Overview

Assets Under Management: $3.4 billion
Headquarters: CLAYTON, MO
High-Net-Worth Clients: 138
Average Client Assets: $5 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Institutional Clients

Fee Structure

Primary Fee Schedule (ARGENT CAPITAL MANAGEMENT LLC PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $3,000,000 0.80%
$3,000,001 and above 0.65%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $39,000 0.78%
$10 million $71,500 0.72%
$50 million $331,500 0.66%
$100 million $656,500 0.66%

Clients

Number of High-Net-Worth Clients: 138
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 20.70
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 1,067
Discretionary Accounts: 1,062
Non-Discretionary Accounts: 5

Regulatory Filings

CRD Number: 107930
Last Filing Date: 2025-01-10 00:00:00
Website: https://www.linkedin.com/company/argent-capital-management

Form ADV Documents

Primary Brochure: ARGENT CAPITAL MANAGEMENT LLC PART 2A (2025-03-24)

View Document Text
100 S. Brentwood Blvd., Suite 110 St. Louis, Missouri 63105 314-725-6000 www.argentcapital.com March 24, 2025 DISCLOSURE BROCHURE Item 1: Cover Page This disclosure brochure provides information about the qualifications and business practices of Argent Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (314) 725-6000. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Argent Capital Management, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an investment adviser provide you with information about which you determine to hire or retain an investment adviser. Additional information about Argent also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2: Material Changes There have been no material changes to Argent Capital Management, LLC’s brochure. Pursuant to SEC rules, the Adviser will ensure that its clients receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of its business fiscal year. A copy of our current brochure may be requested by contacting Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000 or shammer@argentcapital.com. Our brochure is also available free of charge on our website at www.argentcapital.com. Additional information about Argent Capital Management, LLC is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with Argent who are registered, or are required to be registered, as investment adviser representatives of Argent. -ii- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Table of Contents Item 1. Cover Page ……… ......................................................................................................... ….i Item 2. Material Changes ................................................................................................................ ii Item 3. Table of Contents............................................................................................................... iii Item 4. Advisory Business ............................................................................................................. iii Item 5. Fees and Compensation ...................................................................................................... 3 Item 6. Performance-Based Fees and Side-By-Side Management ................................................. 4 Item 7. Types of Clients .................................................................................................................. 4 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 5 Item 9. Disciplinary Information .................................................................................................... 5 Item 10. Other Financial Industry Activities and Affiliations ........................................................ 5 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 6 Item 12. Brokerage Practices ......................................................................................................... 7 Item 13. Review of Accounts ......................................................................................................... 9 Item 14. Client Referrals and Other Compensation ........................................................................ 9 Item 15. Custody ............................................................................................................................. 9 Item 16. Investment Discretion ..................................................................................................... 10 Item 17. Voting Client Securities .................................................................................................. 10 Item 18. Financial Information ..................................................................................................... 11 Table 1: Risks Associated with Investments ................................................................................ 12 Brochure Supplement -iii- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Item 4: Advisory Business Argent Capital Management, LLC (“Argent”) was founded in 1998 and is a registered investment adviser. We are a Missouri limited liability company that is 100% owned by current employees, of which Steven L. Finerty is the principal owner. Our Mission Argent’s mission is to provide superior investment management in conjunction with a level of personal service and communication that is unique in the investment management community. We provide investment advice to endowments, foundations, pension funds, investment companies and high net worth individuals. As of December 31, 2024, Argent had approximately 3,898,065,509 in assets under management, including 3,610,169,946 of discretionary assets and 287,895,563 of non-discretionary assets. In addition to advising on publicly traded equity securities, we may provide advice with respect to a client’s investments in mutual funds, exchange-traded funds, investment grade corporate bonds, government bonds, commercial paper, certificates of deposit, warrants, limited partnerships, real estate investment trusts and money market funds. Investing in securities involves risk of loss that clients should be prepared to bear. Please see Table 1 at the end of this disclosure for an important summary of the primary investment risks and the steps taken by Argent to manage these risks. Investment Philosophy Argent provides investment management services for domestic equity portfolios. We have built all of our strategies upon a similar investment philosophy. Argent invests in high quality, enduring businesses that have growing cash flows, a durable competitive position and allocate capital wisely. This results in a concentrated portfolio of best ideas for our clients. Argent employs a team approach to portfolio management, with each of the firm’s investment strategies being managed by a portfolio manager, who is supported by a team of analysts. The firm’s Investment Committee is responsible for the oversight and management of Argent Capital Management’s investment strategies. Argent is built on the concept of collaborative investment processes and empowered investment professionals. The purpose of the Investment Committee is to formalize the sharing of ideas and foster communication across and between Argent’s portfolio management teams. This team approach allows us to make prompt investment decisions while avoiding the burden of a large bureaucratic structure. Large Capitalization