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Item 1 – Cover Page
D.F. Dent and Company
400 East Pratt Street Baltimore, MD 21202
410-837-2544
www.dfdent.com
March 31, 2025
This Brochure provides information about the qualifications and business practices of D.F.
Dent and Company, Inc. (“Adviser”). If you have any questions about the contents of this
Brochure, please contact us at 410-837-2544. 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.
D.F. Dent and Company 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 Adviser is also available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site using a unique identifying number
known as a CRD number. The CRD number for D.F. Dent and Company is 105179.
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Item 2 – Material Changes
D.F. Dent and Company, Inc. (“Adviser”) updates this Form ADV Brochure on an annual
basis, and when there are material changes. This Item 2 of the Brochure identifies and
discusses only specific material changes made to the Brochure since the last annual
updating amendment, which was dated March 26, 2024.
The following material changes are included in this Brochure:
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Adviser updated Item 4 and Item 5 to discuss Adviser’s financial planning services,
and the fees associated with financial planning services.
Adviser updated Item 4 to discuss conflicts of interest associated with Adviser
recommending rollovers from ERISA plans and individual retirement accounts.
Adviser’s Brochure may be requested by contacting our Compliance group at (410) 837-
2544 or compliance@dfdent.com. Adviser’s Brochure is also available on Adviser’s web site
www.dfdent.com. Brochures are provided free of charge.
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Item 3 – Table of Contents
Item 1 – Cover Page
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Item 2 – Material Changes
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Item 3 – Table of Contents
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Item 4 – Advisory Business
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Item 5 – Fees and Compensation
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Item 6 – Performance-Based Fees and Side-By-Side Management
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Item 7 – Types of Clients
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9 – Disciplinary Information
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Item 10- Other Financial Industry Activities and Affiliations
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Item 11- Code of Ethics
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Item 12- Brokerage Practices
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Item 13- Review of Accounts
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Item 14 – Client Referrals and Other Compensation
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Item 15- Custody
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Item 16- Investment Discretion
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Item 17- Voting Client Securities
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Item 18 – Financial Information
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Brochure Supplement(s)
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Item 4 – Advisory Business
Adviser was founded as an independent investment management firm by Daniel F. Dent in
1976. Adviser is independently owned and is unaffiliated with any other financial
organization. Its principal owner is Matthew F. Dent.
Adviser provides investment management services to clients. In connection with that role,
Adviser provides the following types of advisory services:
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Defines investment objectives and risk tolerance levels within the framework of the
clients’ needs and constraints.
Establishes investment programs to accomplish clients’ objectives.
Portfolio construction using securities researched by Adviser personnel.
Portfolio management by adhering to a disciplined strategy of managing specific
equity and fixed-income positions and general exposure to equities and fixed-
income during economic and market cycles.
Review and evaluation of investment performance considering clients' specifically
defined objectives.
Writes and distributes quarterly commentaries of general interest to clients,
consultants, and prospective clients. No additional fee is charged to clients for this
service.
Manages Adviser’s equity strategies: All Cap Growth, Midcap Growth, Small Cap
Growth, Concentrated Growth and Dividend Growth.
Manages the DF Dent Premier Growth Fund (symbol DFDPX), an open-end, multi-
cap growth mutual fund, the DF Dent Midcap Growth Fund (symbols DFDMX,
DFMGX, DFMLX), an open-end midcap growth mutual fund, and the DF Dent Small
Cap Growth Fund (symbols DFDSX, DFSGX, DFSLX), an open-end small cap growth
mutual fund.
Serves as a sub-adviser to other managers, model delivery platforms, and outside
Collective Investment Trusts (CITs).
Adviser tailors its advisory services to the individual needs of clients. As noted above,
Adviser and clients establish investment programs to accomplish clients’ investment
objectives considering the clients’ needs, constraints, and risk tolerance levels. Adviser
also maintains ongoing awareness and does periodic reviews of clients’ investments and
portfolios. Clients may impose restrictions on investing in certain securities or types of
securities, and these restrictions are often able to be entered as trading restrictions on
Adviser’s order management system.
Adviser receives discretionary authority from all investment management clients at the
outset of an advisory relationship to select the identity and amount of securities to be
bought or sold, considering any tax or other restrictions dictated by the client. As of
December 31, 2024, Adviser managed approximately $8,609 billion in assets on a
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discretionary basis using the SEC’s definition of regulatory assets under management and
not including assets attributable to its Unified Managed Account programs.
Adviser does not sponsor any wrap-fee programs. However, Adviser does act as an adviser
or sub-adviser in several wrap-fee programs and receives a portion of the wrap fee paid by
the client to the wrap-fee sponsor.
As of December 31, 2024, Adviser currently acts as a sub-adviser in 16 model delivery
programs called Unified Managed Account (UMA) programs that we consider to be wrap-
fee programs by strict definition. The UMA programs we manage are for our All Cap
Growth, Midcap Growth and Small Cap Growth products. There are a few slight
differences in how UMA accounts are managed compared to other managed accounts.
Adviser submits model changes to the UMA sponsor for execution and the UMA sponsor
does all the trading in client accounts in this program. There is no contact between
Adviser and the UMA program end client. Adviser interacts solely with the UMA sponsor.
Adviser does not provide personalized investment advice to UMA program end clients.
Adviser provides financial planning services to clients as part of its investment
management services or as a stand-alone service pursuant to a financial planning
agreement. Financial planning services are personalized, depending on the client’s
financial picture, goals, and objectives. Generally, financial planning services include
preparing a formal financial plan that encompasses areas of need, including but not limited
to a net worth statement, a cash flow statement, a review of investment accounts including
asset allocation, strategic tax planning, a review of retirement accounts and plans, estate
planning review, education planning, and other areas of particular interest to the client.
A financial plan will usually include general recommendations for a course of activity or
specific actions to be taken by the client. Adviser may also refer clients to an accountant,
attorney, or other specialists, as appropriate for their unique situation. Clients are not
obligated to implement any recommendations made by Adviser or maintain an ongoing
relationship with Adviser.
For investment management services as well as financial planning services, when Adviser
provides investment advice to clients regarding ERISA retirement accounts or individual
retirement accounts, Adviser is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (ERISA). When deemed to be in the client’s best interest,
Adviser will provide investment advice to clients regarding a distribution from an ERISA
retirement account or to rollover the assets to an IRA, or recommend a similar transaction
including rollovers from one ERISA plan to another or one IRA to another IRA. Such a
recommendation creates a conflict of interest if the Adviser will earn a new, or increase its
current, advisory fee as a result of the transaction. No client is under any obligation to
rollover a retirement account to an account managed by Adviser.
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Item 5 – Fees and Compensation
Adviser is compensated as a percentage of assets under management for investment
management services and a flat rate, or hourly rate for financial planning services. Neither
Adviser nor any of its supervised persons accept compensation for the sale of securities or
other investment products.
