We are a New York limited liability company, established in January 2013 that provides investment advisory services on a discretionary basis to clients, through either separately managed accounts or commingled investment vehicles intended for institutional and other sophisticated investors. Investment advisory services are offered for a percentage of assets under management as well as other compensation structures, as described in more detail below.

One Oak Capital Management LLC is owned primarily by Stephen DiTursi and Victor Perretti. One Oak specializes in investment grade bond portfolio management. The PM’s, in their various positions, were responsible for managing the proprietary investment grade and non-investment grade fixed income and the associated risks at their respective firms.

As an investment adviser, we are responsible for sourcing potential investments, conducting research and due diligence on potential investments, analyzing investment opportunities, structuring investments, and monitoring investments on behalf of our managed funds and accounts. We generate all of our advisory billings from investment advisory services. We provide investment advice to our clients regarding fixed income securities and is delivered on either a separately managed basis or as a limited partner to one or more managed private funds.

In addition to providing personalized investment advice to clients on a separately managed basis, we are also the investment manager of the One Oak Alpha Opportunities Fund, LP, a New York limited partnership, and the One Oak Alpha Opportunities Offshore Fund Ltd., a Cayman Islands exempted company. The One Oak Alpha Opportunities Fund, LP offers Interests in multiple separate series (each, a Series), as further set forth herein. The Fund is currently offering Interests in the following series: (1) Municipal Opportunities Portfolio; (2) the High-Income Municipal Opportunities Portfolio; and (3) the Mid Atlantic Total Return Portfolio. Each will utilize different investment strategies and invest in a different portfolio of assets, as described below. The One Oak Alpha Opportunities Offshore Fund Ltd. however, is a feeder fund that invests all of its assets into the Municipal Opportunities Portfolio through a master-feeder fund structure.
Municipal Opportunities Portfolio
The investments for Municipal Opportunities Portfolio primarily focus on short-term investing in long investment grade municipal and corporate bonds in concert with the shorting or hedging of the long portfolio with transactions to mitigate the interest rate and municipal credit risk. On average, these positions will target 2X leverage. The driving force behind the hedging strategy is to mitigate interest rate and municipal credit risk, while creating a combined return source that is independent of the direction of bond prices. Returns are derived from the profits or losses emanating from the short-term opportunities on the municipal bonds relative to the hedging transactions. The Investment Manager may also invest the Portfolio in other investment grade securities, such as corporate debt securities, mortgage-backed securities, asset-backed securities, securities issued by the U.S. government or its agencies and instrumentalities, securities issued by non-U.S. governments or their agencies and instrumentalities, money market securities and other interest-bearing instruments. The Investment Manager plans to invest the Portfolio in investment-grade fixed income securities of any maturity.
High Income Municipal Opportunities Portfolio
The investments for High Income Municipal Opportunities Portfolio employ a highly diversified portfolio that mitigates the risks of individual credits by focusing on non-investment grade municipals. The Fund manages: (a) credit risk through extensive and continuous research of core positions in the portfolio, and (b) interest rate risks by using a portfolio of US Treasuries, ETFs, and/or options as conditions dictate.

To enhance returns, the strategy may employ leverage on the investment grade municipal bond portion of each portfolios. We have extensive contacts in the regional dealer community that help One Oak seek to exploit opportunities in securities pricings that surface among participants in this marketplace while at the same time mitigating the portfolio’s overall interest rate exposure.
Mid Atlantic Total Return Portfolio
The Portfolio will primarily focus on taking advantage of relative value opportunities with short-term holding periods in both investment grade and non-investment grade long and short fixed income securities, including, but not limited to corporate bonds, emerging markets, asset-backed securities and mortgage-backed securities. The Investment Manager may also invest in municipal bonds, securities issued by the U.S. government and/or its agencies and instrumentalities, non-U.S. governments and/or their agencies and instrumentalities, money market securities and other interest- bearing instruments. Additionally, a portion of the Portfolio will also be involved in the short-term investing of initial public offerings (New Issues), preferred stock, secondary equity transactions, convertible securities, ETFs, warrants, options and futures. This portion will be actively managed in concert with the shorting or hedging of the long portfolio with a tailored hedging strategy.
One Oak Alpha Opportunities Offshore Fund Ltd. (“Feeder Fund”)
One Oak Alpha Opportunities Offshore Fund Ltd., a Cayman Islands exempted company, was formed to pool investment funds of its shareholders for the purpose of investing and trading in a wide variety of securities, financial instruments and other assets and investments, as more fully described herein. The Fund will invest all of its assets in the Municipal Opportunities Portfolio, a portfolio within the One Oak Alpha Opportunities Fund, LP, a Delaware series limited partnership (“Master Fund”), through a “master-feeder” fund structure. Any related management and/or performance fees are calculated at the Master Fund level.

