Vann Equity Management LLC, which is formerly known as Precision Capital Management (referred to herein as "VEM," the "Firm," "us" and "we"), is an investment adviser that is registered with the United States Securities and Exchange Commission ("SEC"), and is a Limited Liability Company formed pursuant to the laws of the State of Texas.

VEM primarily provides customized discretionary portfolio management services to individuals, families, pension and profit-sharing plans, corporations or other businesses and non-profit institutions. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is granted by the investment management agreement you sign with our firm. VEM generally invests client assets in domestic and international stocks, bonds, mutual funds, options, exchange traded funds ("ETFs") and other public or private securities or investments. Advisory Representatives are available to offer advice on most types of investments owned by a client and at the specific request of a client, will explore investment options not currently owned by a client.

Ownership

VEM is owned and controlled 100% by Vann Partners LLC, formally known as LFAM Investment Counsel and Advisors LLC ("Vann"). The JAV 2020 Irrevocable Trust and Aaron Vann are members of Vann, as of November 2020. VEM has been in the advisory business under the current ownership since November 2020.

Some Investment Advisory Representatives ("IAR's") operate under Austin Wealth Specialists, a "doing business as" ("DBA") trade name and logo, which they use for marketing purposes. Clients should understand that even though Vann's IARs operate under this DBA, when those IARs offer or provide advisory services through Vann, they do so under the supervision of Vann.

Services Offered

• Financial planning services

• Portfolio management services for individuals and/or small businesses

• Portfolio management for businesses or institutional clients (other than investment companies)

• Pension consulting services

Assets Under Management

VEM managed $203,644,459 in client assets on a discretionary basis, as of December 31, 2024.

Overview of Services Offered

Asset Management Services

VEM provides advisory services through its Asset Management Services program. Asset Management Services involve providing clients with continuous and on-going management over client accounts. This means that VEM will continuously monitor a client's account and make trades in client accounts, when necessary, in accordance with the client's investment objective.

VEM's services are always provided based on the individual needs of each client. VEM Advisory Representatives are instructed to consider the individual needs of each client when recommending an advisory platform. VEM's Advisory Representative will conduct a complimentary initial meeting with the client for an information and data-gathering session. At this initial meeting, the Advisory Representative will assist the client in determining the advisory services needed. Clients are given the ability to impose restrictions on their accounts including specific investment selections and sectors. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account.

When client accounts are managed using models, investment selections are based on the underlying models, and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client's individual investment goals, objectives, and mandates.

US Large Cap Growth Model

A pure growth portfolio of typically between 60-75 US large cap stocks with diversified exposure across industries. We seek to invest in competitively advantaged businesses at various stages of their corporate life cycle, leveraging innovation and change to drive rapid growth in earnings and cash flow. We look to identify stocks with the potential to deliver sustainable earnings growth, capitalizing on both secular and cyclical growth. We are patient investors, aiming to invest in companies trading at attractive valuations relative to their long-term potential and taking advantage of cyclical opportunities to build positions in high conviction names.

US Large Cap Value Model

A best ideas portfolio of 60-65 US large cap companies with hidden value and upside potential that we believe are overlooked by the market. We are looking for high quality companies with effective management teams where we believe they can materially improve the business. We focus on relative value, searching for companies with solid businesses, strong balance sheets, and durable earnings profiles that are inexpensive relative to their history, sector, or the market. We balance our valuation analysis with qualitative factors to identify the most compelling valuation opportunities.

US Small/Mid Cap Core Model

Mid Cap Core Equity Fund seeks long-term growth of capital. The portfolio management team aims to construct a portfolio of companies that have high or improving return on invested capital, quality management, a strong competitive position and which are trading at compelling valuations. The investment seeks to provide long-term capital growth. The fund will normally invest at least 80% of its net assets (including any borrowings for investment purposes) in stocks of small companies. The advisor defines a small company as one whose market capitalization falls (i) within or below the current range of companies in either the Russell 2000® Index or the S&P SmallCap 600 Index or (ii) below the three-year average maximum market cap of companies in either index as of December 31 of the three preceding years. While most assets will typically be invested in U.S. common stocks, the fund may invest in foreign stocks in keeping with its objectives.

Non-US International ADR Core Model

International ADR core is a thematic growth portfolio that is geographically, economically, and demographically diversified, and seeks long-term capital appreciation by investing in non-U.S. securities of varying market capitalizations.