Strategy The goal of the Large Cap Strategy is to outperform our benchmarks, either the S&P 500® or the Russell 1000 Growth® Index, over the long term. Our review begins with a universe of all U.S. companies with a market capitalization of $3 billion or more. Argent Capital’s® Large Cap Strategy consists of a portfolio of 30-35 stocks. Each of these stocks must demonstrate the characteristics consistent with our investment approach. Argent invests in high quality, enduring businesses that have growing cash flows, a durable competitive position -1- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE and allocate capital wisely. Argent’s Large Cap process results in a concentrated, low turnover portfolio of companies that we seek to own for the long term. Dividend Select Strategy The goal of the Dividend Select Strategy is to outperform the Russell 1000 Value® over the long term. Our review begins with a universe of all U.S. companies with a market capitalization of $3 billion or more. Argent Capital’s® Dividend Select Strategy consists of a portfolio of 30-35 dividend paying stocks. Each of these stocks must demonstrate the characteristics consistent with our investment approach. Argent invests in high quality, enduring businesses that have growing cash flows, a durable competitive position and allocate capital wisely. Argent’s Dividend Select process results in a concentrated, low turnover portfolio of companies that we seek to own for the long term. Mid Capitalization Strategy The goal of the Mid Cap Strategy is to outperform the Russell Mid Cap® Index over the long term. Argent’s Mid Cap process begins by screening the approximately 1,500 companies with market capitalizations in the range of the Russell Midcap Index® and average daily trading volume of $20 million. Argent Capital’s® Mid Cap Strategy consists of a portfolio of 40-50 stocks. The Mid Cap Strategy utilizes an integrated blend of quantitative and fundamental research to identify opportunities to purchase ownership stakes in good businesses that meet our criteria of investing in high quality, enduring businesses that have growing cash flows, a durable competitive position and allocate capital wisely. Argent’s Mid Cap process results in a concentrated, low turnover portfolio of companies that we seek to own for the long term. Argent is also the advisor to the Argent Mid Cap Collective Investment Fund® and is the sub- advisor to the Argent Mid Cap ETF® (ticker: AMID). Focused Small Capitalization Strategy The goal of the Focused Small Cap Strategy is to outperform its benchmark the Russell 2000® Index over the long term. We will typically invest in stocks within the market capitalization range of the Russell 2000® at the time of investment/purchase. Argent Capital’s® Focused Small Cap Strategy consists of a portfolio of 35-45 stocks. Each of these stocks must demonstrate the characteristics consistent with our investment approach. Argent invests in high quality, enduring businesses that have growing cash flows, a durable competitive position and allocate capital wisely. Argent’s Focused Small Cap process results in a concentrated, low turnover portfolio of companies that we seek to own for the long term. -2- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE SMID Capitalization Strategy The goal of the SMID Cap Strategy is to outperform the Russell 2500® Index over the long term. Argent’s SMID Cap process begins by screening the approximately 2,500 companies with market capitalizations in the range of the Russell SMID Cap Index®. Argent Capital’s® SMID Cap Strategy consists of a portfolio of 40-50 stocks. The SMID Cap Strategy utilizes an integrated blend of quantitative and fundamental research to identify opportunities to purchase ownership stakes in good businesses that meet our criteria of investing in high quality, enduring businesses that have growing cash flows, a durable competitive position and allocate capital wisely. Argent’s SMID Cap process results in a concentrated, low turnover portfolio of companies that we seek to own for the long term. All of Argent’s strategies are available as separately managed accounts. Sell Discipline In implementing our strategies, we generally purchase a security with the intent of holding it for the long term. If a company's execution deteriorates and/or valuation becomes excessive relative to our investment thesis, we sell and direct the assets to a more attractive opportunity. Specifically, we may sell a security for any reason, including but not limited to: excessive valuation; poor execution; permanent impairment of the company; an individual stock holding representing greater than a predetermined percentage of the total portfolio; or a source of cash for a better opportunity. Item 5: Fees and Compensation Separate Account Fees Argent’s fees are established in a written Investment Advisory Agreement, and are typically calculated as a percentage of assets under management according to the following schedule: Standard Fee Schedule (All Strategies) 1.00% on first $1,000,000 0.80 % on next $2,000,000 0.65% on balance Institutional Fee Schedule (All Strategies) 0.75% on first $10,000,000 0.55 % on next $15,000,000 0.50% on balance -3- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Standard and Institutional account fees are typically billed quarterly in advance, based on the market value of each client account as of the last day of the prior quarter. We may negotiate or waive fees in certain circumstances. We pro-rate fees for accounts that have been funded less than a calendar quarter at the time of billing. Argent’s fees do not include custodian fees, brokerage commissions or securities transaction fees charged by a client’s custodian and/or broker/dealer. Our fees also do not include any fees that may be charged by mutual fund companies for accounts that hold mutual fund shares. Such charges, fees and commissions are incurred by the client are in addition to our fee, and we shall not receive any portion of these charges, fees and commissions. Please see “Brokerage Practices” on page 9 for the factors that we consider in selecting broker-dealers for client transactions and determining the reasonableness of their commissions. Argent will assist clients in establishing a custodial account at the client’s request. Clients typically grant us authority to deduct its fees directly from the client’s custodial account, although we may send an invoice direct to clients upon their request. Argent will direct the custodian to send clients a statement reflecting the deduction of all fees from the account The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not determine if the fee was properly calculated. Clients retain ownership of all funds and securities in their accounts. Clients may terminate an Investment Advisory Agreement upon written notice to Argent, or as otherwise noted in their Investment Advisory Agreement with Argent. Clients will receive a pro-rata refund of any advisory fees paid, but not yet earned, as of the date of termination. Item 6: Performance-Based Fees and Side-By-Side Management Argent previously offered performance-based fee arrangements for certain investment strategies. A performance fee arrangement is a method of compensating an investment adviser based on a share of the gains or appreciation of the assets under management. For