General Partner to Private Funds
One Oak Capital Advisory Group I, LLC, a New York limited liability company is the General Partner to the Private Funds. As the managing members and controlling persons of the General Partner and One Oak Capital Management (the “adviser”), Stephen DiTursi and Victor Perretti, Jr. control all of the operations and activities of the Private Funds and the adviser.
Availability of Customized Services for Individual
We tailor our advisory services to the individual needs of each of our Funds and/or clients.
Wrap Fee Programs
We do not participate in a wrap fee program.
Assets Under Management
As of November 2019, we had a total of $229 million in regulatory assets under management on a discretionary basis and no client assets under management on a non-discretionary basis. please register to get more info

Advisory and Other Services and Fees
Private Funds In consideration for services provided pursuant to the Investment Management Agreement, the Investment Manager will receive a monthly management fee (“Management Fee”), with respect to each Series, equal to: 1.0% annually for: (a) Municipal Opportunities Portfolio, and (b) 1.2% annually for: High Income Municipal Opportunities Portfolio. The Management Fee will be calculated and payable to the Investment Manager monthly, in advance, as of the first day of each month. A pro rata Management Fee will be charged to Limited Partners on any amounts accepted by the General Partner during a month. The Mid Atlantic Total Return Portfolio does not charge a management fee.

Separately Managed Accounts – In consideration for services provided pursuant to the Investment Management Agreement, the Investment Manager will receive a monthly management fee (“Management Fee”), with respect to each client that ranges between 1.0% - 1.40% annually.

Our fees are exclusive of brokerage commissions, custody fees, fund expenses, transaction fees, and other related costs and expenses, which may be incurred by our clients. Clients may incur certain charges imposed by custodians, brokers, and other third parties, including fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. These charges, fees, and commissions are exclusive of and in addition to our management fees. We shall not receive any portion of these commissions, fees, and costs and shall not receive a brokerage commission or other compensation attributable to the sale of a security or other investment product.
Prepayment of Fees
In cases when the advisory agreement does not span the full billing period, fees are prorated from the date of inception. Fees are not rebated if an account is terminated prior to the end of the billing period. The Advisor or Client may terminate the investment advisory agreement at any time with written notice to the advisor.
Additional Compensation and Conflicts of Interest
We do not receive a brokerage commission or any other compensation attributable to the sale of securities or investment products and our personnel do not receive such compensation. please register to get more info

Municipal Opportunities Portfolio
In consideration for services provided pursuant to the Partnership Agreement, the General Partner will receive a performance allocation (“Performance Allocation”), with respect to each Series, at the close of each calendar quarter (or other period referred to below, as the case may be) equal to 20% of the Partnership’s net income (including realized and unrealized gains and losses and net of the management Fee) attributable to each Limited Partner’s capital account in such Series for such calendar quarter (or other period). The Performance Allocation will be subject to a Loss Carryforward (sometimes referred to as a “high water mark”). The Performance Allocation is subject to what is commonly known as a “high water mark” provision. That is, if a Limited Partner’s capital account has a net loss in any calendar quarter (or other period, as applicable), this loss will be recorded and carried forward as to such capital account to future calendar quarters (or other periods) (such amount is referred to as the “Loss Carryforward”). The General Partner will not receive the Performance Allocation with respect to a Limited Partner’s capital account in any future calendar quarter (or other period) until the Loss Carryforward amount for such capital account has been recovered (i.e., when the Loss Carryforward amount has been exceeded by the cumulative profits allocable to such capital account for the calendar quarters (or other periods) following the Loss Carryforward). Once the Loss Carryforward has been recovered, the Performance Allocation will be based on the excess profits (over the Loss Carryforward amount) as to such capital account, rather than on all profits. When a Limited Partner withdraws capital, any Loss Carryforward will be adjusted downward in proportion to the withdrawal. The General Partner may agree with any Limited Partner to apply a different Loss Carryforward provision for such Limited Partner.

Performance based fee arrangements may create an incentive for us to recommend investments that may be riskier or more speculative than those that we may recommended under a different fee arrangement. In the allocation of investment opportunities, performance-based fee arrangements may also create (i) an incentive for us to favor accounts with performance or incentive fee arrangements over accounts that are not charged, or from which we will not receive, a performance fee; and (ii) an incentive for us to favor accounts from which we will receive a greater performance fee over accounts from which we will receive a lesser performance fee. We have adopted Order Aggregation and Allocation Procedures (the “Allocation Procedures”) designed to ensure that all of our clients are treated fairly and equally and to prevent this form of conflict from influencing the allocation of investment opportunities among our clients. We will offer clients the right to participate in all investment opportunities that we determine are appropriate for the client in view of relative amounts of capital available for new investments, the investment programs, and the portfolios of our clients. In accordance with our Allocation Procedures, we will endeavor to treat each of our clients in a fair and equitable manner. In addition, certain of our clients may provide investment guidelines that prohibit us from making highly speculative investments or using leverage. These prohibitions limit the concern that we may recommend certain investments in order to enhance our performance fees. High Income Municipal Opportunities Portfolio does not charge a performance fee. Mid Atlantic Total Return Portfolio does not charge a management fee, but is subject to a monthly performance fee of 60%. Separately Managed Account clients that meet the regulatory definition of “Qualified Clients”, may be charged a performance-based fee ranging from 0% - 30% above pre-defined benchmarks that are then deducted on a quarterly basis. The formula is based on the quarterly P&L for each individual account based on the last day of each quarter, subject to attaining the previous high-water mark. Such fees are subject to individualized negotiation with each such client. In measuring clients' assets for the calculation of performance-based fees, One Oak shall include realized and unrealized capital gains and losses. Performance based fee arrangements may create an incentive for One Oak to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. One Oak has procedures designed and implemented to ensure that all clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among clients. please register to get more info

At present, we provide investment advisory services to private funds, as well as advice on a separately managed account basis to individuals, high net worth individuals, trusts, estates, endowments, charitable organizations, corporations, limited liability companies, other business entities and other investment advisors.

