CCM INVESTMENT ADVISERS, LLC

Form ADV Part 2A: Firm Brochure CCM Investment Advisers, LLC 1201 Main Street, Suite 1910 Columbia, SC 29201 803-254-9500 www.ccminc.com March 20, 2025 This Brochure provides information about the qualifications and business practices of CCM Investment Advisers, LLC. If you have any questions about the contents of this Brochure, please contact us at 803-254-9500 or compliance@ccminc.com. 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. CCM Investment Advisers, 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 adviser provide you with information about which you determine to hire or retain an adviser. Additional information about CCM Investment Advisers, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes This section of CCM’s Form ADV brochure is designed to describe any material changes since our last annual updated amendment, which was filed on March 13, 2024. • We have updated our Summary of Material Risks to provide additional information in Item 8: Methods of Analysis, Investment Strategies and Risk of Loss. ii  Item 3 -Table of Contents Material Changes ......................................................................................................................................... ii Table of Contents ......................................................................................................................................... iii Item 4 - Advisory Business ........................................................................................................................... 1 A. Background .......................................................................................................................................... 1 B. Services Provided ................................................................................................................................. 1 C. Assets Managed .................................................................................................................................... 2 Item 5 - Fees and Compensation ................................................................................................................... 2 A. Fees Paid to CCM ................................................................................................................................ 2 B. Other Fees and Expenses ..................................................................................................................... 4 Item 6 - Performance-Based Fees and Side-By-Side Management .............................................................. 5 Item 7 – Types of Clients .............................................................................................................................. 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 5 Item 9 – Disciplinary Information ................................................................................................................ 6 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 6 Item 11 – Code of Ethics .............................................................................................................................. 7 A. Code of Ethics ...................................................................................................................................... 7 B. Participation or Interest in Client Transactions .................................................................................... 7 C. Personal Trading................................................................................................................................... 7 Item 12 – Brokerage Practices ...................................................................................................................... 8 A. Selecting Broker-Dealers ..................................................................................................................... 8 B. Soft-Dollar Practices ............................................................................................................................ 8 C. Recommending Broker-Dealers ........................................................................................................... 9 D. Directed Brokerage .............................................................................................................................. 9 E. Bundling of Trades ............................................................................................................................. 10 Item 13 – Review of Accounts .................................................................................................................... 10 Item 14 – Client Referrals and Other Compensation .................................................................................. 11 Item 15 – Custody ....................................................................................................................................... 11 Item 16 – Investment Discretion ................................................................................................................. 11 Item 17 – Voting Client Securities .............................................................................................................. 12 Item 18 – Financial Information ................................................................................................................. 