any measurement period, a performance-based fee may be higher or lower than Argent’s current fee schedule. Performance fee arrangements are no longer offered to new Argent clients for any of Argent’s investment strategies. Argent will continue to maintain historical performance-based fee arrangements with existing clients who previously qualified and were subject to such fees. Argent’s previous performance fee arrangements were in compliance with Section 205(e) of the Investment Advisers Act of 1940. According to Section 205(e) (see Rule 205-3 thereunder), only natural individual clients meeting the SEC’s definition of “Qualified Clients” may enter into agreements providing for performance-based compensation to Argent, with Qualified Clients defined as having either $1,100,000 under management with Argent or a net worth of $2,200,000 (excluding the value of the Client’s primary residence and debt secured by the residence, up to the estimated value of the residence). Argent required that performance-based fee accounts had a minimum account size of $500,000. Qualified Clients that were charged a performance fee were not otherwise charged an annual asset management fee Item 7: Types of Clients Argent provides investment advice to endowments, foundations, pension funds, investment companies and high net worth individuals. For new standard (non-institutional) accounts, we have established minimum initial account values of $150,000 and for institutional accounts a minimum -4- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE of $2,000,000 for all strategies, which may be waived or lowered at our discretion. Accounts maintained at levels below the stated initial account values will be periodically reviewed with the client. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss Argent’s primary activity is advising on publicly traded equity securities. In addition, we may provide advice with respect to a client’s investments in other securities such as mutual funds, exchange-traded funds, investment grade corporate bonds, government bonds, commercial paper, certificates of deposit, warrants, limited partnerships, real estate investment trusts and money market funds. Investing in securities involves risk of loss that clients should be prepared to bear. It is important that clients understand that risk of loss must generally be assumed in order to achieve long-term investment objectives. Argent does not offer any guarantee that the strategies it recommends and/or employs within client portfolios will produce desired results or avoid loss. Investing money in the financial markets carries with it numerous risks. The primary risk is market risk, including the possibility of loss stemming from market declines in various asset classes, rising interest rates, and rising credit spreads, among other influences. While Argent strives to construct portfolios that are diversified, there is no guarantee that market forces will not overwhelm diversification efforts, subjecting clients to correlation risk. Recognizing that assuming some type of risk is unavoidable, Argent takes a risk-based approach to reduce the probability and magnitude of losses. Such risk management steps include proper asset and sector allocation, proactive tactical shifts to exploit opportunities or avoid risks, in-depth and independent research, and regular portfolio monitoring and client reviews. Please see Table 1 at the end of this disclosure for an important summary of the primary investment risks and the steps taken by Argent to manage these risks. Please note this list is intended to highlight primary risks of investing assets with Argent, but it does not capture all such risks. Argent provides investment management services for domestic equity portfolios which are comprised primarily of large capitalization, mid capitalization or small capitalization companies. For more information on our Investment Strategies and Methods of Analysis, please refer to “Advisory Business” on page 1. Item 9: Disciplinary Information A registered investment adviser is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the adviser or the integrity of the adviser’s management. Argent has no legal or disciplinary actions to report. Item 10: Other Financial Industry Activities and Affiliations Logan Finerty, President of Argent, is a current partner of Moneta Group Investment Advisors, LLC (“Moneta”), a registered investment adviser that offers comprehensive financial planning services. Steven L. Finerty, Chairman and CEO of Argent, was a partner of Moneta until December -5- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE 31, 2024. Moneta partners may refer to Argent those clients requesting individual equity management services. Argent charges an advisory fee as described in “Fees and Compensation” on page 6. Moneta and its partners may also receive fees from clients for managing client portfolios, including the assets that are managed by Argent, although Steven Finerty and Logan Finerty credit any Argent fees against Moneta fees. No client is obligated to use Argent for equity management services as a result of a referral by Moneta partners. Argent provides equity management services to some clients of Enterprise Trust, a division of Enterprise Bank & Trust, pursuant to a subadvisory agreement. Argent receives a subadvisory fee based on a percentage of assets under management from Enterprise Trust for providing portfolio management services to trust clients. Enterprise Trust charges its own advisory and/or trustee fees. In addition, Argent may recommend that its clients select Enterprise Trust as custodian for their assets managed by Argent. Argent typically pays, out of its advisory fee, any custodial fees charged by Enterprise Trust to Argent’s advisory clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Argent has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to personal trading procedures, the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, among other things. The Code of Ethics also requires all covered persons to comply with federal securities laws and avoid activities, interests, and relationships that might interfere with making decisions in the best interest of client portfolios. All Argent supervised persons certify their knowledge of and obligations under the Code of Ethics annually. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with making decisions in the best interest of Argent’s advisory clients. Subject to the Code of Ethics and applicable laws, officers, directors and employees of Argent may trade for their own accounts in securities which are recommended to and/or purchased for our clients. In addition, the Code of Ethics requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between Argent and its clients. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with Argent’s obligation of best execution. In such circumstances, the affiliated and client accounts will receive the average price paid or received for the entire aggregated trade. We will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. -6- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE We will not affect any principal transactions for client accounts and cross trades between client accounts are allowed in limited circumstances when in the best interest of the client and properly documented with all parties. You may obtain a copy of Argent’s Code of Ethics by sending a written request to: Code of Ethics Information Request, Argent Capital Management, LLC, 100 South Brentwood Boulevard, Suite 110, St. Louis, Missouri 63105. Item 12: Brokerage Practices Argent typically has the discretion to select the broker/dealer that will provide the best execution of a portfolio transaction at the best price for client accounts. When we select a broker/dealer, we are responsible for exercising discretion regarding commissions paid by client accounts. For each specific transaction, we use our best judgment to select the broker/dealer most capable of providing the necessary services to obtain the best available price and the most favorable execution. Best available price and most favorable execution generally describe a policy of executing portfolio transactions at prices which provide the most favorable total cost or net proceeds that are reasonably obtainable under the circumstances. In addition to price, we may consider additional broker/dealer services when selecting a broker/dealer for transactions including among others: trading ability, capital strength, communications, settlement processing, automation, knowledge of other buyers or sellers, administrative ability, underwriting, and provision of information on the particular security or market. The specific criteria used vary depending upon the nature of the transaction, the market, and number of broker/dealers capable of effecting the transaction. In recognition of the value of these factors, transactions will not always be executed at the lowest available commission rate. Negotiated rates will be based upon our judgment of the rates, which generally reflect the execution requirements of the transaction regardless of whether the broker provides research services to Argent. We may also consider utilizing brokers who supply research or brokerage services to us. Client accounts may pay commission rates in excess of those that another broker/dealer would have charged for effecting the same transaction if we determine, in good faith, that the commission paid is reasonable in relation to the value of the research or brokerage services provided as permitted by Section 28(e) of the Securities Exchange Act of 1934. Argent receives both research services that are proprietary to broker/dealers effecting transactions, and third party research and brokerage services provided by broker/dealers through “soft dollars.” We receive a benefit because we do not have to produce or pay for the services. We may use research and brokerage services furnished by broker/dealers to service any or all of our clients, including accounts other than those that pay commissions to the broker/dealer providing the services. We may allocate brokerage for research and brokerage services that are also available for cash, where appropriate and permitted by law and may pay cash for certain research services received from external sources. Research services provided may include, among other things, economic or company information, accounting and tax law/interpretations, political and legal developments, technical market action, quotes, pricing systems, market index information, appraisal services, or analysis. Research services may be in the form of computer-generated data, software, support and related maintenance -7- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE costs. Research services may also be provided through meetings with corporate and industry spokespersons, economists, academicians and government representatives. Brokerage services may include, among other things, our order management system and messaging database utilized to execute trades. In all circumstances where research or brokerage services are provided by broker/dealers with “soft dollars,” and such research or brokerage services are also used by us for administrative purposes (such as the preparation of client account valuations), a reasonable allocation is made by us so that the value of the service for making investment and brokerage decisions is borne by client accounts, and the value attributable to administrative functions is borne by Argent (and paid in cash by us.) Clients should be aware that they have brokerage options. Argent will execute transactions through a particular brokerage firm as a result of a client’s direction or as a result of a client’s decision to participate in a ‘wrap fee’ arrangement. In these situations, the client will be responsible for negotiating the commission rates paid by the client for the execution of transactions. In directed broker arrangements, the client should be aware of Argent’s inability to negotiate commissions, obtain volume discounts and that best execution may not be achieved for transaction in the client’s account(s). As a result, transactions in accounts directed by a client to a particular brokerage firm may result in higher commissions, greater spreads or less favorable net prices than would be the case if Argent were authorized to choose the brokerage firm through which to execute transaction for the client’s account(s). Argent frequently aggregates client orders for execution, which generally results in lower commission rates. When the aggregate order is executed at various prices on a given day, each participating client’s proportionate share of such order reflects the average price paid or received with respect to the total order. In limited circumstances, due to low liquidity, orders may be executed over multiple days with the average price paid or received applied to accounts participating on that day. For trades taking multiple days to complete, the order in which accounts participate is rotated so as not to give advantage to any particular group of accounts. In managing accounts, Argent attempts to allocate securities fairly among client accounts based on each account’s investment style, applicable restrictions, other holdings and availability of cash and securities, but cannot ensure that all accounts will participate equally, or even at all, in every investment. Personal trades for employees of Argent will from time to time be included in aggregated orders with trades in client accounts. If Argent makes an error in submitting a trade order on a client’s behalf, Argent will follow its formal trade error policy. In general, this policy states that if an erroneous trade cannot be broken, then Argent will place a correcting trade with the broker-dealer (the “correcting trade”). If the correcting trade results in a loss to the broker-dealer, Argent will issue a check to cover the loss from company funds and the client account will not be affected in any way. If the correcting trade results in a gain, Argent will review the circumstances and, if appropriate, will apply the gain to the client’s account; if, however, the correcting trade affects several client accounts or is not appropriate, then the gain will be retained by the broker-dealer or directed to a charitable organization. In all cases, any correcting entries will be made in the best interest of the client. -8- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Item 13: Review of Accounts Argent’s investment policy committee reviews portfolios to confirm that each is being managed consistent with the client’s stated goals and objectives and Argent’s investment