The minimum account size necessary to invest in our portfolio will vary by the type of Investor. For instance, Investors in the One Oak Alpha Opportunities Fund must make a minimum initial investment of at least $500,000 million and any additional investments must be in increments of $100,000. From time to time initial investments less than $500,000 million and additional investments less than $100,000 may be accepted, and these thresholds may be increased or decreased. The General Partner has the discretion to negotiate a lower the minimum investment size. please register to get more info

Security analysis methods may include economic, fundamental, technical and cyclical analysis. The main sources of information may include the research provided via Bloomberg and any other research department they may offer access to, research materials prepared by others, corporate rating services, annual reports, prospectuses, press releases, filings with the SEC, financial newspapers and magazines, and the Internet.
Risk of Loss
Investing in securities involves risk of loss that our clients (and underlying investors) should be prepared to bear. There can be no assurance that the Funds will achieve its investment objective. Assessment of the prospects of investments may not prove accurate. No assurance can be given that any investment or trading strategy implemented by the Advisor on behalf of the Funds will be successful and, because of the speculative nature of the Fund’s investment and trading strategy, investors may suffer a significant loss of their invested capital, including loss of the entire investment In addition, we believe that clients and their underlying investors should be aware of the risk factors delineated below. These risk factors are not a complete explanation of all the risks to clients and underlying investors from investing with us. Clients should read this brochure, any investment advisory agreement, any organizational or offering documents, and the documents and materials referred to in this brochure before determining to invest with us.
Risk Factors
Note: All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Although One Oak advises assets in a manner consistent with risk tolerances, there can be no guarantee that our efforts will be successful. The investor should be prepared to bear the risk of loss.
Market Risks
Competition. The securities industry and the varied strategies and techniques to be engaged in by the Adviser are extremely competitive and each involves a degree of risk. The Adviser will compete with firms, including many of the larger securities and investment banking firms, which have substantially greater financial resources and research staffs.

Market Volatility. The profitability of the Adviser substantially depends upon it correctly assessing the future price movements of stocks, bonds, options on stocks, and other securities and the movements of interest rates. The Adviser cannot guarantee that it will be successful in accurately predicting price and interest rate movements.

Adviser’s Investment Activities. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Adviser to realize profits.

Material Non-Public Information. By reason of their responsibilities in connection with other activities of the Adviser and/or its affiliates, certain principals or employees of the Adviser and/or its affiliates may acquire confidential or material non-public information or be restricted from initiating transactions in certain securities. The Adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may not be able to initiate a transaction that it otherwise might have initiated and may not be able to sell an investment that it otherwise might have sold.

Accuracy of Public Information. The Adviser selects investments, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Adviser by the issuers or through sources other than the issuers. Although the Adviser evaluates all such information and data and sometimes seeks independent corroboration when it’s considered appropriate and reasonably available, the Adviser is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. Investments in Undervalued Securities. The Adviser intends to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Adviser’s investments may not adequately compensate for the business and financial risks assumed.
Investment Risks
One Oak invests substantially all of their available capital (other than capital the General Partner retains in cash or cash equivalents) principally in fixed income securities. Markets for such instruments fluctuate and the market value of any particular investment may vary substantially. The Fund’s portfolio may not generate any income or appreciate in value.

Portfolio Turnover. The portfolios may require active trading of the portfolio, and as a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size.

Lack of Diversification. The portfolios may not be widely diversified among sectors, industries, geographic areas or types of securities. Further, portfolios may not necessarily be diversified among a wide range of issuers. Accordingly, the portfolios may be subject to more rapid change in value than would be the case if the Investment Vehicles were required to maintain a wide diversification among companies or industry groups.

Short-Sales. One Oak may sell securities short. Short sales can, in certain circumstances, substantially increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase.

Derivative Instruments. One Oak may invest, from time to time, derivative instruments, including, fixed income swap agreements. The values swap agreements depend primarily upon the price of the securities, indexes, commodities, currencies or other instruments underlying them. Payments pursuant to swap agreements are also influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies.