12 Brochure Supplements iii  Item 4 – Advisory Business A. Background CCM Investment Advisers, LLC (“CCM”) is an independent investment advisory firm established in 1986 by Fowler W. Cary, Jr., who passed away in February 2019. The principal owners of the firm as of the date of this brochure are The Big Dog Family Preservation Trust [Trustees: Carlynn E. Cary, Amanda Cary Antonovich and Stephen D. Kirkland, CPA, CMC, CFF] and Fowler Cary Family Trust [Trustees: Carlynn E. Cary, Amanda Cary Antonovich] B. Services Provided 1. Portfolio Management Services CCM provides discretionary portfolio management for individual and institutional investors according to client investment objectives. Discretionary portfolio management is a continuous advisory process where CCM makes ongoing security selection, asset allocation, and related portfolio decisions without client approval on a per-transaction basis (within the stated parameters of the investment objective). CCM utilizes fundamental analysis in managing a variety of equity, fixed income and balanced strategies as described in more detail in Item 8 below. CCM manages every client account as a separate portfolio based on that client’s investment objectives. Through the use of an investment policy statement, written investment instructions or the “CCM Client Investment Parameters” worksheet, the investment objectives and any client- imposed limitations are loaded into CCM’s proprietary Total Portfolio Management System (TPMS). Utilizing the TPMS, each portfolio manager is able to view investment objectives, client- imposed restrictions and other limitations, and risk profiles for each client as their individual account is managed. Each client is allowed to impose restrictions on investing in certain securities, types of securities, or asset classifications. 2. Portfolio Management Through Wrap-Fee and Other Programs CCM participates as a portfolio manager in various wrap-fee programs. Under such programs, a program sponsor (a registered broker-dealer and investment adviser that is not affiliated with CCM) assists the client in selecting a portfolio manager, effects purchases and sales of securities for the client’s account, acts as custodian of the client’s assets, monitors the portfolio manager’s performance and provides periodic reports to clients. The wrap program sponsor charges one bundled or “wrap” fee for all these services and pays a portion of that fee to the portfolio manager. CCM currently participates in wrap-fee programs sponsored by Envestnet PMC and Wells Fargo Advisors Financial Network, LLC. CCM has other arrangements with clients whereby CCM contracts directly with and charges the client for portfolio management services, and the client contracts separately with a broker-dealer (or a dually registered broker-dealer/investment adviser) for portfolio execution and custody, as well as, in some cases, recordkeeping, non-discretionary investment advice, including manager 1  selection and other services that are provided to the client for an asset-based or some form of bundled fee. The process by which CCM makes investment decisions in wrap-fee and other program accounts is the same as the process used for all its managed accounts. In all cases, CCM utilizes the Total Portfolio Management System described above. A wrap program can cost the client more or less than purchasing such services separately. Certain factors bear upon the relative cost of the program, such as the cost of the services if provided separately and the trading activity in the client’s account. C. Assets Managed As of December 31, 2024, CCM managed client assets totaling $1,318,093,474 on a discretionary basis. CCM does not manage assets on a non-discretionary basis. Item 5 – Fees and Compensation A. Fees Paid to CCM 1. Portfolio Management Services Client Fees are based on the fair market value of all assets under management in the respective portfolio. Fair market value for assets is determined by custodians holding client assets. In the event that a fair market value is not available for a security(ies), CCM would work with other pricing sources such as Bloomberg, other custodians or its own internal valuation analysis to determine a fair market value. Annual fee schedules are as follows: Equity/Balanced Accounts Market Value of Managed Assets Annual Fee Up to $ 2,500,000 1.00% Next $ 2,500,000 0.90% Next $ 5,000,000 0.75% Next $ 10,000,000 0.60% Over $20,000,000 0.45% Calculation Example Using tiered pricing to calculate the annual management fee for a $35,000,000 Balanced or Equity Account would be as follows: 2,500,000*1.00%)+(2,500,000*0.90%)+(5,000,000*0.75%)+(10,000,000*0.60%)+(15,000,000* 0.45%) = $212,500 2  The fee for a $35,000,000 Equity or Balanced Account would be: $212,500. Fixed Income Accounts Market Value of Managed Assets Annual Fee Up to $ 10,000,000 0.50% Next $ 10,000,000 0.35% Over $ 20,000,000 0.25% Calculation Example Using tiered pricing to calculate the annual management fee for a $35,000,000 Fixed Income Account would be as follows: (10,000,000*0.5%)+(10,000,000*0.35%)+(15,000,000*0.25%) = $122,500 The fee for a $35,000,000 Fixed Income Account would be: $122,500. In certain cases, advisory fees are negotiable depending on a variety of special factors that are based on a client's particular circumstances. As explained above, in some cases CCM manages client account assets as a subadviser, we are paid a portion of the investment management fee received by the primary adviser and does not charge the client directly. Likewise, where CCM participates in a wrap-fee program, it is compensated by the wrap fee plan sponsor from the bundled fee charged to clients. The advisory fees it earns on such accounts range from 0.30% to 0.50%, based on the program and the strategy selected. The specific manner in which CCM’s fees are charged is established in a client’s written agreement with CCM. CCM will generally bill its fees on a quarterly basis, in arrears, although some clients elect to be billed in advance. Clients can also elect to be billed directly for fees or to authorize the custodian to debit our fees directly from their custody accounts. Management Fees can be prorated for each capital contribution and withdrawal made during the applicable calendar quarter under certain circumstances. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. If a client maintains securities in their account and they do not play a role in the client’s investment strategy, CCM excludes these assets from the account for the purpose of the Management Fee calculation. Fee discounts are awarded to clients for a variety of factors including but not limited to competitive pressure, length of relationship and service requirements. As an example, clients with multiple accounts, including friends and family relationships, with market values totaling more than $5,000,000 are grouped together to qualify for the breakpoint fee discount described below in our standard fee schedule. 3  Example of Household fee discount: Balance $2,500,000 $2,500,000 $2,500,000 Account A B C Average Rate and Total Fee Fee Rate 1.00% 1.00% 1.00% 1.00% Fee $25,000 $25,000 $25,000 $75,000 Household fee calculation: Fee Tier Balance 1.00% $2,500,000 0.90% $2,500,000 $2,500,000 0.75% Average Rate and Total Fee 0.88% Fee $25,000 $22,500 $18,750 $66,250 B. Other Fees or Expenses CCM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients will incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. A complete description of brokerage and custodial fees can be obtained from the respective brokerage firm or custodian. CCM does not receive any portion of these commissions, fees, and costs. As noted above, some of CCM’s clients have entered into arrangements whereby some or all of the fees described in this section are charged on an asset-based fee or other bundled basis. In addition to the foregoing, clients will incur additional expenses in the event that CCM purchases mutual funds or exchange-traded funds for the client accounts. Such funds charge their own internal management fees which are disclosed in the funds’ prospectuses. Item 12 of this brochure further describes the factors that CCM considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Item 12 also describes factors clients should consider in evaluating various brokerage arrangements. 4  Item 6 – Performance-Based Fees and Side-By-Side Management CCM does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Item 7 – Types of Clients CCM provides portfolio management services to individuals, high net worth individuals, corporate and public pension and profit-sharing plans, charitable institutions, foundations, endowments, municipalities, trust programs, and other U.S. and international institutions, entities, or individuals. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investment strategies are established based on each client’s risk tolerance as specified in writing by the client on the “CCM Client Investment Parameters” form, accompanying the CCM Investment Advisory Agreement, through written instructions, or on an Investment Policy Statement. Investment strategies include, but are not limited to “CCM Bonds”, “CCM Low Risk Balanced”, “CCM Moderate Risk Balanced”, “CCM Core Balanced”, “CCM Core Balanced Plus”, and “CCM Core Equity”. CCM utilizes fundamental analysis in the securities selection process. Stocks are analyzed based on their valuation and growth characteristics using a combination of an internally-developed ranking system and other external information. Other factors considered in the stock selection process include but are not limited to: the potential impact of governmental regulations; Environmental, Social and Governance-based investing principles (“ESG”); and various fiscal, monetary and trade policies. CCM’s resulting stock selection is an “aggregate” evaluation process of these criteria, rather than being derived from a “single metric” or criteria (i.e., ESG qualifications, Price/Earnings Ratios, etc.) CCM constructs a model stock portfolio which portfolio managers then use as a template to guide security selection and allocations within equity and balanced accounts. Bonds are evaluated based on credit ratings provided by nationally accredited rating agencies and internal research by CCM. The CCM Investment Committee establishes parameters such as allocation between government and corporate bonds, average duration and credit rating thresholds that portfolio managers follow in building and managing client portfolios. For Balanced strategies which contain stocks and bonds, CCM determines the allocation to each asset class using its own internally developed equity risk premium calculation as well as other external research sources. Summary of Materials Risks CCM primarily utilizes individual stock and bond securities as appropriate for each specific investment strategy; however, certain exchange-traded funds can also be incorporated into client accounts. While our objective is to maximize return for a given risk, there is a material risk that, 5  because of factors known or unknown to CCM, the securities selected for the client could lose all of their value. A summary of material risks associated with CCM investment strategies include but are not limited to the following: • • Company-Specific Risk – loss due to specific company-related matters, such as missed earnings expectations, revenue declines, accounting discrepancies, management issues, reputational matters, etc. Industry-Specific Risk – loss due to industry related factors such as housing declines, international trade matters, etc. • Stock Market Risk – loss due to market fluctuations; • Macroeconomic Risk – loss due to recession, labor, manufacturing and service industry trends; • Geopolitical and Country Risk – loss due to war, political conflicts, currency, and related international matters; • Technological Risk – loss due to