strategies. All portfolios are reviewed at least annually by the Investment Policy Committee. The committee consists of the portfolio managers, along with representatives from the Client Services and Compliance Teams. In addition to reviews by the Investment Policy Committee, clients may receive regular written reports from Argent regarding their account. The nature and frequency of these reports are determined primarily by the particular needs of each client. Generally, large capitalization strategy clients receive monthly reports of all trades for that period, unless they opt out. Generally, small and mid capitalization strategy clients receive quarterly reports that include summary information on holdings, returns, characteristics and sector weights. Additionally, our portfolio managers are available, upon reasonable request, to conduct special reviews or meet with clients to discuss investment policies and strategies employed to achieve clients’ investment objectives. Clients will receive notice from Argent annually, requesting updated information regarding changes to their financial situation, investment objective and account restrictions. A member of our Investment Committee who is knowledgeable about the management of the client’s portfolio will be available on a reasonable basis to meet with the client at the client’s request. Clients will retain ownership of all funds and securities in their accounts. Additionally, clients will receive monthly or quarterly reports from the client’s broker/dealer and/or custodian that include confirmation of all securities transactions in their account during that month. Please see “Custody” on page 12 for further information. Item 14: Client Referrals and Other Compensation Argent does not enter into written agreements with third-party individuals to function as solicitors or to receive cash compensation for referral of client accounts. If such arrangements are approved in the future, Argent will comply with the Testimonials, Endorsement and Solicitation provisions of The Marketing Rule (Rule 206(4)-1 by providing all parties full disclosure and proper documents of the arrangement. Note that Argent’s officers, directors, or employees may receive compensation for referring clients as a part of their normal course of work. Item 15: Custody Clients retain ownership of all funds and securities in their accounts. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. We urge clients to carefully review such statements and compare such official custodial records to any account statements or reports that we may provide. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients typically grant Argent authority to deduct their fees directly from the client’s custodial account, although we may send an invoice directly to clients at their request. We will send the -9- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE client’s custodian communication reflecting the fees billed and the custodian will send the client a statement, at least quarterly, reflecting all fees deducted from the account. We urge clients to verify the accuracy of the fee calculation, as the client’s custodian will not determine if the fee was properly calculated. Item 16: Investment Discretion Argent typically manages discretionary accounts. Accordingly, we usually receive discretionary authority from the client at the outset of an advisory relationship to determine which securities are bought and sold for each client’s account and the amount of such securities bought or sold. We exercise such discretion in a manner consistent with the stated investment objectives for the particular client account, and clients may impose reasonable restrictions on particular securities. We record investment guidelines and restrictions in writing. Item 17: Voting Client Securities (Proxy Voting) Argent has adopted policies and procedures governing the voting of client proxies (the “Proxy Voting Policy”), which are designed to meet the requirements of the Unites States Securities and Exchange Commission and to fulfill the fiduciary duties owed to clients. The Proxy Voting Policy is intended to provide Argent employees with principles to guide their voting of proxies in an informed and responsible manner in the best interests of our clients by using a defined process for evaluating proxy issues. We have retained Broadridge Proxy Policies & Insights (PPI) Shareholder Value Template to provide proxy-related services to us. The SV Template provides data-driven vote instructions based on the annual voting trends from publicly disclosed vote records of top fund families, selected by assets under management, and whose goal is to maximize shareholder value. We generally intend to follow the recommendations of the Broadridge SV Template in a manner consistent with our Proxy Voting Policy. The guidelines in the Proxy Voting Policy address a broad range of topics including, but not limited to, those related to corporate governance, changes to corporate structure, the board of directors, and compensation. The Argent compliance department is responsible for making proxy voting decisions on your behalf. The compliance team shall make a reasonable effort to monitor corporate actions and obtain sufficient information to make an informed voting decision in your best long- term interests. While we believe this process will result in most voting decisions being made in accordance with the Policy, each vote will be determined based upon a number of relevant factors. As a result, votes occasionally may deviate from the guidelines set forth in the Proxy Voting Policy. Argent’s Investment Committee will make the voting decision in the case where an individual responsible for making proxy voting decisions on your behalf proposes to make a voting decision that deviates from the Policy, or when the decision involves a conflict of interest. Clients may retain their rights to vote any or all proxies for their account. Clients must provide specific voting instructions to Argent in writing and prior to the voting deadline. You may obtain a copy of Argent’s Proxy Voting Policy or information regarding how we vote with respect to your securities by sending a written request to: Proxy Voting Information Request, Argent Capital Management, LLC, 100 South Brentwood Boulevard, Suite 110, St. Louis, Missouri 63105. -10- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Item 18: Financial Information Financial Information We have no financial commitment that impairs our ability to meet our contractual and fiduciary commitments to clients. -11- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Table 1: Risks Associated with Investments As noted in Item 8, previous, please read this important summary of primary investment risks and the steps taken by Argent to minimize these risks. Please note this list is intended to highlight primary risks of investing assets with Argent, but it does not capture all such risks. Disclosure Statement Risk Risk of Loss – General Mitigation Diversification, asset allocation, tactical changes in allocation Market Fluctuation Investment plan suited to client objectives, liquidity needs, and time horizon Asset Class Correlations Continuous monitoring, rebalancing, communication, and disclosure Mutual Funds Portfolio construction and diversification Portfolio construction and