Hedging Transactions. Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds & portfolios to hedge against fluctuations in the relative values of its portfolio positions as a result of changes in currency exchange rates, interest rates and/or the equity markets or sectors thereof. Any hedging against a decline in the value of portfolio positions does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the portfolio positions’ value. Such hedging transactions also limit the opportunity for gain if the value of the portfolio positions should increase. The Adviser is not obligated to establish hedges for portfolio positions and may not do so. Leverage. One Oak will use leverage by engaging in short sales, entering into swaps and other derivatives contracts and other leveraging strategies. Such leverage increases the risk of loss and volatility. In addition, the use of leverage requires the pledging of assets as collateral. Margin calls or changes in margin requirements can cause the portfolios to be required to pledge additional collateral or liquidate the portfolio’s holdings, which could require the portfolio to sell securities at substantial losses that would not otherwise be realized. Market or Interest Rate Risk. The price of most fixed income securities move in the opposite direction of the change in interest rates. For example, as interest rates rise, the price of fixed income securities falls. If the Adviser holds a fixed income security to maturity, the change in its price before maturity may have little impact on the Adviser’s performance; however, if the Adviser has to sell the fixed income security before the maturity date, an increase in interest rates could result in a loss to the Adviser.

Fixed Income Call Option Risk. Many bonds, including agency, corporate and municipal bonds, and all mortgage-backed securities, contain a provision that allows the issuer to “call” all or part of the issue before the bond’s maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are three disadvantages to the call provision. First, the cash flow pattern of a callable bond is not known with certainty. Second, because the issuer will call the bonds when interest rates have dropped, the Adviser is exposed to reinvestment rate risk – the Adviser will have to reinvest the proceeds received when the bond is called at lower interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond.

Inflation Risk. Inflation risk results from the variation in the value of cash flows from a security due to inflation, as measured in terms of purchasing power. For example, if the Adviser purchases a 5- year bond in which it can realize a coupon rate of 5%, but the rate of inflation is 6%, then the purchasing power of the cash flow has declined. For all but inflation-linked bonds, adjustable bonds or floating rate bonds, the Adviser is exposed to inflation risk because the interest rate the issuer promises to make is fixed for the life of the security.

Lack of Liquidity. One Oak may invest in thinly traded and relatively illiquid securities or those securities may not be traded at the time the portfolios invest or may cease to be traded after the portfolios invests. One Oak also may acquire significant positions in some securities. In such cases and in the event of extreme market activity, One Oak may not be able to liquidate its investments promptly if necessary. In addition, One Oak’s sales of thinly traded securities could depress the market value of those securities and thereby reduce the profitability or increase its losses. Such circumstances or events could affect the portfolio’s gain or loss materially and adversely.

Limited Operating History. Although One Oak has significant investment management experience, One Oak is recently-formed entities and have limited operating history upon which investors can evaluate their likely performance. Accordingly, an investment in the One Oak Funds entails a significant degree of risk. Risk of Default or Bankruptcy of Third Parties. One Oak may engage in transactions in securities, commodities, other financial instruments and other assets that involve counterparties. Under certain conditions, the Adviser could suffer losses if a counterparty to a transaction were to default or if the market for certain securities, commodities, other financial instruments and/or other assets were to become illiquid.
Regulatory Risks
Strategy Restrictions. Certain institutions may be restricted from directly utilizing investment strategies of the type in which the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their own advisors, counsel and accountants to determine what restrictions may apply and whether an investment in the Adviser is appropriate.

Trading Limitations. For all securities, instruments and/or assets listed on an exchange, including options listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render certain strategies difficult to complete or continue and subject the Adviser to loss. Also, such a suspension could render it impossible for the Adviser to liquidate positions and thereby expose the Adviser to potential losses.

Conflicts of Interest: In the administration of client accounts, portfolios and financial reporting, the Adviser faces inherent conflicts of interest which are described in this brochure. Generally, the Adviser mitigates these conflicts through its Code of Ethics which provides that the client’s interest is always held above that of the Firm and its associated persons.

Supervision of Trading Operations. The Adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. Despite the Adviser’s efforts, however, there is a risk that unauthorized or otherwise inappropriate trading activity may occur in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients will be exposed to risks that are specific to the securities in their particular investment portfolio.

Reliance on Management and Key Personnel. Investors have no right or power to take part in the management of One Oak. Accordingly, no investor should invest with One Oak unless such investor is willing to entrust all aspects of management to One Oak. The investment performance of the One Oak portfolios depends largely on the skill of key personnel of One Oak, including, in particular, its sub advisors. If key personnel were to leave One Oak, it might not be able to find equally desirable replacements and the performance of the One Oak Funds could, as a result, be adversely affected.

Security Specific Risks
Liquidity. Liquidity is the ability to readily convert an investment into cash. Securities where there is a ready market that is traded through an exchange are generally more liquid. Securities traded over the counter or that do not have a ready market or are thinly traded are less liquid and may face material discounts in price level in a liquidation situation. One Oak may invest in thinly traded and relatively illiquid securities or those securities may not be traded at the time One Oak invests or may cease to be traded after One Oak invests. One Oak also may acquire significant positions in some securities. In such cases and in the event of extreme market activity, One Oak may not be able to liquidate its investments promptly if necessary. In addition, One Oak’ sales of thinly traded securities could depress the market value of those securities and thereby reduce the portfolio’s profitability or increase its losses. Such circumstances or events could affect the gain or loss materially and adversely. Currency. Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Lack of Registration. One Oak private funds or LP interests have neither been registered under the Securities Act nor under the securities or “blue sky” laws of any state and, therefore, are subject to transfer restrictions.