Adviser’s standard investment management Fee Schedule is as follows:
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1% on the first $10,000,000
0.75 of 1% on $10,000,001 - $20,000,000
0.50 of 1% on amount above $20,000,001
For balanced accounts, 0.30 of 1% on fixed income assets
Under certain circumstances, Adviser enters into alternative fee arrangements and offers
discounts to its standard fee schedule or negotiates fees with clients. These alternative fee
arrangements are lower than Adviser’s standard fee schedule. Adviser’s fee may be
discounted for fixed-income accounts or balanced accounts that own both equities and
fixed income. Fees for sub-advisory or UMA relationships are negotiated on a case-by-case
basis but are lower than the standard fee schedule. The fee schedule is established in a
client’s written Investment Advisory Agreement with Adviser.
Adviser bills its investment management fees on a quarterly basis. It is Adviser’s
customary practice that investment management fees are billed and are payable in advance
(i.e., calculated based on the market value of the assets as of the close of business on the
date preceding the commencement of each successive quarter). However, in certain
circumstances, Adviser has agreed to allow monthly or quarterly payment in arrears.
Adviser does not adjust invoices for contributions and withdrawals after the billing date.
Accounts initiated during a calendar quarter will be charged a prorated fee. Upon the
effective date of a termination of any account (which may, under Adviser’s Advisory
Agreement with clients, occur thirty days after a notice of termination is given), any
prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due
and payable.
Adviser collects a management fee on Advisers’ mutual funds, the DF Dent Premier Growth
Fund, the DF Dent Midcap Growth Fund, and the DF Dent Small Cap Growth Fund
(collectively, the “Funds”). In the case of the Funds, the management fees are calculated on
daily assets within the Funds, and the management fees are known only in arrears due to
the flow of shareholder funds into and out of the Funds.
In addition to Adviser’s investment management fees, clients bear trading costs and
custodial fees. Mutual funds and ETFs also charge internal management fees, which are
disclosed in the fund’s prospectus. Such charges, fees and commissions are exclusive of
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and in addition to Adviser’s fee, and Adviser does not receive any portion of these charges,
fees, and commissions.
Adviser has a conflict of interest in connection with recommendations that Adviser makes
concerning the purchase, sale, or holding of investments for clients’ accounts because
different asset classes or investments in clients’ accounts may have different billable
statuses or fees associated with them. The portion of clients’ assets that are invested in
domestic equities or held in cash are subject to the fee schedule established in the
Investment Advisory Agreement. The portion of clients’ assets that are invested in fixed
income may be subject to a flat fee. The portion of clients’ assets that are invested in non-
D.F. Dent mutual funds or exchange-traded funds (ETFs) are not subject to an Adviser
management fee; however, the assets are subject to fees charged by the mutual fund or ETF
itself. Finally, the portion of clients’ assets that are in one of the DF Dent Growth Funds are
subject to an expense ratio that may be higher or lower than Adviser’s fee schedule (i.e., the
client may not always be invested in the lowest fee vehicle when comparing separately
managed DF Dent accounts with the DF Dent Growth Funds). In addition, the DF Dent
Midcap Growth Fund and the DF Dent Small Cap Growth Fund have multiple share classes
that are subject to different expense ratios. The share class in which a client invests
depends on the size of the investment and the availability of the share class on the platform
on which the client chooses to invest. Adviser does not assess an investment management
fee on the value of a DF Dent Growth Fund held in a separately managed portfolio (i.e.,
clients’ assets invested in the DF Dent Growth Funds are not billed twice).
For its investment management clients, since Adviser has discretion to allocate clients’
assets among different asset classes, Adviser will decide at various times to purchase or sell
fixed income, mutual funds, or ETFs thus changing the billable status of those assets. For
example, if Adviser decides to sell fixed income and invest the proceeds in domestic equity
securities, the assets previously invested in fixed income at a lower fee will then be
included in the total market value of assets subject to Adviser’s standard fee schedule. Or if
Adviser decides to sell non-D.F. Dent mutual funds or ETFs and invest the proceeds in
domestic equity securities, the assets previously invested in non-D.F. Dent mutual funds or
ETFs and not subject to Adviser’s management fee would then be included in the total
market value of assets subject to Adviser’s management fee.
Custodians offer cash vehicles like bank sweep deposit programs and money market funds
that allow clients to earn yields on their cash balances. Adviser strives to select cash
vehicles for clients that earn competitive yields or are backed by the U.S. government.
Factors that influence the cash vehicle Adviser chooses for a client include the range of
offerings from the custodian and the timeframe for the investment of the cash. Adviser
does not receive any revenue or indirect benefit from bank sweep deposit programs or
money market funds that custodians offer.
Adviser offers financial planning services as part of its overall investment management fee.
There is no additional fee for financial planning when combined with investment
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management services. In some cases, at Adviser’s discretion, Adviser also offers financial
planning services as a stand-alone service charged either as an hourly or fixed fee. Fees are
determined based on the nature and complexity of the services to be provided and the
overall relationship with the Advisor.
Financial planning poses a conflict between the interests of the Adviser and the interests of
the client. For example, Adviser has an incentive to recommend that clients engage Adviser
for investment management services or to increase the level of assets with Adviser, as this
would increase the amount of advisory fees paid to the Adviser.
Item 6 – Performance-Based Fees and Side-By-Side Management
Adviser does not charge any performance-based fees (i.e., fees based on a share of capital
gains on or capital appreciation of the assets of a client). As a result, Adviser does not
engage in side-by-side management of accounts that charge performance-based fees with
other accounts, and Adviser faces no conflict of interest related to incentives to favor
performance-based fee accounts over other accounts.
Item 7 – Types of Clients
institutions,
Adviser provides investment management services to individuals, high net worth
individuals, corporate pension and profit-sharing plans, Taft-Hartley plans, wrap-fee
programs/UMAs, charitable
foundations, endowments, municipalities,
registered mutual funds, trust programs, CITs, and other U.S. institutions. Adviser provides
financial planning services to individuals and high net worth individuals.
With respect to account minimums, for All Cap individual clients the standard minimum
account size is $5,000,000, while for All Cap institutional clients the standard minimum
account size is $10,000,000. The minimum portfolio size for Midcap and Small Cap
individual accounts is $1,000,000. The minimum portfolio size for Midcap and Small Cap
institutional clients is $5,000,000. Adviser grants exceptions to these standard minimum-
account-size thresholds at Adviser’s discretion.
Adviser offers to its employees the option to open an employee-owned separately managed
account to be managed by Adviser. The employee-owned separately managed account
must be invested in one of Adviser’s strategies and the individual employee does not have
discretion over the account. Employee-owned accounts are governed by our standard fee
schedule, and the account minimum is $100,000.
Under certain very limited circumstances, Adviser manages foundations funded by
employees of Adviser. Adviser does not charge a fee to these accounts because that would
amount to direct or indirect compensation to the portfolio manager in his capacity as
Adviser.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Adviser uses multiple investment strategies to implement investment advice given to
clients. Adviser has discretionary authority to invest in equity securities, fixed-income
securities, exchange-traded funds (“ETFs”), options, and mutual funds, in addition to
investing cash reserves in short-term, low-risk, highly liquid assets such as money market
funds, bank deposit funds, commercial paper, repurchase agreements and direct
obligations of the U.S. Government or its agencies with maturities of less than 12 months.
