shall remain in full force and effect.

15. Contact

For questions about these Terms of Service:

Lotus Oak Capital Institute Attention: Chief Compliance Officer Email: [email protected]

DRAFT v0.1 — This document requires review by legal counsel before publication. Created 2026-03-03 as part of compliance audit #1437.

DRAFT — NOT YET EFFECTIVE | Requires legal counsel review before publication.

Version: 0.1-DRAFT | Created: 2026-03-03

Lotus Oak Capital Institute (“L0CI,” “we,” “us”) is a registered investment adviser with the California Department of Financial Protection and Innovation (CRD #339053). This Cookie Policy explains how we use cookies and similar technologies on our website and applications.

What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work efficiently and to provide information to website operators.

Cookies We Use

Essential Cookies

These cookies are necessary for the website and Fact Finder application to function. They cannot be disabled.

Analytics Cookies

We currently do not use analytics cookies or third-party tracking. If we add analytics in the future, this policy will be updated and consent will be requested before any analytics cookies are set.

Third-Party Cookies

We do not use third-party cookies. Our website does not embed social media widgets, advertising pixels, or other third-party tracking technologies.

Your Cookie Choices

Browser Settings

Most web browsers allow you to control cookies through their settings. You can:

• Block all cookies
• Delete existing cookies
• Allow cookies from specific sites only
• Set your browser to notify you when a cookie is set

Note: Blocking essential cookies may prevent the Fact Finder application from functioning properly.

California Residents (CCPA/CPRA)

Under the California Consumer Privacy Act, you have the right to know what personal information is collected through cookies and to request its deletion. Since we only use essential cookies and do not use cookies for advertising or cross-site tracking, there is no “sale” or “sharing” of personal information through cookies to opt out of.

European Residents (GDPR)

If we determine that EU residents are using our services, we will implement a cookie consent mechanism that:

• Obtains explicit consent before setting any non-essential cookies
• Allows you to withdraw consent at any time
• Does not condition service access on cookie consent for non-essential cookies

Consent Banner

A cookie consent banner will be displayed on first visit, allowing you to:

• Accept all: Enable all cookie categories
• Essential only: Use only cookies required for site functionality
• Manage preferences: Choose individual cookie categories

Note: The consent banner component requires implementation in the Phoenix/LiveView frontend (separate engineering task).

Changes to This Policy

We will update this Cookie Policy when our cookie practices change. Material changes will be communicated via the website.

Contact

For questions about our cookie practices:

Lotus Oak Capital Institute Attention: Chief Compliance Officer Email: [email protected]

DRAFT v0.1 — This document requires review by legal counsel before publication. The consent banner LiveView component is a separate implementation task. Created 2026-03-03 as part of compliance audit #1437.