Withdrawal of Capital. The ability to withdraw funds from the One Oak private funds or LP interests is usually restricted in accordance with the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period of time could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund’s assets and/or disrupting the fund’s investment strategy.

Recommendation of a Particular Type of Security
We recommend on a particular type of security, fixed income (subject to anything to the contrary in the relevant investment advisory agreement, offering document, or organizational documents of a particular client). please register to get more info

To the best of our knowledge, there are no legal or disciplinary events that are material to our clients’ evaluation of our advisory business or the integrity of our management. please register to get more info

Broker-Dealer Registration
Mr. DiTursi is a registered representative with Fox Chase Capital Partner, LLC as in he may find need to provide his clients with brokerage products in the course of providing advisory level services to his clients. A conflict of interest may arise as these sales may create an incentive to recommend products based on the compensation he may earn.

Fox Chase Capital Partner, LLC is wholly independent of and otherwise unaffiliated with One Oak. It does not supervise its investment management services and has no responsibility for the services to its clients.
Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor
Registration
The Adviser and its management personnel are not registered as futures commission merchants (“FCM”), commodity pool operators (“CPO”), and commodity trading advisors (“CTA”) with the Commodity Futures Trading Commission (“CFTC”) and do not have any application pending to register with the CFTC or the National Futures Association as a FCM, CPO, CTA, or an associated person of a FCM, CPO, or CTA.
Material Relationships and Conflicts of Interests with Industry Participants
We may conduct business with institutions that invest, or whose clients invest with One Oak. In addition, we, our affiliates, and the partners, members, managers, directors, and principals of those affiliates may have financial investments in other clients or interests in the performance of other clients. It is therefore possible that we will have conflicts of interest with one or any of the One Oak Funds. We will abide, at all times, by our contractual and fiduciary obligations to each of our clients and will endeavor to ensure that such conflicts are resolved fairly.

There may be a conflict of interest in the allocation of investment opportunities between each of the One Oak portfolios/sleeves, and/or a separately managed client (each known as a “client”). As a general matter, we intend to allocate investment opportunities between all portfolios in a manner that is in the collective best interests of all clients involved. We may, however, allocate an investment opportunity wholly or primarily to one or more client and, therefore, other clients will be unable to participate in such investment opportunity or may participate only on a limited basis. We are generally not under any obligation to share any investment, idea, or strategy with any of our clients.

Any of our clients may be disadvantaged because of our activities on behalf of any of our other clients (including private funds). For instance, the size of one or more of a client’s position in an investment may be limited because of the legal restrictions on the size of combined positions that we may take on behalf of all of the accounts we manage. In addition, we may choose not to offer an investment opportunity to each or all of the clients because the market may not be able to absorb the sale of combined positions in illiquid investments. Further, there may be circumstances under which we will consider participation by one or more client in investment opportunities in which we do not intend to invest, or intend to invest only on a limited basis, on behalf of one or more of the clients. We will evaluate a variety of factors that may be relevant in determining whether a particular situation or strategy is appropriate and feasible for one or more of the clients at a particular time. These factors include the nature of the investment opportunity, taken in the context of the other current investments, the liquidity of the investment relative to the needs of the particular entity or client, legal, regulatory, or tax limitations on the particular client, and the transaction costs involved. Because these considerations may differ for each of the clients, investment activities of each of the clients, in the context of any particular investment opportunity, may differ considerably from time to time.

We may buy or sell a particular investment for only one of our clients or for neither of our clients. Likewise, we may buy or sell a particular investment for only one of our clients or for none of our clients. We may buy or sell different amounts of a particular investment, at different times, for some but not all of our clients, even if the investment could have been bought or sold for other clients at the same time. Likewise, we may buy a particular investment for one client at the same time that we are selling the same investment on behalf of another client including portfolios managed by the same investment teams. Our clients may receive less (or more) of a certain investment than they would otherwise receive if we did not have a conflict of interest among clients. In effecting transactions, it may not always be possible, or consistent with the investment objectives of our various clients, to take or liquidate the same investment positions at the same time or at the same prices. For example, we may or may not have a fund with new or additional investment capital purchase an equal percentage of a particular investment. For a detailed discussion of the conflicts of interest that may arise because of fee structures and fee arrangements, please see Item 6, “Performance-Based Fees and Side-By-Side Management,” above.
Material Conflicts of Interest Relating to Other Investment Advisers
We do not recommend or select other investment advisers for our clients. please register to get more info

TRANSACTIONS AND PERSONAL TRADING
As a fundamental mandate, we demand the highest standards of ethical conduct and care from all of our employees and officers. Our employees must abide by this basic business standard and must not take inappropriate advantage of their position. Each employee is under a duty to exercise his or her authority and responsibility for our benefit and for the benefit of our clients and may not have outside interests that inappropriately conflict with our interests or those of our clients. Each employee must avoid circumstances or conduct that adversely affect or that appear to adversely affect us or our clients.
Code of Ethics
Pursuant to Rule 204A-1, promulgated under the Investment Advisers Act, we have adopted a Code of Ethics to establish applicable policies, guidelines, and procedures that promote ethical practices and conduct by all of our employees and officers and to prevent violations of the Investment Advisers Act and the Investment Company Act.