The methods of security analysis employed by Adviser include fundamental, technical, and
cyclical analysis. Adviser uses the following sources of information, among others, for
security analysis: financial news publications, meetings with company management,
research materials prepared by others, corporate rating services, annual reports, filings
with the Securities and Exchange Commission, and company press releases.
Investing in securities involves risk of loss that clients should be prepared to bear,
including the possible loss of the principal amount invested. Portfolios will also be subject
to general market risk and market events risk. General market risk is the risk that an
investor could lose money on an investment or that the investment could underperform
other investments. Market events risk may adversely affect clients’ investments due to
market turbulence.
With respect to equity securities, Adviser invests primarily in equity securities such as
common stock, preferred stock and convertible stock of domestic companies that possess
superior long-term growth characteristics and have strong, sustainable earnings prospects
and reasonably valued stock prices. Adviser may also invest in foreign exchange-listed
stocks. Adviser may also invest in companies that do not have particularly strong earnings
histories but do have other attributes that may contribute to accelerated growth in the
foreseeable future. Adviser invests in small, medium, and large-size companies.
The principal risks concerning investment in securities of large-size companies is their
tendency to go in and out of favor based on market and economic conditions, which may
cause them to underperform other market segments. Medium-size and small-size company
securities may be less liquid and tend to exhibit price fluctuations that are more significant
than the price fluctuations of larger, more established companies.
The principal risks concerning growth companies are that growth securities may be more
sensitive to company earnings and more volatile than the market in general primarily
because their stock prices are based heavily on future expectations. If Adviser’s assessment
of the prospects for a company’s growth is wrong, or if Adviser’s judgment of how other
investors will value the company’s growth is wrong, then the price of the company’s stock
may fall or not approach the value Adviser placed on it.
The principal risks related to an actively managed portfolio are if Adviser’s judgments
about the attractiveness and potential appreciation of a particular asset class or individual
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security are incorrect and there is no guarantee that individual securities will perform as
anticipated.
To the extent Adviser invests a significant portion of client assets in a certain sector, clients’
performance could be negatively impacted by events affecting the sector.
With respect to fixed-income securities, Adviser’s investments may include direct
obligations of the U.S. Government or its agencies, state and local obligations, foreign notes,
pooled funds, agency mortgage-backed securities, corporate debt obligations (e.g., finance,
industrial, or utility), collateralized mortgage obligations, asset-backed securities, high-
yield bonds, and non-U.S. dollar denominated bonds.
The general risks associated with fixed-income securities relate to changes in interest rates.
There is normally an inverse relationship between the market value of securities sensitive
to prevailing interest rates and actual changes in interest rates. The longer the remaining
maturity (and duration) of a security, the more sensitive the security is to changes in
interest rates. All debt securities, including U.S. Government securities, can change in value
when there is a change in interest rates. Adviser’s investment in debt securities is also
subject to the credit risk relating to the financial condition of the issuer of the debt security.
Mortgage-backed securities, asset-backed securities and junk bonds exhibit more specific
risks. The value of mortgage-backed securities may be significantly affected by changes in
interest rates, the markets’ perception of issuers, the structure of the securities and the
creditworthiness of the parties involved. Like mortgage-backed securities, the collateral
underlying asset-backed securities are subject to prepayment, which may reduce the
overall return to holders of asset-backed securities. More specifically, asset-backed
securities do not always have the benefit of a security interest in collateral comparable to
the security interests associated with mortgage-backed securities. Finally, junk bonds,
securities rated below investment grade are subject to greater risk of loss of principal and
interest than higher rated securities and are predominantly speculative with respect to the
issuer’s capacity to pay interest and repay principal. In the case of all fixed-income
securities, the issuer’s capacity to pay interest and repay principal may decline during
sustained periods of deteriorating economic conditions or rising interest rates.
Adviser may engage in covered-call option writing. There are certain investment risks
associated with options transactions. These risks include (1) dependence on Adviser’s
ability to predict movements in the prices of individual securities and fluctuations in the
general securities of markets; (2) imperfect correlation between the movements in the
prices of options and movements in the price of the securities (or indices) hedged or used
for cover which may cause a given hedge not to achieve its objective; (3) the fact that the
skills and techniques needed to trade these instruments are different from those needed to
select the securities in which Adviser invests; and (4) lack of assurance that a liquid
secondary market will exist for any particular instrument at any particular time, which,
among other things, may hinder Adviser’s ability to limit exposures by closing its positions.
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Client accounts are subject to the risk that war, terrorism, related geopolitical events, and
health epidemics or pandemics may lead to increased short-term market volatility and
have adverse long-term effects on the U.S. and world economies and markets generally, as
well as adverse effects on issuers of securities and the value of clients’ investments. War,
terrorism, related geopolitical events, and health epidemics or pandemics have led, and in
the future may lead, to increased short-term market volatility and may have adverse long-
term effects on U.S. and non-U.S. economies and markets generally. Those events as well as
other changes in U.S. and non-U.S. economic and political conditions could also adversely
affect individual issuers or related groups of issuers, securities markets, interest rates,
credit ratings, inflation, investor sentiment, and other factors affecting the value of clients’
investments.
Clients also face cybersecurity risk. The computer systems, networks and devices used by
Adviser and service providers to carry out routine business operations employ a variety of
protections designed to prevent damage or interruption from viruses, network failures,
computer and telecommunication failures, infiltration by unauthorized persons and
security breaches. Despite these various protections, systems, networks, or devices
potentially can be breached. A client could be negatively impacted because of a
cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or devices;
infection from computer viruses or other malicious software code; and attacks that shut
down, disable, slow, or otherwise disrupt operations, business processes, or website access
or functionality. Cybersecurity breaches may cause disruptions and impact business
operations, potentially resulting in financial losses to a client; impediments to trading; the
inability by Adviser and other service providers to transact business; violations of
applicable privacy and other laws; regulatory fines, penalties, reputational damage,
reimbursement or other compensation costs, or additional compliance costs; as well as the
inadvertent release of confidential information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers of
securities in which a client invests; governmental and other regulatory authorities;
exchange and other financial market operators, banks, brokers, dealers, and other financial
institutions; and other parties. In addition, substantial costs may be incurred by these
entities to prevent any cybersecurity breaches in the future.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of Adviser or the
integrity of Adviser’s management. Adviser has no information applicable to this Item.
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Item 10 – Other Financial Industry Activities and Affiliations
Adviser has supervised persons registered as registered representatives of a
broker/dealer, however these supervised persons do not accept compensation for the sale
of investment products. As a result, Adviser believes this minimizes or eliminates potential
conflicts of interest.
Adviser has no supervised or management persons registered, or pending registration, as a
futures commission merchant, commodity pool operator, a commodity trading advisor, or
an associated person of the foregoing entities.