Index Advantage Fixed Income ETF

The Index advantage Fixed Income strategy is constructed using Mutual Funds and ETF's consisting of investment grade, hi-yield, U.S and Non-U.S. denominated securities varying in yield, credit and duration. The strategy looks to be consistently 95% invested. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the Fixed Income market.

Index Advantage Domestic ETF

The Index Advantage Domestic US strategy seeks investment results that produce higher returns than the S&P 500 Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in the US equity market. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the US equity market.

Index Advantage International ETF

The Index Advantage International Non-US strategy seeks investment results that produce higher returns than the MSCI EAFE Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in NON-US equity markets. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, country, developed vs. emerging, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the Non-US equity markets.

Index Advantage Global ETF

The Index Advantage Global strategy seeks investment results that produce higher returns than the MSCI All Country World Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in US and NON-US equity markets. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, country, developed vs. emerging, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to equity markets available across the world. This strategy can also be considered a complete allocation to equity markets.

Third-Party Portfolio Management Program

VEM may recommend our Third-Party Portfolio Management Programs ("Program") to Clients to supplement our advisory services. The Program is typically managed by third-party portfolio manager ("TPPM") on a discretionary basis, and each TPPM may offer different types of investment programs and/or services. TPPM programs offer access to a variety of investment portfolio models and strategies, with varying levels of risk. After consultation with their VEM financial professional, a Client may select a TPPM investment management program that is appropriate for their objectives, goals, financial situation and risk tolerance. When using a TPPM, the Client may incur additional platform and investment management fees. The TPPM fees are generally not included in the fees charged by Vann but are disclosed in the Advisory Firm's investment management agreement, which each Client is provided and must sign in order to access the services of the TPPM. Such additional fees are only incurred on the portion of Client's portfolio managed by the TPPM. TPPMs are separately registered investment advisers, and are not affiliated with VEM.

Freedom Platform

VEM offers asset management services to advisory clients utilizing Freedom Investment Management, Inc.'s ("Freedom") portfolios on the Freedom platform. The client can elect to authorize VEM discretionary authority within the Investment Advisory Agreement, full discretion to hire and fire sub-advisors within the Freedom platform. Freedom shall have discretionary authority for the investment and reinvestment of the designated assets with full authority to buy, sell or otherwise effect investment transactions involving the designated assets in the client's name and for the client's account.

Realized Financial, Inc. Sub-Advisory Services

VEM has entered into a sub-advisory agreement with Realized Financial, Inc. ("Realized") as a sub-advisor to directly manage portions of the overall client portfolio concerning Delaware Statutory Trusts ("DSTs"), Qualified Opportunity Zone Funds ("QOZFs"), certain real estate investment trusts (including 721 exchanges, also known as UPREITS) offered by the sponsors of such securities, and 1031-like exchanges involving such securities. VEM continues to serve as a client's primary advisor. In this capacity, VEM remains responsible for the ongoing monitoring of Realized managed accounts as well as for whether Realized remains suitable in the context of a client's overall investment program. VEM will recommend adjustments to Realized allocations when we believe such changes would be in a client's best interest. Clients are provided with the Form ADV Part 2A (or similar disclosure) for any sub-advisor recommended, which provides complete detail on the sub-advisory fees, billing schedule, and payment procedures.

Retirement Plan Services

We offer various levels of advisory and consulting services to employee benefit plans ("Plan"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible Plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status. VEM services may also include planning services for retirement plan participants and consulting with the retirement plan sponsor on methods of improving or enhancing the retirement plan. The exact suite of services provided to a client will be listed and detailed in the Retirement Plan Services Agreement.

Retirement Accounts – DOL Disclosure

We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 ("ERISA") and/or the Internal Revenue Code ("Code"), as applicable, when we provide investment advice regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to sometimes herein as ("Retirement Accounts").

Financial Planning Services

VEM provides advisory services in the form of financial planning and consulting services. Financial planning services do not involve the active management of client accounts, but instead focus on a client's overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas.

Wrap Program

VEM does not provide a wrap program, however, through the Program described above, it does provide access to third-party portfolio managers who offer wrap programs. The TPPM's services are further described in their respective Form ADV Wrap Brochure, which will be provided to you should you elect to engage a TPPM.