technological advancements rendering a company’s products or services obsolete; Interest-Rate Risk – loss due to a rise in interest rates which causes bond prices to decline; • Cybersecurity Risk – loss due to hacking or cyber-attacks; • • Credit Risk – loss as a result of a debt issuer defaulting on its ability to pay; • Quantitative and Qualitative Analysis Risk – loss due to inaccuracies in our methods of quantitative or qualitative analysis in assessing a securities risk; and • Environmental, Social and Governance (ESG) Risk – loss due to the impact of ESG policies on a company’s operations or its attractiveness as an investment. The client is advised that no guarantees are made with regards to account performance. Investing in securities involves risk of loss that clients should be prepared to bear. CCM does not offer investment strategies that incorporate explicit Environmental, Social and Governance (ESG) goals or characteristics. Item 9 – Disciplinary Information CCM has no information applicable to legal or disciplinary events material or immaterial to disclose. Item 10 – Other Financial Industry Activities and Affiliations CCM is not actively engaged in any business other than giving investment advice, and it does not sell products or services other than investment advice to clients. CCM is neither registered nor seeking to be registered in any capacity other than as an investment adviser, and the only registration status of CCM’s management personnel is that of investment adviser representative. 6  Material Third-Party Relationships and Conflicts of Interest CCM maintains relationships with broker-dealers that provide separately managed accounts (SMA) as part of their wrap-fee programs. CCM strategies are offered through these programs. CCM does not believe any material third-party conflicts exist as it relates to its wrap-fee program sponsors; however, we maintain policies and procedures to identify and address prospective conflicts. As an example, CCM’s compliance procedures include the monitoring and preparation of items such as trade analysis (best execution, cross-trading); completing due diligence requests received from our wrap sponsors; and compliance-approved marketing materials made available to those sponsors. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics CCM has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and establishing as a priority, the fiduciary duty to our clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumormongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items. The Code of Ethics also establishes personal securities trading reporting and preclearance procedures, among other things. All supervised persons at CCM must acknowledge the terms of the Code of Ethics annually, or as amended. A copy of our Code of Ethics is available, without charge, to clients and prospective clients upon request. B. Participation or Interest in Client Transactions Neither CCM or a related person participates in or has an interest in any client transactions. CCM does not buy or sell securities, acting as a principal, in client accounts in which CCM or related persons have a financial interest. C. Personal Trading From time to time, CCM’s supervised persons buy and sell for their personal accounts the same securities that CCM purchases for client accounts, and the personal trades can occur at or around the same time as the client trades. This situation presents a potential conflict between the supervised persons’ interests and the interests of our clients. In order to address this potential conflict, the CCM Code of Ethics and related procedures are designed to ensure that the interests of our clients come first. In this regard, the CCM Code of Ethics is designed to prevent the firm’s supervised persons from improperly trading on inside information. Supervised persons must preclear any personal trades in initial public offerings (IPOs), limited partnerships and other limited offerings. With limited 7  exceptions (such as for mutual funds and US Treasury bonds, etc.), supervised persons must report their securities holdings and trading activity to CCM’s Chief Compliance Officer, who reviews the records to ensure that personal trades do not compromise the integrity of the services CCM provides to clients. Item 12 – Brokerage Practices A. Selecting Broker-Dealers As a discretionary investment manager, CCM has the authority to determine which securities are to be bought or sold and the amount to be bought or sold for its portfolio management clients. In a very limited number of cases, CCM is also authorized to select broker-dealers for client transactions and to negotiate commission rates paid on such trades on clients’ behalf. CCM uses its best judgement and experience to choose brokers who will seek to obtain favorable prices and executions on securities transactions. CCM considers the quality, accuracy and efficiency of trade executions, access to inventory, the size and complexity of a particular transaction, the level of service provided by the broker-dealer, and as described further in the next section, the availability of ancillary research services. It is CCM’s policy that the firm will not, acting as principal, buy any securities from or sell any securities to an advisory client. CCM, from time to time, and only when in the best interest of each client involved, purchase securities that are being sold from a managed account through a nonrelated broker-dealer, for the account of another client. B. Research and Other Soft-Dollar Benefits CCM utilizes client commissions to obtain research or other services from brokers with which it places trades, which provides a benefit to CCM and may give it an incentive to recommend such brokers. CCM can place