With respect to material arrangements, as discussed in other sections, Adviser serves as
investment adviser to the DF Dent Growth Funds, (the “Funds”) each a series of Forum
Funds, a Delaware statutory trust registered as an investment company under the
Investment Company Act of 1940, as amended. The Forum Funds Board of Trustees
oversees the management of the Funds and meets periodically to review each Fund’s
performance, monitor investment activities and practices, and discuss other matters
affecting the Funds. When clients invest in shares of the Funds, they are subject to the
Funds’ fees and expenses, however Adviser does not charge an account level advisory fee
for client investments in the Funds. Adviser has a conflict of interest to the extent that the
fees it earns from managing the Funds are different than the fees earned by Adviser from
managing a similar separately managed account.
Adviser does not have any other business relationships with other investment advisers that
create a material conflict of interest.
Item 11 – Code of Ethics
Adviser has adopted a Code of Ethics (“Code”) and associated procedures, including a Code
of Conduct for Personal Securities Transactions (“Code of Conduct”), for all supervised
persons of the firm describing its fiduciary principles, loyalty to clients, and client-oriented
investment approach. The Code includes provisions on subjects such as conflicts of
interest, insider trading, gifts and entertainment, confidentiality, service on a board of
directors, marketing and promotional activities, other outside business activities, and
personal trading. Adviser’s clients or prospective clients may request a copy of the firm's
Code of Ethics by contacting Compliance at 410-837-2544 or compliance@dfdent.com.
Important elements of Adviser’s Code of Conduct include (i) a designation of the categories
of advisory persons covered by the Code of Conduct, such as portfolio managers making
investment decisions, those employees with access to investment information, and their
relatives whose investments they are managing (collectively “Access Persons”); (ii) the
identification of the kinds of securities to be covered and excluded from the Code of
Conduct; (iii) pre-authorization procedures for the prior approval of personal securities
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transactions by Access Persons; (iv) a review and monitoring procedure for personal
trading activity as well as a description of any restricted or blackout periods for
transactions for Access Persons; and (v) a reporting procedure for transactions and
arrangements for confirmations and statements to be forwarded to Adviser. Failure to
comply with the Code results in varying degrees of disciplinary action up to and including
termination of employment.
The Code of Conduct is designed to ensure that the personal securities transactions,
activities and interests of the Access Persons of Adviser will not interfere with (i) making
decisions in the best interest of advisory clients; (ii) the requirement that all personal
securities transactions be conducted consistent with Adviser’s Code and in such a manner
as to avoid any actual or potential conflict of interest or any abuse of an individual’s
responsibility and position of trust; and (iii) the fundamental standard that Adviser
personnel not take inappropriate advantage of their positions. Subject to satisfying the
Code of Conduct, Adviser and its Access Persons may trade for their own accounts in
securities which have been recommended to and/or purchased for Adviser’s clients at
some time in the past. However, the Code of Conduct now precludes personal transactions
in securities that are currently in any verified composites of Adviser.
Under certain circumstances Adviser will recommend to clients that they purchase
securities in which Adviser, or its Access Persons have a material financial interest. This
occurs in two primary areas: (i) Adviser may recommend to clients that they purchase
public equity securities previously purchased by Adviser or its Access Persons in
accordance with the personal securities pre-approval process described above (or in
accordance with previous practices that were in place before the current Code of Ethics
was first adopted in 2005); and (ii) in cases where clients’ assets are below Adviser’s
minimum-account-size thresholds, Adviser may recommend the DF Dent Growth Funds to
clients. Adviser is paid a management fee on assets in all Funds.
Item 12 – Brokerage Practices
Adviser has financial relationships with other companies in the investment industry.
Adviser receives research services from many brokers and from several non-broker third
parties. These research services include information on the economy, the securities
markets, portfolio strategies, industry sectors or groups, and individual securities. The
services received from brokers also include access to investor conferences and to
management teams of companies of interest, both existing portfolio holdings of Adviser
and potential holdings. Research is shared for the benefit of Adviser’s investment
management clients.
In the case of research services received from full-service brokers with which Adviser has a
business relationship, Adviser trades through those brokers for non-directed accounts and
pays them a standard commission rate for those trades of not more than $0.05 per share.
Although full-service brokers do not break down commissions between execution and
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research services, a portion of these brokerage commissions are allocated to research
services as opposed to execution. In the case of non-broker third-party research firms that
provide research services that are eligible under the Section 28(e) safe harbor, the
contractual payments for these services are made through a soft dollar arrangement with
Adviser’s soft dollar brokers. These commissions are in no case greater than $0.05 per
share, a portion of which is allocated to execution and a portion of which is allocated to
research services.
The use of soft dollar benefits creates a conflict of interest because a client’s brokerage
commissions pay for products or services that do not exclusively benefit such client but
benefit Adviser or other clients of Adviser. In addition, the availability of these benefits can
influence Adviser’s selection of a particular broker over another to perform services for
clients. Where a broker does not provide a dollar value of any research products and
services or brokerage services obtained with clients’ commissions, Adviser will make a
good faith determination that the amount of the commission paid is reasonable in relation
to the value of the brokerage and research products and services provided.
Under certain narrow and specific circumstances, Adviser trades through a broker at a
reduced commission rate with little or no portion of the brokerage commission allocated to
research services.
Adviser does not request or require that clients choose a bank custodian over a broker-
custodian or vice versa. Adviser allows clients to choose to direct brokerage through a
broker-custodian (which Adviser refers to as a “directed account”) or to use a bank
custodian that permits trading at any brokerage firm (which Adviser refers to as a “non-
directed account”). If a client elects to direct brokerage in its account, then Adviser will not
be able to achieve best execution in placing orders. Adviser also will not be able to
negotiate favorable brokerage commissions such as volume discounts and has no
obligation to negotiate such brokerage commissions. As a result, the client often pays
higher commissions to a directed broker than the client would pay for a non-directed
account. Adviser receives no financial remuneration in connection with orders placed
through any brokerage firm, directed or non-directed.
Adviser also has clients who elect directed brokerage in their accounts because the client
has entered into a commission recapture agreement with the directed broker whereby
some portion of trading commissions are paid directly back to the client in return for order
flow. Adviser does not receive any benefits from commission recapture agreements.
Adviser does not promote or sponsor any commission recapture agreements. Commission
recapture agreements are driven by client direction.
With respect to execution of trades in non-directed accounts, Adviser will seek the best
combination of price and execution for the particular transaction (which may be a single
trade or a series of trades). In placing orders for the execution of portfolio transactions,
among Adviser’s considerations in evaluating execution capability are the size of the order,
the ability to effect and settle the transaction promptly and efficiently, and, where a broker
14
or dealer is involved in such transaction, the Adviser’s perception of the broker’s or
dealer’s reliability, integrity, and financial condition and the value to clients of an ongoing
relationship of Adviser with such broker or dealer. So long as Adviser uses its best efforts
in seeking the best combination of price and execution in selecting brokers or dealers to
execute transactions, Adviser also considers the fact that a broker or dealer has furnished,
or has agreed to furnish in the future, statistical, research, or other information or services
to Adviser which enhance Adviser’s investment research and portfolio management
capability.