Our Code of Ethics requires all of our employees to adhere to the highest ethical standards when discharging their investment advisory duties to clients or conducting general business activity on our behalf in every possible capacity, such as investment management, administration, dealings with service providers, confidentiality of information, and financial matters of every kind. Accordingly, the Code of Ethics sets forth policies that are designed to reasonably assure that the high ethical standards that we maintain continue to be applied, deter misconduct by employees, and protect clients and investors in the Client Accounts that we manage. The Code of Ethics prohibits certain activities and personal financial interests and requires disclosure of certain personal investments and related business activities of employees. In addition, the Code of Ethics requires all employees to have an obligation and a responsibility to conduct business in a manner that maintains the trust and respect of fellow employees, our clients, their investors, our business counterparties, and the general public. We will provide a copy of our Code of Ethics, free of charge, to any client or investor and prospective client or prospective investor upon request. Our Code of Ethics may be requested by contacting our Chief Compliance Officer, Joanne Costantini, at 914-205-5823 or [email protected].
Recommending, Buying, or Selling Securities in which We or a Related Person Have a Material
Financial Interest, Invest, or Buy or Sell at the Same Time; Conflict of Interests
In appropriate circumstances, we may cause client accounts over which we have investment authority to affect the purchase or sale of securities, or related securities such as warrants, options, or futures, in which our advisory personnel, our other clients, or we, directly or indirectly, have a position of interest. We may also recommend that our clients or prospective clients purchase or sell such securities. Nevertheless, we anticipate that we will rarely invest client assets in the same or related securities in which we, or our related persons, are invested. There may be circumstances in which we may recommend to clients, or buy or sell for One Oak funds, securities in which our related persons, our other clients, or we, have a position of interest. Such purchases and sales may occur at or about the same time that we buy or sell the same security for our own account or our related persons buy or sell the same security for their own accounts.

Conflicts of interest may occur when we, or our related persons, invest in the same securities that we recommend to our clients and when we, or our related persons, trade in the same security at or about the same time. As discussed above, we expect these situations to occur infrequently, if ever. For example, theoretically we may seek to sell the securities we hold, while simultaneously recommending that our clients maintain their position in the security. A sale by our related persons or us, may affect the liquidity of the securities that our clients continue to hold.

Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities.

Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre- clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates.

Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize any conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Related persons may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. If a security is bought or sold for clients and for Firm access persons on the same day, the access person’s trades must either be: 1. aggregated with the client transactions, in which case all participants in the transaction participate on an average price basis; or 2. executed at the end of the trade day after all client trades in the subject security for that day are completed. If the access person’s purchase of the security is not aggregated with client trades, the price received by the access person cannot be more favorable than the price received for the same security for client accounts that day.

Related persons may buy or sell different investments, based on personal investment considerations, which the Firm may not deem appropriate to buy or sell for clients. It is also possible that employees may take investment positions for their own accounts that are contrary to those taken on behalf of clients. Employees may also buy or sell a specific security for their personal account based on personal investment considerations aside from company or industry fundamentals, which are not deemed appropriate to buy or sell for clients. If these securities subsequently appreciate, these personal transactions could be viewed as creating a conflict of interest.

Conversely, related persons may liquidate a security position that is held both for their own account and for the accounts of Firm clients, sometimes in advance of clients. This occurs when personal considerations (i.e., liquidity needs, tax-planning, industry/sector weightings) deem a sale necessary for individual financial planning reasons. If the security subsequently falls in price, these personal transactions could be viewed as a conflict of interest. please register to get more info