securities transactions with brokers that provide securities and statistical investment research information, other research services, and other services that aid the investment decision-making process, in arrangements designed to qualify under the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934. Such research services, information, and other services are expected to enhance the general portfolio management capabilities of CCM and will be, in the good-faith judgement of CCM, in the overall best interest of its clients’ accounts. Typical research and statistical assistance provided by brokers includes: analysts’ reports on companies and industries, market forecasts, macro-economic analysis, industry forecasts, historical company financial data, quotation services, computer databases and software, and industry trade publications. The benefits realized from research services and data received from brokerage institutions accrue to all of our clients, not just the clients whose commissions pay for them. Brokers who provide research service charge higher commissions than those who do not. While CCM believes that the ancillary research services it receives from brokers enhance its general portfolio management capabilities and ultimately benefit clients, such arrangements confer a benefit on us, because we do not have to produce or pay for the research services we receive in 8  this way. For this reason, the SEC requires us to disclose that we have an incentive to select or recommend a broker-dealer based on our interest in receiving research rather than on client’s interest in receiving the most favorable execution. In order to protect clients’ interest, CCM will periodically evaluate the services provided by brokers. In addition to factors CCM uses to determine the quality of brokerage execution, factors used in evaluating research services include the diversity of sources, market experience, analytical ability, professional stature and reputation, financial conditions, past performance, execution capabilities, and integrity. This process can result in the client’s paying more than the lowest commission rate per share on trades. Some services which aid in the investment decision-making process can have other uses that are not entirely investment decision-making related, such as administrative functions. Registrant will reimburse the brokers, which provide such services, for the administrative portion of such services based on a good-faith estimate of the cost of the pro-rata use of those services for administrative purposes. C. Brokerage for Client Referrals CCM typically offers suggestions for low-cost “execution-only” broker-dealers, “mid-priced” broker-dealers and “full-service” broker-dealers. While none of these broker-dealers is affiliated with CCM, some of the broker-dealers have referred clients to CCM in the past and continue to do so in the future, which presents a potential conflict of interest because we have an incentive to recommend or agree to recommend or select such brokers based on our interest in receiving client referrals, rather than on our clients’ interest in receiving the most favorable brokerage. CCM addresses this potential conflict by not having formal arrangements or understandings that CCM will recommend broker-dealers in exchange for referrals of clients, and by giving the client the ability to select their broker-dealer. D. Directed Brokerage We generally request that clients open accounts at certain broker-dealers to maintain custody of their assets and to execute CCM recommended securities transactions. Not all advisers require clients to direct brokerage. When a client instructs CCM to direct trading for the client’s account to a particular broker-dealer, we may be unable to achieve most favorable execution of client transactions. CCM’s ability to seek best execution is compromised, because we will not trade with other broker-dealers for the client’s account and our ability to negotiate the commission rates charged to the account is be limited or eliminated. As a result of this brokerage direction, in some cases, the account will pay higher commissions, receive less favorable net prices or pay more administrative costs than it would otherwise. The disparity between the commissions a directed account pays and those available through other broker-dealers can be substantial. When a client negotiates a commission rate with a custodian/broker-dealer, it is possible they will not be receiving the lowest possible rate. Furthermore, directed accounts likely will not be eligible to participate in favorable bundled trades that CCM could effect if accounts authorized us to select broker-dealers. Where fixed-income 9  securities are bought or sold for an account, the client pays for the trade through a commission, a mark-up or mark-down on the securities or both as a result of the directed brokerage situation. From time to time the broker-dealers recommended to and/or selected by clients offer clients the option to pay for brokerage and custody services by means of asset-based or fixed fees instead of commissions or other transaction-based fees. In reviewing possible fee arrangements with broker- dealers, clients should consider a number of factors, including the size of the portfolio and nature of the securities held; investment objectives and financial resources; past and anticipated trading practices, including trading volume; the client’s knowledge of securities markets and financial capabilities; the projected cost of the arrangement and how that compares to the cost of paying for executions on a per-trade basis; the services provided; and personal preferences, including the desire for certainty or predictability of fees. The cost of the asset-based fee arrangement