In general, Adviser has the authority in non-directed accounts to determine, without
obtaining specific client consent, the broker or dealer to be used and the commission rates
paid. Adviser does not consider, in selecting or recommending a broker-dealer, the
prospect of receiving client referrals from a broker-dealer or third-party. Adviser has no
affiliations or other economic relationships with a broker-dealer that would create a
material conflict of interest.
Where Adviser is retained as an adviser or sub-adviser in a UMA program, Adviser does not
negotiate brokerage commissions or related charges on the client’s behalf for the execution
of transactions in the UMA account. Trading commissions and other transaction costs are
generally included in the wrap fee charged by the sponsor. UMA program model changes
are submitted to the program sponsor either through the sponsor’s designated website or
via email. The program sponsor, not Adviser, executes the trades associated with the UMA
program model changes. Adviser does not have the discretion to select broker-dealers to
execute trades for the UMA programs.
Certain clients of Adviser choose to negotiate a bundled fee arrangement with their
directed broker/custodian under which the client pays a bundled fee per month or per year
that includes custodial services, brokerage commissions and possible other services.
Adviser is not a party to any such arrangements between client and directed
broker/custodian.
Adviser treats non-directed accounts first in Adviser’s trading priority. Where possible,
these non-directed orders are aggregated at the same broker, thereby facilitating equitable
treatment of all non-directed client accounts and facilitating timely and efficient execution
of non-directed client trades. Instances in which certain non-directed client orders might
not be aggregated with other non-directed client orders on the same trading day include
•
the following:
•
•
Different client objectives and constraints (e.g., different risk and volatility
tolerance, tax constraints);
Different cash positions and future cash needs; and
Different desires for portfolio concentration.
As disclosed to all investment management clients that have client-directed brokerage, the
non-directed accounts receive a higher trading priority than accounts that have client-
15
directed brokerage. After trading priority is given to non-directed accounts, the Traders
will implement a rotational trading schedule (by day of the week) among all directed
accounts.
In
limited
For most UMA Programs, Adviser does not consider itself to have a discretionary
investment advisory relationship with the clients of the Program Sponsor or Overlay
Manager. The Program Sponsor or Overlay Manager typically serves as the discretionary
investment manager and is responsible for monitoring client accounts, executing
transactions, and seeking best execution.
instances, Adviser retains
responsibility for Section 13(f) and (g) filings for UMA Program clients. Adviser provides a
model to the Program Sponsor or Overlay Manager, and, in turn, the Program Sponsor or
Overlay Manager agrees to implement the model for client accounts, subject to any client-
imposed restrictions. The Program Sponsor or Overlay Manager is responsible for
executing transactions and monitoring client accounts. Clients of the UMA Program should
refer to their UMA Program documentation for additional information regarding
transactions for their account.
With respect to notifying UMA Programs of a model change, Adviser will include within a
rotation with its non-directed accounts those UMA Programs that promptly acknowledge
receipt of a model change, notify Adviser when trading activity has been completed,
provide Adviser with execution prices, and satisfy other relevant criteria as determined by
Adviser. To ensure fair practice, Adviser uses a rotational schedule (by day of the week) to
submit the model changes to the UMA Program Sponsor for execution.
Adviser will generally proceed to the next trading group or UMA Program following receipt
of information indicating that trading for the previous group or program has been
completed. In some instances, Adviser may initiate trading for more than one UMA
Program at a time if market/liquidity conditions are favorable, and the presence of multiple
orders in the market are not expected to adversely affect executions. This scenario is more
likely to occur in larger cap names.
Some of Adviser’s UMA Program clients do not provide notification that a recommended
model change has been accepted or report that trading has commenced and/or has been
completed. Adviser will typically submit model changes to these UMA Programs following
trading for other clients. Adviser will consider communication of a model change to these
UMA programs, which occurs using a rotational schedule (by day of the week), to be
complete upon transmission, and Adviser may not wait before communicating model
changes to other, similarly situated UMA programs. Due to Adviser’s lack of visibility into
certain UMA Program trading, Adviser may take prudent measures, including controlling
the timing of model change submissions, to allow time for trading and minimize the
potential for simultaneous trading.
One exception to the above-described trading priority is Adviser’s use of “step-outs” to
increase trading efficiency and the ability to aggregate trades. Adviser has agreements in
place with several directed brokers whereby an order may be assigned to a brokerage firm
other than the directed broker. This order will receive its standard directed broker
16
commission even though it is executed by another brokerage firm. Stepped-out trades are
given the same trading priority as non-directed account trades. Therefore, there are
occasions in which a directed account subject to a stepped-out trade may receive the same
trading priority as non-directed accounts and a higher trading priority than other directed
accounts.
Once an aggregated order is executed (whether by a non-directed or directed broker),
participating accounts will receive the average price for trades with that broker as their
execution price. Partial fills will be allocated among the eligible accounts using either the
“Random” or the “Pro Rata” allocation function in Adviser’s order management system.
The Random allocation function gives full allocations (in an order randomly chosen by the
order management system) to certain accounts among those designated as eligible for
participation in the trade. The Pro Rata Allocation function gives partial, pro rata
allocations to all accounts designated as eligible for participation in the trade. To avoid any
implication of inequitable treatment by clients, all partial fills within given directed brokers
will also be allocated among the eligible accounts using the “Random” or “Pro Rata”
allocation function in the order management system. Adviser’s policy of trade aggregation
is intended to protect the interests of Adviser’s clients.
Adviser makes its best effort to specify tax lots when executing sale orders, but Adviser
cannot guarantee that custodians always follow tax lot instructions.
Adviser does not engage in any principal or agency cross securities transactions for client
accounts. On occasion, when a portfolio manager wishes to sell a bond on behalf of one of
its clients and another client can use the same issue in its portfolio, bid and offer price
levels are obtained from a broker and the bond is “crossed” at the mean of the bid and offer
price. In this case, the transaction is always executed through a broker with a small
commission of price adjustment to the mean price to compensate the broker for processing
the trade. Adviser uses an independent outside broker to establish the price at which the
transaction is executed.
These brokerage practices do not apply to stand-alone financial planning clients as Adviser
does not accept authority to manage those assets, but rather provides financial planning
advice on those assets.
Item 13 – Review of Accounts
Each of Adviser’s accounts is reviewed at least once per quarter considering market
developments within the context of each client's particular investment objectives. Adviser
prepares a report comparing each Portfolio Composition to the corresponding Target
Allocation for that portfolio as set forth in the Investment Program to monitor for
deviations from the intended portfolio target allocations. Any material, account-specific
development or consideration that is expected to have a significant bearing upon a client's
17
portfolio or individual holdings would trigger a separate review in addition to the quarterly
review.