diversification Exchange- Traded Funds (ETFs) and Exchange Traded Notes (ETNs) Investing in securities involves risk of loss, including the possibility of total loss, that clients should be prepared to bear. Financial markets and the value of investments fluctuate substantially over time, which may lead to losses in the value of client portfolios, especially in the short run. During times of market turmoil, correlations between asset classes may break down, which may result in higher- than-expected losses for diversified portfolios. Mutual fund investing involves risk; principal loss is possible. Investors will pay fees and expenses, even when investment returns are flat or negative. Investors cannot influence the securities bought and sold, nor the timing of transactions which may result in undesirable tax consequences. ETFs and ETNs are subject to risks similar to those of stocks and are not suitable for all investors. Shares can be bought and sold through a broker, and the selling shareholder may have to pay brokerage commissions in connection with the sale. Investment returns and principal value will fluctuate so that when shares are redeemed, they may be worth more or less than original cost. Shares are only redeemable directly from the fund. There can be no assurance that an active trading market for the shares will develop or be maintained, and shares may trade at, above or below their NAV. Additionally, ETNs and some ETFs are not structured as investment companies and thus are not regulated under the Investment Company Act of 1940. An -12- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Risk Disclosure Statement Mitigation Fixed Income Vary maturities, careful selection of securities to match client risk tolerance and time horizon ETN’s value generally depends on the performance of the underlying index and the credit rating of the issuer. Additionally, the value of the investment will fluctuate in response to the performance of the underlying benchmark. ETFs and ETNs incur fees that are separate from those fees charged by Argent. Accordingly, our investments in ETFs and ETNs will result in the layering of fees and expenses. Prices of fixed income (debt) securities typically decrease in value when interest rates rise. This risk is usually greater for longer-maturity debt securities. Investments in debt with lower credit ratings (and non-rated credits) are subject to a greater risk of loss to principal and interest than those with higher credit ratings. Inflation Risk Asset allocation and security selection Liquidity Risk Asset allocation and security selection Income Risk Portfolio construction and financial planning to avoid asset depletion Socio- political Risk Understanding of client objectives, liquidity needs, and time horizon; portfolio construction, diversification, ongoing monitoring, and rebalancing Risk that increases in the prices of goods and services, and therefore the cost of living, reduce consumer purchasing power. Risk evident when investors do not have full access to their funds and/or when assets cannot be converted into cash according to normal market settlement standards. Liquidity risk is generally higher for small capitalization stocks, alternative assets, and private placement securities. Risk that an investment strategy designed to generate a sufficient income, resulting in the inability to sustain a desired lifestyle and/or the need to sell other assets to generate desired income. Sociopolitical risk is the possibility that instability or unrest in one or more regions of the world will affect investment markets. Terrorist attacks, war, and pandemics are just examples of events, whether actual or anticipated, that impact investor attitudes toward the market in general and result in -13- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Risk Disclosure Statement Mitigation Cyber- Security Risk Established business continuity plans and information security risk management systems which include among other controls, access restrictions, cyber training, security incident response plan, and cybersecurity insurance systemwide fluctuations in currencies as well as prices of securities and commodities. As the use of technology has become more prevalent in the normal course of business, Argent and other firms are more susceptible to operational and information security risks. Cyber incidents can result from deliberate attacks or unintentional events and include, but are not limited to, gaining unauthorized access to electronic systems for purposes of misappropriating assets, personally identifiable information (“PII”) or proprietary information (e.g., trading models and algorithms), corrupting data, or causing operational disruption, for example, by compromising trading systems or accounting platforms. Other ways in which the business operations of Argent, other service providers, or issuers of securities in which Argent invests a client’s assets may be impacted include interference with a client’s ability to value its portfolio, the unauthorized release of PII or confidential information, and violations of applicable privacy, recordkeeping and other laws. A client and/or its account could be negatively impacted as a result. While Argent has established internal risk management security protocols designed to identify, protect against, detect, respond to and recover from cybersecurity incidents, there are inherent limitations in such protocols including the possibility that certain threats and vulnerabilities have not been identified or made public due to the evolving nature of cybersecurity threats. Furthermore, Argent cannot control the cybersecurity systems of third-party service providers or issuers. While Argent does maintain cybersecurity insurance coverage, there currently is no insurance policy available -14- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE Risk Mitigation Disclosure Statement to cover all of the potential risks associated with cyber incidents. Unless specifically agreed by Argent separately or required by law, Argent is not a guarantor against, or obligor for, any damages resulting from a cybersecurity- related incident. Pandemics / COVID-19 Understanding of client objectives, liquidity needs, and time horizon; asset allocation, portfolio construction, diversification, ongoing monitoring, and rebalancing Occurrences of epidemics or pandemics, depending on their scale, may cause different degrees of damage to global, national, and local economies. COVID- 19 (also known as novel coronavirus or coronavirus disease 2019) presents unique, rapidly changing, and hard to quantify risks. In general, it has resulted in a significant reduction in commercial activity on a global scale that has adversely impacted many businesses. Governments, on the national, local, and state level, have instituted a variety of measures including lockdowns, quarantines, and states of emergencies, which materially slowed the global economy. The effects of COVID-19 have and may continue to adversely affect the global economy, which may materially and adversely impact the volatility, value and performance of the securities held in client accounts and our ability to buy or sell such securities at an advantageous time and/or price. The long-term impact of the accommodative monetary policy in the United States, which has been a critical tool in the government’s response to the pandemic, is unknown. However, any meaningful and sustained rise in inflation could further adversely impact the volatility, value and performance of the securities held in client accounts. -15- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE

Additional Brochure: ARGENT CAPITAL MANAGEMENT LLC PART 2B SUPPLEMENT (2025-03-24)

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100 S. Brentwood Blvd., Suite 110 St. Louis, Missouri 63105 314-725-6000 www.argentcapital.com March 24, 2025 Item 1 – Cover Page This brochure supplement provides information about Argent’s Investment Team personnel that supplements the Argent brochure. You should have received a copy of that brochure. Please contact Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000 if you did not receive Argent’s brochure or if you have any questions about the contents of this supplement. Additional information about Argent’s Investment Team personnel is available on the SEC’s website at www.adviserinfo.sec.gov Argent Capital Management LLC Investment Team Brian Reynolds, CFA, CFP Senior Research Analyst Scott Harrison, CFA Portfolio Manager Dividend Select Steven K. Smith, CFA Senior Research Analyst Kirk McDonald, CFA Portfolio Manager Mid Cap SMID Cap Bill Weeks, Ph.D., CFA Senior Research Analyst, Quantitative Peter Roy, CFA Portfolio Manager Focused Small Cap SMID Cap Parker Moses, CFA Research Analyst M. Jed Ellerbroek, Jr., CFA Portfolio Manager Large Cap Jacob Clinkenbeard Research Analyst Ward Brown Director of Portfolio Engagement -1- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT PROFESSIONAL CERTIFICATIONS Select employees have earned certifications which are explained in detail below. CHARTERED FINANCIAL ANALYST (CFA) The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 190,000 CFA charterholders working in 164 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: • Place their clients’ interests ahead of their own • Maintain independence and objectivity • Act with integrity • Maintain and improve their professional competence • Disclose conflicts of interest and legal matters Global Recognition Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in over 30 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance courses. Comprehensive and Current Knowledge The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. To learn more about the CFA charter, visit: www.cfainstitute.org CERTIFIED FINANCIAL PLANNER TM CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements: -2- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT • Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirement through other qualifying credentials. • Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations. • Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements. • Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by the CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks: • Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client. • Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net. -3- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Scott A. Harrison, CFA Portfolio Manager – Dividend Select Strategy As a Portfolio Manager for the Argent Dividend Select Strategy, Scott plays an important role in investment decisions and risk management for the strategy. Scott has 28 years of industry experience and has been a member of Argent’s investment team since joining Argent in 2000. He has been the lead decision maker for Argent’s Dividend Select Strategy since its inception in 2005. As one of Argent’s first employees, he is trained in many roles within the firm, from operations to investment analysis. Scott received his B.S. in Finance from the University of Missouri-St. Louis. He is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of St. Louis Mr. Harrison was born in 1976. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. Harrison is supervised by CEO, Steven L. Finerty. Harrison and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -4- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Kirk McDonald, CFA Portfolio Manager – Mid Cap and SMID Cap Strategies Senior Research Analyst - Quantitative As Portfolio Manager for the Argent Mid Cap and SMID Cap Strategies, Kirk manages client portfolios and plays a key role in investment decisions. He developed the Mid Cap Strategy and began investing in it as of March 2014. He performs primary market research, focusing his analysis across the universe of mid-capitalization stocks. Additionally, Kirk leverages his expertise in quantitative research to lead Argent’s quantitative screening and risk management efforts across all our strategies. Kirk, a Chartered Financial Analyst, has 23 years of experience in the industry. Prior to joining Argent in 2011, he was a portfolio manager for Fiduciary Asset Management LLC (FAMCO). His background also includes serving as a Senior Consultant for Arthur Andersen and as a pilot in the United States Air Force. Kirk earned a B.S. from the United States Air Force Academy and a Master of Business Administration from the University of Oklahoma. He is a member of the Chicago Quantitative Alliance and co-founder and past president of the St. Louis Chapter of the United States Air Force Academy Association of Graduates. He is a member of the CFA Institute and CFA Society of St. Louis. He is also a member of the CQA Investment Challenge, serving as a mentor to a team of students at Webster University. In addition, Kirk is active in the community, volunteering as a committee member for the annual Memorial Day Remembrance at Jefferson Barracks National Cemetery. Mr. McDonald was born in 1967. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. McDonald is supervised by CEO, Steven L. Finerty. McDonald and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -5- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Peter Roy, CFA Portfolio Manager – Focused Small Cap and SMID Cap Strategies As Portfolio Manager for the Argent Focused Small Cap and SMID Cap Strategies, Peter plays an important role in investment decisions and managing portfolio risk. Peter has 26 years of experience in the industry. Prior to joining Argent in 2019, he was with PNC Capital Advisors in St. Louis for 17 years and Nuveen Investments in Chicago. At PNC he held various roles, most recently as a Managing Director and Senior Portfolio Manager on the Select Equity Small Cap Strategy. Peter received his B.A. in English from the University of Dayton and his M.B.A, with a concentration in Finance, from Washington University’s Olin School of Business. He is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of St. Louis. Mr. Roy was born in 1974. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. Roy is supervised by CEO, Steven L. Finerty. Roy and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -6- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience M. Jed Ellerbroek, Jr., CFA Portfolio Manager – Large Cap Strategy As a Portfolio Manager of the Argent Large Cap Strategy, Jed plays an important role in investment decisions and managing risk for the strategy. Jed has 20 years of industry experience. Prior to joining Argent in 2020, he worked with PNC Capital Advisors in St. Louis from 2008-2019 progressing from an analyst role to an Associate Portfolio Manager on the Select Equity Small Cap Strategy. He also served as an Associate Analyst at Wachovia Capital Markets in St. Louis and as an Analyst for consulting firm Jeffrey Slocum & Associates in Minneapolis. Jed holds dual degrees in Economics and Finance from the University of Northern Iowa. He is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of St. Louis. Mr. Ellerbroek was born in 1983. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation. Item 6 – Supervision Mr. Ellerbroek is supervised by CEO, Steven L. Finerty. Ellerbroek and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -7- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Ward Brown Director of Portfolio Engagement Ward serves as the Director of Portfolio Engagement. As Director, he serves as the liaison between the investment team and the rest of the organization. He provides the investment teams with daily and weekly technical analysis and market commentary. Ward has 29 years of industry experience. Prior to joining Argent in 2013, he served as an Equity Execution Consultant at Instinet LLC, where he managed a book of commission-based institutional business. Ward began his career at Bridge Trading Company, where he held several positions, the most recent as Co-Head of Institutional Trading. While at Bridge, Ward served in the company’s UK office, developing its international brokerage arm. Ward earned a B.A. in Human and Organizational Development from Vanderbilt University. Mr. Brown was born in 1973. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. Brown is supervised by CEO, Steven L. Finerty. Brown and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -8- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Brian J. Reynolds, CFA, CFP Senior Research Analyst As a Senior Research Analyst, Brian performs fundamental investment research supporting Argent’s strategies. Brian has 18 years of industry experience. Prior to joining Argent in 2022, he worked with Concordia Plan Services as Assistant Vice President – Investment Research where he oversaw the management of pension plan assets on behalf of the Lutheran Church – Missouri Synod. He was also a Senior Research Analyst on the Select Equity team at PNC Capital Advisors, where he conducted in-depth fundamental research on small and mid-cap companies. Brian received his B.S. in Business Administration with an emphasis in Finance and a minor in Accounting from the University of Missouri – St. Louis. He is a member of the CFA Institute and CFA Society of St. Louis. Mr. Reynolds was born in 1985. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation. Item 6 – Supervision Mr. Reynolds is supervised by Portfolio Manager, M. Jed Ellerbroek, Jr. Reynolds and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -9- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Steven K. Smith, CFA Senior Research Analyst As a Senior Research Analyst, Steven performs fundamental investment research supporting Argent’s strategies. Steven has over ten years of industry experience. Prior to joining Argent, he worked for Fidelity Investments Canada from 2020-2022 as an Equity Research Analyst covering Consumer Staples. In 2019, during his graduate studies, he served as a summer research analyst intern – at Sunriver Management, a global long/short equity investment firm. Before his graduate program, he was an Equity Research Associate Analyst with Edward Jones covering the Energy and Utilities and Technology and Telecom sectors. Steven was with Edward Jones from 2014-2018. Steven holds a Master of Business Administration from the Value Investing Program at Columbia Business School and a Bachelor of Science in Finance from St. Louis University. He is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of St. Louis. Mr. Smith was born in 1992. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation. Item 6 – Supervision Mr. Smith is supervised by Portfolio Manager, M. Jed Ellerbroek, Jr. Smith and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -10- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Bill Weeks, Ph.D., CFA Senior Research Analyst, Quantitative As a Senior Research Analyst, Quantitative, Bill uses his experience in artificial intelligence to build applied machine-learning algorithms to improve equity models for Argent. Bill has more than 20 years of experience in the investment industry in quantitative investment modeling. Prior to joining Argent in 2020, Bill was with American Century Investments where he was a Senior Quantitative Analyst. Before American Century Investments, Bill worked as a Director of Quantitative Research at the Kauffman Foundation where he created multifactor quantitative investment models. Bill has dual degrees in Physics and Electrical Engineering from Washington University as well as a M.S. and Ph.D. in Electrical Engineering from the University of Illinois at Urbana-Champaign. He is a Chartered Financial Analyst and a member of the CFA Institute. Dr. Weeks was born in 1972. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Dr. Weeks is supervised by Portfolio Manager, M. Jed Ellerbroek, Jr. Weeks and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -11- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Parker Moses, CFA Research Analyst As a Research Analyst, Parker performs fundamental investment research supporting Argent’s strategies. Parker, a former Argent intern, joined the firm full-time in 2021. Before coming back to Argent, he was a Performance Analyst with Cardinal Investment Advisors. Parker earned his B.S. in Finance and Accounting from Southern Illinois University, Carbondale. He is a Chartered Financial Analyst and a member of the CFA Institute and CFA Society of St. Louis. Mr. Moses was born in 1998. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. Moses is supervised by Portfolio Manager, M. Jed Ellerbroek, Jr. Moses and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -12- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT Item 2 – Educational Background and Business Experience Jacob Clinkenbeard Research Analyst As a Research Analyst, Jacob performs fundamental investment research supporting Argent’s strategies. Prior to joining the firm in 2024, Jacob interned at both BOK Financial and a search fund to broaden his finance experience while completing his bachelor's degree. Jacob earned his B.S. in Finance and Economics from Baylor University and is currently in pursuit of becoming a CFA charterholder. Mr. Clinkenbeard was born in 2001. Item 3 – Disciplinary Information There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice. Item 4- Other Business Activities There are no outside business activities to report. Item 5 – Additional Compensation There is no additional compensation to report. Item 6 – Supervision Mr. Clinkenbeard is supervised by Portfolio Manager, M. Jed Ellerbroek, Jr. Clinkenbeard and all Argent Investment Team professionals are supervised by policies and procedures relating to the provision of investment advice. These policies include preauthorization of all marketing materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily, and monitoring personal trading activities. For additional information regarding Argent’s supervisory activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000. -13- ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE – SUPPLEMENT