Item 5 - Fees and Compensation

Type of Compensation

• A percentage of assets under management

• Hourly charges

• Fixed fees (other than subscription fees)

Asset Management Service Fees

For VEM asset management services, we will charge an annual fee based upon a percentage of the market value of the assets being managed. Our fee for asset management services is set forth in the following fee schedule. Our fees are negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with you, etc.).

Fee Schedule

Minimum AmountMaximum AmountFee (%)

$0.00$50,000,000.001.50%

$50,000,001.00And AboveNegotiable

You will be charged a 1.5% advisory fee when your account is valued at $50,000,000 or less. If greater than $50,000,000 the fees are negotiable. Since our fees are negotiable, the exact fee you will pay may be different from those reflected above. The fees you will pay will be clearly stated in the advisory agreement that you sign with our firm.

Freedom Platform Fees

The Freedom Platform Fee will be charged as a percentage of assets under management. For Clients utilizing the Freedom platform, Freedom will charge all fees including the Vann Advisory Fee.

Investor Household AUMFee Range

<$250,0000.34%-0.76%

Next $250,0000.32%-0.70%

Next $1,500,0000.30%-0.62%

Next $3,000,0000.28%-0.45%

$5,000,001+Discretionary

Realized Sub-Advisory Fees

Pursuant to the Sub-Advisory Agreement, Realized may be engaged by VEM to provide discretionary investment advisory services to certain portions of the portfolios of specified clients of VEM. Realized is paid a portion of the asset management fee paid by clients to VEM based on the value of the client's account as shown below. Fees are calculated on an annual basis and deducted from your account quarterly, in arrears, by VEM with Realized's portion of the overall fee paid directly by VEM to Realized.

Minimum AmountMaximum AmountFee (%)

$300,000$500,0001.60%

$500,001$1,000,0001.55%

$1,000,001$2,500,0001.50%

$2,500,001$5,000,0001.45%

$5,000,001$10,000,0001.38%

$10,000,001$15,000,0001.33%

$15,000,001$20,000,0001.30%

$20,000,001$30,000,0001.20%

Retirement Plan Service Fees

For the retirement plan engagements, fees are negotiated on a case-by-case basis and are determined with each client depending upon the size and complexity of the retirement plan and the services rendered. We also take into consideration special situations or conflicts of interest where charging a fee is prohibited under ERISA law. The exact fee assessed, and payment arrangements will be quoted and disclosed in the Retirement Plan Services Agreement prior to commencing such services. Upon termination of an agreement, any fees paid in advance will be prorated and any unearned fees will be refunded.

Financial Planning Service Fees

VEM will charge a fixed fee and/or hourly fee for consulting services. Our consulting fees are negotiable. We utilize the following financial planning fee schedules:

Fixed Fees: VEM will charge a fixed fee that ranges from $1,000.00 to $20,000.00, for broad-based planning services. In limited circumstances, the total cost could potentially exceed $20,000.00. In such cases, we will notify the client and may request that the client pay an additional fee.

Hourly Fees: VEM charges an hourly fee of $350 for clients who request specific services (such as a modular plan or hourly consulting services) and do not desire a broad-based written financial plan.

Additional Fees and Expenses

In addition to the advisory fees we charge, VEM also assesses an annual technology and administrative fee to each individual account. The amount of that fee is determined based on the platform under which the account is managed, as follows:

Account Fee per Registration - $75.00

This flat fee will be charged in addition to our advisory fees and will be charged regardless of the value of each account. Upon a client terminating their relationship with VEM, the annual technology fee will be prorated for the time the account is active during the current calendar year.

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

What Information We Disclose

We only share your nonpublic personal information with your representative within our firm, affiliates, and non-affiliated companies or individuals as permitted by law, such as mutual funds, insurance companies, and other product vendors, or to comply with legal or regulatory requirements. With your approval, we also may share information with your advisors, which can include your accountant and/or attorney. Additionally, in the normal course of our business, we may disclose information we collect about you to companies or individuals that contract with us to perform servicing functions such as:

• Record keeping.

• Computer related services.

• Good faith disclosure to regulators who have regulatory authority over the company.

Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. Notwithstanding the above, we will not release information about our customers or former customers unless we receive your prior written consent, we believe the recipient to be you or your authorized representative or we are required by law to release information to the recipient.

We do not sell your personal information to anyone.

Confidentiality and Security