In general, Adviser manages all its investment products using a team approach, allowing
investment strategies to be formulated and investment decisions to be made as the product
of group discussion rather than individual decisions. The investment teams meet regularly
to evaluate current investments and discuss potential new investments.
Adviser’s portfolio managers may consider many factors in deciding whether securities are
appropriate for particular accounts, based on those accounts’ objectives and constraints.
These factors include the following:
•
•
•
•
•
•
•
•
•
Risk and return profile of client.
Legal, regulatory, or client-dictated restrictions on account.
Time horizon of investment and/ or client.
Availability of cash in the account.
Liquidity of security.
Existing ownership of security or similar security.
Tax considerations.
Minimum transaction costs imposed by brokers/custodians.
Asset allocation guideline on account.
With respect to the Funds in particular, Adviser monitors the Funds for compliance with
the limitations set forth in the Prospectus and SAI and reviews the Funds on a quarterly
basis for signs of window dressing and portfolio pumping. Apex Group, Ltd. as the CCO of
the DF Dent Growth Funds, conducting comprehensive annual examinations of the Funds
and conducting targeted quarterly and ongoing reviews of the Funds.
Adviser sends via U.S. mail or electronic distribution, depending on client instruction, a
quarterly report to each client (for each portfolio), unless client directs otherwise, that lists
each asset indicating cost, current market price, current market value, percent of portfolio
represented by each security based upon current market value, and current yield. Adviser
also includes a performance report that summarizes percentage time-weighted returns for
principal and income for the total account and in each applicable sector (e.g., equities, fixed
income) versus a relevant benchmark.
Clients should receive at least quarterly statements from the broker dealer, bank or other
qualified custodian that holds and maintains clients’ investment assets. Adviser urges
clients to carefully review such statements and compare such official custodial records to
the account statements that Adviser provides to clients. Adviser’s statements may vary
from custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
18
Financial planning clients who do not contract Adviser for investment management
services, are not subject to ongoing review of the financial plan unless contractually
obligated at the beginning of the relationship.
Item 14 – Client Referrals and Other Compensation
Neither Adviser nor any related person has any arrangement, verbal or in writing, whereby
someone who is not a client provides economic benefit to Adviser for providing investment
advice or other advisory services to Adviser’s clients.
In 2016, Adviser entered into a third-party promoter agreement with a third-party firm,
Stonecrest Advisors, Inc. For its services, the third-party firm is paid a percentage of the
management fee received by Adviser from the clients or investors the third-party firm has
solicited and introduced to Adviser. As of July 2021, Stonecrest is no longer soliciting or
introducing new clients to Adviser. The promoter arrangement does not affect the fees paid
by any client – i.e., no solicited client pays higher fees because of the promoter
arrangement.
Adviser does not execute transactions with any broker-dealer in exchange for promoting or
selling Adviser products, including shares of the Funds.
Adviser may use certain equity and fixed-income research of brokerage firms and may
compensate those brokers for their research in the form of brokerage commissions. The
retail-brokers of these firms may independently decide to place their clients in the Funds.
The brokerage commissions in exchange for research are not tied in any way to the
purchase of Fund shares by the clients of the retail brokers.
Adviser pays a fee to certain brokerage firms for making the Funds available to their
clients. No other compensation or exchange takes place. The Funds are also available to
investors through other platforms to which Adviser does not pay a fee.
Item 15 – Custody
To avoid being deemed to have custody of client assets, Adviser must not have signatory
power over any client’s checking account; have power to unilaterally wire funds from a
client’s account; hold any client’s securities or funds in Adviser’s name at any financial
institution; physically hold cash or securities of any client; have general power of attorney
over a client’s account; hold any client’s assets through an affiliate of Adviser where
Adviser or its employees or officers have access to advisory client assets; receive the
proceeds from the sale of client securities or interest or dividend payments made on a
client’s securities of check payable to Adviser except for advisory fees; or act as general
partner and investment adviser to any investment partnership. Adviser has none of the
19
above indicia of custody over client accounts.
If any employee of Adviser receives funds, securities, or other assets from a client that
might establish custody, such employee must immediately notify the Chief Compliance
Officer or her designee and arrange to return such funds, securities or other assets to the
client. Clients should receive at least quarterly statements from the broker-dealer, bank or
other qualified custodian that holds and maintains clients’ investment assets. Adviser
urges clients to carefully review such statements and compare such official custodial
records to the account statements that Adviser provides to clients. Adviser’s statements
may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities.
Item 16 – Investment Discretion
For investment management relationships, Adviser receives discretionary authority from
the client at the outset of an advisory relationship to select the identity and amount of
securities to be bought or sold. In all cases, such discretion is to be exercised in a manner
consistent with the stated investment objectives for the particular client account as
reflected in the Investment Program. In addition, if the client has not elected to direct
brokerage in its account, Adviser will have full brokerage discretion (in addition to
security-selection discretion). The Adviser evaluates the range and quality of a broker’s
services in placing trades including commission rates, confidentiality, clearance and
settlement capabilities, promptness and quality of execution and the financial stability of
the broker-dealer.
When selecting securities and determining amounts, Adviser considers investment policies,
limitations, and restrictions of the clients for which it advises, including the Investment
Program that Adviser maintains for each client. Limitations such as 25% of the supervised
portfolio in any one industry or 5% of the portfolio in any one equity at original cost are
typical in multi-cap accounts. Percentage limitations in Equities, Fixed Income and Reserve
Funds are also spelled out in the Investment Program. For registered investment
companies, Adviser’s authority to trade securities may also be limited by certain federal
securities and tax laws that favor the holding of investments once made. Investment
guidelines and restrictions must be provided to Adviser in writing (or reflected in a written
Investment Program drafted by Adviser and agreed to by client) for Adviser to act in
accordance with them.
Adviser does not accept investment discretion for standalone financial planning clients.
Item 17 – Voting Client Securities
Adviser has discretion to vote the proxies for most of its accounts, including the Funds.
Proxy voting is an important right of shareholders, and reasonable care and diligence must
be undertaken to ensure that such rights are properly and timely exercised. Adviser uses
20
Broadridge’s ProxyEdge software system for the collection, voting and recordkeeping of
proxies for most client accounts. Certain custodians require that Adviser use a different
proxy voting platform than ProxyEdge. Further, certain clients may assume proxy voting
authority for themselves or have given such authority to their custodian, broker, or
consultant.
Adviser votes according to certain guidelines in its Proxy Voting Policy. Adviser will vote
proxies in the best interests of its clients and the Funds’ shareholders and in accordance
with these procedures and policies. Since the quality and integrity of management is a
primary factor Adviser considers when investing in an issuer, the recommendation of the
issuer’s management on any issue, particularly routine issues, will be given substantial
weight in deciding how to vote proxies. However, Adviser will not support the position of
the issuer’s management in any situation where Adviser determines that the position is not
in the best interest of Adviser’s clients. The instances in which Adviser may vote against an
issuer’s board of directors or “management” proposal will be determined on a case-by-case
basis, and Adviser’s Designated Officer will document those instances in Adviser’s Proxy
Voting file.