A. Selection of Broker-Dealers and Reasonableness of Compensation
Subject to the policies that may be established by any of our clients, we will be primarily responsible for selecting brokers and dealers to execute transactions with respect to the publicly-traded securities in our clients’ portfolios and for allocating brokerage commissions. We do not expect to execute transactions through any particular broker-dealer, but rather will seek to obtain the best net results for our clients under the circumstances. We will take into account factors such as (i) price (including the applicable brokerage commission or dealer spread); (ii) execution capabilities of the broker-dealers (including accurate and timely execution, clearance, and error/dispute resolution); (iii) research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice, and market analysis); (iv) other services (including reporting and technology) provided by such broker-dealers, which are expected to enhance our general portfolio management capabilities; (v) size of the transaction; (vi) difficulty of execution; (vii) operational facilities of the broker-dealers involved; (viii) risk in positioning a block of securities; (ix) reputation; (x) financial strength and stability; and (xi) quality of the overall brokerage and research services provided by the broker-dealers. We generally seek to have our clients pay the lowest commission rate available to obtain the quality of execution that we deem necessary for the applicable transaction. As noted above, however, we consider other factors besides commission rates when selecting broker- dealers. For example, at times we may receive research reports from brokers and our portfolio managers may consult with brokers’ analysts. Accordingly, we may not always obtain the lowest commission rates available.
Research and Other Soft Dollar Arrangements
Subject to applicable legal requirements and consistent with Section 28(e) of the Securities and Exchange Act of 1934, as amended, and as permitted by a particular client’s investment advisory agreement, offering document, or organizational documents, we may select a broker based upon brokerage or research products or services provided to us. Such products and services may include, but are not limited to, economic forecasts, investment strategy advice, written reports, fundamental advice on individual securities, valuation advice, and market analysis. Such products and services include both proprietary research created or developed by the broker-dealer and research created or developed by a third party. Research services received from broker-dealers are supplemental to our own research efforts, and, when utilized, are subject to internal analysis before being incorporated into our investment process. In return for these “soft-dollars” and other benefits and services, our clients may pay a higher commission (or markup/markdown) than other brokers would charge. We may nevertheless choose to engage a broker-dealer charging a higher commission − a practice referred to as “paying-up” − if we determine in good faith that such commission is reasonable in relation to the services provided.

When we use client brokerage commissions (or markups/markdowns) to obtain research or other products or services, we receive a benefit because we do not have to produce or pay for the research, products, or services. The receipt of research and other “soft-dollar” benefits from broker-dealers provides an incentive for us to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving the most favorable execution. We only use “soft-dollars” to service the accounts or portfolios of clients that paid for those benefits. Similarly, we seek to allocate “soft-dollars” to client portfolios or accounts proportionately to the “soft-dollar” credits generated.
Brokerage for Client Referrals
In selecting or recommending broker-dealers, we do not consider whether we, or any of our affiliates, receive client or investor referrals from a broker-dealer or other third party.
Directed Brokerage
We do not recommend, request, or require that our clients direct us to execute transactions through a specified broker-dealer. Each client’s investment advisory agreement generally grants us the full authority to determine, without obtaining the client’s consent or consulting with the client on a transaction-by-transaction basis, the broker-dealers through whom all transactions will be executed. By directing transactions to certain broker-dealers, we may be unable to achieve the most favorable execution of client transactions and this practice may cost our clients more money. As a result, clients who have elected to direct brokerage may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices than would otherwise be the case. In a directed brokerage account, we may not be able to aggregate orders to reduce transaction costs and our clients may receive less favorable prices.
Aggregating Orders for Various Client Accounts
At the start of the month, our custodian calculates the excess buying power for our Fund and SMAs. We allocate to existing portfolios on a pro rata basis based upon the excess margin throughout the month. All trades are set to be allocated across all accounts equitably through a pro-rata methodology where appropriate between the relevant portfolios. Today, and at this point in the firm’s evolution, this procedure is only relevant for the investment grade purchases and sales of municipal bonds and corporates. The Municipal Opportunities Portfolio cannot purchase non-investment grade securities. Allocation percentages are set at the start of the month and allocations are finalized at the end of the trading day. One Oak utilizes an established formula for allocating securities, including IPOs and Private Placements and/or recommendations among clients. The formula must provide a fair and equitable basis for allocations and be consistently applied to all clients. Prior to the allocation of securities by One Oak, One Oak will determine if a client’s investment objectives and suitability requirements qualify the client for participation in purchasing a specific security. If the client qualifies, One Oak will allocate a certain percentage of the total allocation to each qualified client based upon the following formula: The formula requires dividing the total par amount allocated to One Oak by the total number of clients and their assets under management. For example, if the total allocation to One Oak is $1,000,000 of bonds and One Oak has ten clients that qualify for a percentage of the allocation and each client has a total of $1,000,000 under management with One Oak, each client will receive an allocation of $100,000 worth of bonds. One Oak also utilizes a front-end system called Fabkom which has the ability to allocate to different prime brokers and SMAs. please register to get more info

Periodic Review of Client Accounts
We review each of our portfolios on a daily basis to ensure conformity with each client’s investment style and appropriate asset allocation, and to monitor changes to performance of individual securities. Reviews also include the monitoring of cash and cash equivalent positions and position limits within each client’s account.
Additional Review of Client Accounts
In addition to daily oversight, we also review client portfolios on a quarterly basis.
Contents and Frequency of Account Reports to Clients
Each underlying investor of the One Oak Alpha Opportunities Fund receives a monthly written report summarizing the current value of the account, as of the end of the month, including month-to-date and year-to-date performance information. In addition, taxable investors in the One Oak Alpha Opportunities Fund shall generally receive Schedule K-1s by March 31 of each year. All investors shall receive audited financial statements of the One Oak Alpha Opportunities Fund in which they are invested (prepared in accordance with generally accepted accounting practices) within 120 days of the fiscal year end. If we distribute different or more frequent performance information to an underlying investor in the One Oak Alpha Opportunities Fund, we will make such information available to all investors in the Fund, as applicable. please register to get more info

Economic Benefits for Providing Services to Clients
We do not receive an economic benefit from anyone other than our clients for providing investment advice or other advisory services to our clients.
Compensation to Non-Supervised Persons for Client Referrals
The Adviser does not currently compensate any person who is not our supervised person for client referrals. please register to get more info

Rule 206(4)-2 promulgated under the Investment Advisers Act (the “Custody Rule”) imposes specific conditions on investment advisers who have actual or deemed custody of client assets. As an investment adviser to advisory clients, including investment accounts and pooled investment vehicles, we may be deemed to have custody in instances where we have actual possession or the authority to obtain possession of the assets of our advisory clients, and therefore we must meet the applicable conditions of the Custody Rule.