can be more or less than the cost of a commission-based brokerage account. Clients also should know that the broker-dealers they have selected may have referred their accounts or other investment management accounts to CCM. As noted above, although we do not have formal referral agreements with broker-dealers, we do, from time to time, receive referrals from client- directed broker-dealers. Such referrals create a potential conflict between our clients' interests in obtaining best execution on their trades and our interest in receiving future referrals. Upon request, we will tell you if your account has been referred to us by the broker-dealer you have selected. E. Bundling of Trades In certain circumstances, CCM will aggregate trades for the same broker-dealer to benefit clients through increased trading efficiency. However, because there are multiple portfolio managers who make individual investment decisions in their respective client portfolios at different times, there will be instances when like trades are transmitted for execution at different times in the same trading day to the same broker-dealer. This will likely result in situations where similar accounts receive different execution prices, different fees, and different commission rates, on the same day. Accordingly, every reasonable effort is made to ensure that we are acting in the best interest of our clients. Item 13 – Review of Accounts Each account is reviewed by one of the Portfolio Managers on a regular basis. All investment advisory accounts are reviewed on a routine cycle. Managers are alerted by the Total Portfolio Management System (TPMS) of changes such as cash inflows or outflows as they occur. Also, on an as needed basis, in addition to the routine monthly review, accounts are reviewed when changes are indicated in asset mix, equity selection, or fixed income selection. These actions will be appropriately reflected in each individual account. The reviewers (all of whom are officers of the company in addition to being Portfolio Managers) are: Robert F. Key, President and Chief Compliance Officer, Chris W. Antley, Chief Investment Officer, Michael A. Burkett, Chief Equity Strategist, Richard J. Linden, High-Net Worth Strategist, Anthony F. Carimi,VP, and Christian J. Leveque VP. 10  On a calendar quarter basis, all clients are furnished an investment review that includes the following: time weighted rate of return for total account and components, individual securities cost basis and market value, summary of investments, income rate, current yield, purchase and sale summary, income and expense summary, and a contributions and withdrawals schedule for the current quarter. Unrealized gain/loss schedules are provided on a quarterly basis upon request. Realized gain/loss schedules are provided with the year-end statement. Item 14 – Client Referrals and Other Compensation A. CCM does not receive any economic benefit from anyone for providing investment advice or other advisory services to our clients. B. Neither CCM nor a related person directly or indirectly compensates (cash or non-cash) any person for client referrals. However, as discussed in Item 12 above, CCM can effect portfolio transactions with broker-dealers who have referred advisory clients to CCM. Item 15 – Custody CCM does not have physical custody of client funds or securities. CCM is however deemed to have custody limited to instances where clients have authorized their custodian to debit our advisory fees directly from their custody account. CCM maintains an independent accounting system reflecting initial positions and regular transactions as directed for execution or as advised by the respective custodian. Our client accounting department produces statements on a quarterly basis as referenced elsewhere in this document. Clients will receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains a client’s investment assets. CCM urges you to carefully review and compare the custodial statement with the account statement provided by us. Our statements occasionally vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Should you have any question about differences between the respective statements, we encourage you to contact us, or your custodian. Clients should contact CCM if for some reason they do not receive a statement at least quarterly from their custodian. Item 16 – Investment Discretion CCM receives discretionary authority from the portfolio management clients at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, CCM observes the investment policies, limitations and restrictions of the clients for which it advises. 11  Investment guidelines and restrictions must be provided to CCM in writing along with an executed contract and all required documentation before we will assume investment discretion. Item 17 – Voting Client Securities Proxy Voting Policy CCM will accept responsibility to vote client securities when directed in writing. In all matters, CCM will act in the best interest of, and with the purpose of increasing the wealth of the shareholders, (i.e. our clients). If any material conflict of interest is discovered between CCM’s interests and those of the client, it will be disclosed to the client and the proxy will be voted in the client’s best interest. Accordingly, the voting decisions will be evaluated on a case-by-case basis, and guided by common sense and the prudent man principle. Clients can direct CCM to vote the proxy of a particular security in any manner that they desire, provided those instructions are made in writing and are received in a timely manner. CCM’s proxy voting records and proxy voting policies and procedures are available upon request Item 18 – Financial Information This item does not pertain to our business. 12