Adviser recognizes that under certain circumstances it may have a conflict of interest in
voting proxies. A conflict of interest means any circumstance in which Adviser (including
officers, directors, and employees) knowingly does business with, receives compensation
from, or sits on the board of, a particular issuer or closely affiliated entity, and, therefore,
may appear to have a conflict between its own interests and the interests of shareholders
in how proxies of that issuer are voted. If Adviser determines that a material conflict of
interest exists, Adviser’s Chief Compliance Officer and/or Designated Officer will determine
whether it is appropriate to disclose the conflict to the affected clients, to give the clients an
opportunity to vote the proxies themselves, or to address the voting issue through other
objective means such as voting in a manner consistent with a predetermined voting policy
or receiving an independent third-party voting recommendation.
Adviser maintains hard-copy or electronic files relating to Adviser’s proxy voting
procedures in an easily accessible place (e.g., through the ProxyEdge website). Adviser will
maintain and preserve records for at least six years from the end of the fiscal year during
which the last entry was made on a record.
The proxy voting record for the DF Dent Growth Funds is disclosed annually on its Form N-
PX filing. Beginning in 2024, in accordance with new rules, Adviser also began disclosing
the proxy voting record for its separately managed accounts on executive compensation, or
so-called “say-on-pay” matters.
Clients may obtain a copy of Adviser’s complete proxy voting policies and procedures by
contacting Compliance at 410-837-2544 or compliance@dfdent.com. Clients may contact
Adviser to obtain information about how Adviser voted any proxies on behalf of their
account(s).
21
Regarding securities class action settlements, for certain clients, Adviser files securities
class action settlement claims on behalf of clients through the use of an outside service
provider, Broadridge. This service enables clients to participate in all settlements for which
they are eligible and receive the maximum amount to which they are entitled to, less
administrative fees assessed by Broadridge. To avoid duplicate claims, Adviser does not file
securities class action claims for those clients where the custodian already files on the
client’s behalf. Furthermore, Adviser does not file securities class action claims for those
clients who have requested to opt-out of the service.
Item 18 – Financial Information
impairs
Registered investment advisers are required in this Item to provide you with specific
financial information or disclosures about Adviser’s financial condition if that financial
condition is impaired in certain respects. On this subject, Adviser reports that it has no
financial commitment that
its ability to meet contractual and fiduciary
commitments to clients, and Adviser has never been the subject of a bankruptcy
proceeding.
22
Item 1 – Cover Page
Daniel F. Dent
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Daniel F. Dent that supplements
the D.F. Dent and Company Brochure. You should have received a copy of that Brochure.
Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not
receive D.F. Dent and Company’s Brochure or if you have any questions about the contents
of this Brochure Supplement.
Additional information about Daniel F. Dent is available on the SEC’s website at
www.adviserinfo.sec.gov.
23
Item 2 – Educational Background and Business Experience
Daniel Forbes Dent
Born - 1941
Princeton University – A.B.; Wharton Graduate School, University of Pennsylvania – M.B.A.
Chartered Financial Analyst (CFA)
Chairman, Portfolio Manager, and Investment Adviser – D.F. Dent and Company, Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted
in the United States and
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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
24
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person is not actively engaged in other business or investment-related
activities.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
25
Item 1 – Cover Page
Thomas F. O’Neil
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Thomas F. O’Neil that supplements
the D.F. Dent and Company Brochure. You should have received a copy of that Brochure.
Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not
receive D.F. Dent and Company’s Brochure or if you have any questions about the contents
of this Brochure Supplement.
Additional information about Thomas F. O’Neil is available on the SEC’s website at
www.adviserinfo.sec.gov.
26
Item 2 – Educational Background and Business Experience
Thomas Francis O’Neil
Born - 1946
Georgetown University – B.S.; B.A., Columbia University Graduate School – M.B.A.
Chartered Financial Analyst (CFA)
Portfolio Manager and Investment Adviser – D.F. Dent and Company, Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
in the United States and
marks") are professional certification marks granted
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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
27
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including Trustee Emeritus – Jemicy School; Vice President – The O’Neil Family
Foundation.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
28
Item 1 – Cover Page
Linda W. McCleary
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides
information about Linda W. McCleary that
supplements the D.F. Dent and Company Brochure. You should have received a copy of
that Brochure. Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if
you did not receive D.F. Dent and Company’s Brochure or if you have any questions about
the contents of this Brochure Supplement.
Additional information about Linda W. McCleary is available on the SEC’s website at
www.adviserinfo.sec.gov.
29
Item 2 – Educational Background and Business Experience
Linda Watson McCleary
Born - 1949
Smith College – A.B.; Loyola College – M.B.A.
Portfolio Manager and Investment Adviser – D.F. Dent and Co., Inc.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including Vice President and Treasurer– The Middendorf Foundation.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
30
Item 1 – Cover Page
Matthew F. Dent
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Matthew F. Dent that supplements
the D.F. Dent and Company Brochure. You should have received a copy of that Brochure.
Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not
receive D.F. Dent and Company’s Brochure or if you have any questions about the contents
of this Brochure Supplement.
Additional information about Matthew F. Dent is available on the SEC’s website at
www.adviserinfo.sec.gov.
31
Item 2 – Educational Background and Business Experience
Matthew Forbes Dent
Born - 1974
Brown University – A.B.
Chartered Financial Analyst (CFA)
Investment Banking Analyst – Deutsche Bank; Research Associate - Robertson Stephens;
Research Analyst – Camp Six, Inc.; Research Analyst – Stafford Capital;
President, Portfolio Manager, and Investment Adviser – D.F. Dent and Co., Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted
in the United States and
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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.
32
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including Trustee - Cristo Rey Jesuit High School; Member- Roland Park Country
School Finance Committee.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
33
Item 1 – Cover Page
Michael N. Morrill
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides
information about Michael N. Morrill that
supplements the D.F. Dent and Company Brochure. You should have received a copy of
that Brochure. Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if
you did not receive D.F. Dent and Company’s Brochure or if you have any questions about
the contents of this Brochure Supplement.
Additional information about Michael N. Morrill is available on the SEC’s website at
www.adviserinfo.sec.gov.
34
Item 2 – Educational Background and Business Experience
Michael Norris Morrill
Born - 1965
Johns Hopkins University – B.A.
Institutional Sales – DB Alex Brown; Institutional Sales – Wachovia Capital Markets;
Head of Client Relations and Marketing, Portfolio Manager, and Investment Adviser – D.F.
Dent and Co., Inc.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including Board Member - Baltimore Chesapeake Bay Outward Bound School.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
35
Item 1 – Cover Page
Gary D. Mitchell
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Gary D. Mitchell that supplements
the D.F. Dent and Company Brochure. You should have received a copy of that Brochure.
Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not
receive D.F. Dent and Company’s Brochure or if you have any questions about the contents
of this Brochure Supplement.
Additional information about Gary D. Mitchell is available on the SEC’s website at
www.adviserinfo.sec.gov.