The Advisor does not accept or permit the Firm or its associated persons from acting as trustee, provide bill paying service, have password access to control account activity or any other form of controlling client assets. All checks or wire transfer to fund client accounts are required to be made out to/sent to the account custodian and transferred to the custodian by the end of the next business day.

Separately Managed Accounts All assets are held at qualified custodians and the custodians provide account statements not less than quarterly to clients at their address of record. Clients should carefully review such statements for any discrepancies or inaccuracies. In certain cases, and at the client’s request, the Advisor allows the use of a standing letters of authorizations (“SLOA”) that permits, with certain limitations the third-party transfer of money between their accounts. Based on the No-Action Letter submitted by the Investment Adviser Association dated February 21, 2017, the SEC indicates that an adviser generally has custody where a client grants the adviser power in a standing letter of authorization (“SLOA”) to conduct third party transfers. The No-Action Letter further states that an Adviser is exempt from the annual surprise audit requirement if it complies with the seven stated conditions of the letter that are intended to protect client assets in such situations. The Advisor meets the seven conditions the SEC has set forth and is therefore not subject to an annual surprise audit. Private Funds The Custody Rule contains significant provisions applicable to investment advisers that serve as a general partner or managing member to private funds formed as limited partnerships or limited liability companies, such as the One Oak Alpha Opportunities Fund. Most significantly, the Custody Rule provides an alternative approach to the quarterly account statement delivery requirement and the annual surprise examination requirement. Specifically, an investment adviser to a private fund need not send to each investor a quarterly account statement or have an annual surprise examination if the fund is (i) subject to an audit (as defined in section 2(d) of Article 1 of Regulation S-X) by an accountant registered with the Public Company Accounting Oversight Board at least annually and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to all investors within 120 days of the end of the fund’s fiscal year. We typically rely upon this exception. please register to get more info

At the outset of an advisory relationship, we may receive discretionary authority from a client to select the identity and amount of securities to be purchased and sold by the client. For example, we will have investment discretion to manage securities accounts on behalf of the One Oak portfolios. In all cases, we exercise this investment discretion in a manner consistent with the stated investment objectives of the client.

When selecting securities and determining amounts of investments, we observe the investment policies, limitations, and restrictions of the clients we advise, as stated in the applicable investment advisory agreement or other applicable agreements. Our clients may, and customarily do, place limitations on our investment authority, including, without limitation, designating types of permitted investments or the percentage of permitted investments, or prohibiting certain types of investments. For a complete discussion of our advisory business and the services we provide to our clients, please see Item 4, “Advisory Business,” above. please register to get more info

As a matter of firm policy and practice, we do not accept authority to vote proxies on your behalf. Generally, you will receive their proxies or other solicitations directly from the custodian or transfer agent. However, you may call or e-mail us with questions regarding a particular proxy or other solicitation, and we may provide advice to you regarding your voting of proxies or such solicitations, upon your request. Nearly all clients authorize us to receive duplicate copies of proxies and other correspondence from investment sponsors.

You retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios.

You should note that we will not advise nor act on your behalf in legal proceedings involving companies whose securities are held or previously were held in your account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, you may direct us to transmit copies of class action notices to you or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. please register to get more info

Balance Sheet
We are not required to attach a balance sheet because we do not require or solicit the payment of fees six months or more in advance.
Contractual Commitments to Our Clients
We have no financial condition that is reasonably likely to impair our ability to meet contractual and fiduciary commitments to our clients.
Bankruptcy Petitions
We have never been the subject of a bankruptcy petition.
ITEM 19: INFORMATION SECURITY PROGRAM & BUSINESS CONTINUITY
Information Security
The Advisor maintains an information security program to reduce the risk that your personal and confidential information may be breached.
Business Continuity Plan
The Advisor has a business continuity plan in place that provides steps to mitigate and recover from the disruption and loss of office space, communications, services or key people.

The business continuity plan covers natural disasters such as snow storms, hurricanes, tornados, and flooding. The plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1-communications line outage, internet outage, railway accident and aircraft accident. Electronic files are backed up regularly and archived offsite.

Alternate locations are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all Investor/Owners within fifteen days of a disaster that dictates moving our office to an alternate location.

A summary of the business continuity plan is available upon request to One Oak Capital Management; Attention: Joanne Costantini, Chief Compliance Officer. please register to get more info