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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.
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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
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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
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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.
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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
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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
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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
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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.
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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
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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.
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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
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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.
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Item 18: Financial Information
Financial Information
We have no financial commitment that impairs our ability to meet our contractual and fiduciary
commitments to clients.
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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
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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
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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
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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.
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ARGENT CAPITAL MANAGEMENT, LLC: DISCLOSURE BROCHURE