36
Item 2 – Educational Background and Business Experience
Gary David Mitchell
Born - 1966
Harvard College – A.B.; Harvard Law School – J.D.
Corporate Counsel – Lucent Technologies Inc.; Assistant General Counsel – C.R. Bard, Inc.;
Portfolio Manager and Investment Adviser – D.F. Dent and Co., Inc.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including Secretary, Board of Trustees - Harvard Club of Maryland.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
37
Item 1 – Cover Page
Bruce L. Kennedy
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides
information about Bruce L. Kennedy that
supplements the D.F. Dent and Company Brochure. You should have received a copy of
that Brochure. Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if
you did not receive D.F. Dent and Company’s Brochure or if you have any questions about
the contents of this Brochure Supplement.
Additional information about Bruce L. Kennedy is available on the SEC’s website at
www.adviserinfo.sec.gov.
38
Item 2 – Educational Background and Business Experience
Bruce Lee Kennedy, II
Born - 1977
Dartmouth College – B.A.; Stanford University – M.B.A.
Chartered Financial Analyst (CFA)
Investment Banking Analyst – Goldman Sachs; Investment Analyst Intern – Wasatch
Advisers; and Associate Analyst – T. Rowe Price;
Portfolio Manager– D.F. Dent and Co., Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted
in the United States and
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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.
39
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person is not actively engaged in other business or investment-related
activities.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
40
Item 1 – Cover Page
Gary Wu
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Gary Wu that supplements the D.F.
Dent and Company Brochure. You should have received a copy of that Brochure. Please
contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not receive
D.F. Dent and Company’s Brochure or if you have any questions about the contents of this
Brochure Supplement.
information about Gary Wu
is available on
the SEC’s website at
Additional
www.adviserinfo.sec.gov.
41
Item 2 – Educational Background and Business Experience
Gary Wu
Born - 1969
Peking University Medical School – B.M.; Columbia University – Ph.D. in Molecular Biology
Chartered Financial Analyst (CFA)
Management Consultant – Mars & Co. Consulting; Investment Banking Associate – Legg
Mason Wood Walker; Securities Analyst and Co-Portfolio Manager – Legg Mason Capital
Management; and Senior Vice President – BDT Capital Partners;
Chief Risk Officer and Portfolio Manager – D.F. Dent and Co., Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted
in the United States and
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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.
42
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person is not actively engaged in other business or investment-related
activities.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
43
Item 1 – Cover Page
Noelle Savage
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
This Brochure Supplement provides information about Noelle Savage that supplements
the D.F. Dent and Company Brochure. You should have received a copy of that Brochure.
Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if you did not
receive D.F. Dent and Company’s Brochure or if you have any questions about the contents
of this Brochure Supplement.
Additional information about Noelle Savage is available on the SEC’s website at
www.adviserinfo.sec.gov.
44
Item 2 – Educational Background and Business Experience
Noelle Savage
Born - 1980
Washington and Lee University – B.S.
Chartered Financial Analyst (CFA)
Equity Research Analyst – Legg Mason Capital Management; Managing Director – Atlas
Diligence; President and Co-Founder – Skipjack Global Capital Management;
Client Relationship Manager, Portfolio Manager, and Investment Adviser– D.F. Dent and Co.,
Inc.
The Chartered Financial Analyst (CFA®) and Certification Mark (collectively, the "CFA
marks") are professional certification marks granted
in the United States and
internationally by the CFA Institute.
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 90,000 CFA charter holders working in 135 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 charter
holders 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 charter holders-
often making the charter a prerequisite for employment.
Additionally, regulatory bodies in 19 countries 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.
45
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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related
activities including President-Elect– Baltimore CFA Society.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
46
Item 1 – Cover Page
Christina Walters
th
D.F. Dent and Company, Inc.
400 East Pratt Street, 7
Floor Baltimore, MD 21202
410-837-2544
March 31, 2025
information about Christina Walters
This Brochure Supplement provides
that
supplements the D.F. Dent and Company Brochure. You should have received a copy of
that Brochure. Please contact Compliance at (410) 837-2544 or compliance@dfdent.com if
you did not receive D.F. Dent and Company’s Brochure or if you have any questions about
the contents of this Brochure Supplement.
Additional information about Christina Walters is available on the SEC’s website at
www.adviserinfo.sec.gov.
47
Item 2 – Educational Background and Business Experience
Christina Walters
Born - 1970
Slippery Rock University – B.S.
Certified Financial Planner (CFP®)
Investment Adviser Certified Compliance Professional (IACCP®)
Chief Compliance Officer – Croft-Leominster, Inc.; Credit Analyst- Orix Credit Analyst
Private Client Relationship Manager, Compliance Officer, and Investment Adviser– D.F.
Dent and Co., Inc.
®
®
®
Christina Walters is certified for financial planning services in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, Christina Walters may
refer
to herself as a CERTIFIED FINANCIAL PLANNER™ professional or a
®
CFP
professional, and Christina Walters may use these and CFP Board’s other certification
certification is voluntary. No
marks (the “CFP Board Certification Marks”). The CFP
certification.
federal or state law or regulation requires financial planners to hold the CFP
certification at www.cfp.net.
You may find more information about the CFP
®
®
professionals have met CFP Board’s high standards for education, examination,
professional, an individual must fulfill the
CFP
experience, and ethics. To become a CFP
Education
following requirements:
– 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
Examination
other qualifying credentials.
®
– 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
Experience
planning knowledge in the context of real-life financial planning situations.
Fitness Standards for Candidates for CFP® Certification
– Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets
and Former
Ethics
additional requirements.
CFP® Professionals Seeking Reinstatement
– Satisfy the
®
and agree to be bound by 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
48
Board Certification Marks:
Code and Standards
Ethics
– Commit to complying with CFP Board’s
®
®
Education
. 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
Continuing
fiduciary obligation to the client.
– 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.
Item 3 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. No information is applicable to this Item.
Item 4 – Other Business Activities
Adviser has no supervised or management persons registered, or pending registration, as a
broker-dealer or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person
of the foregoing entities.
Supervised person may be actively engaged in other business or investment-related activities
including Member, Mount Washington Pediatric Hospital Horizon Society Council.
Item 5 – Additional Compensation
Adviser has no supervised or management persons who receive an economic benefit from
any entity other than a client for providing advisory services.
Item 6 – Supervision
Adviser’s President (Matthew F. Dent) and its Chairman (Daniel F. Dent) supervise all
Adviser portfolio managers/analysts. In addition, the Adviser’s CCO (Carolyn E. Gaynor)
supervises all portfolio managers/analysts, including Matthew Dent and Daniel Dent, with
respect to regulatory compliance and compliance with Adviser’s policies and procedures.
Finally, Apex Group, Ltd. supervises the Funds’ portfolio managers, including Matthew Dent
and Daniel Dent, in its capacity as the CCO of the DF Dent mutual funds. Adviser personnel
mentioned above can be reached at 410-837-2544.
49