PROVIDENT INVESTMENT MANAGEMENT, INC.

SEC Disclosure Brochure Provident Investment Management, Inc. 39555 Orchard Hill Place, Suite 139 Novi, MI 48375 Tel. 248-380-1700 www.investprovident.com info@investprovident.com This brochure provides information about the qualifications and business practices of Provident Investment Management, Inc. If you have any questions about the contents of this brochure, please contact us at: 248- 380-1700, or by email at: info@investprovident.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Provident Investment Management, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. Filed with the SEC on March 28, 2025 Provident Investment Management, Inc.  Material Changes Annual Update The U.S. Securities and Exchange Commission issued a final rule in July 2010 requiring investment advisors to provide a brochure in narrative “plain English” format. The new final rule specifies mandatory sections and organization. This brochure will be updated annually or when material changes occur since the previous release of our SEC brochure. Material Changes since the Last Update • None. Full Brochure Available Whenever you would like to receive a complete copy of our SEC brochure, please contact us at 248-380-1700 or by email at: info@investprovident.com. Provident Investment Management, Inc.  Table of Contents Material Changes............................................................................................................ i Annual Update ............................................................................................................ i Material Changes since the Last Update .................................................................... i Full Brochure Available ............................................................................................... i Advisory Business ........................................................................................................ 1 Firm Description ......................................................................................................... 1 Principal Owners ........................................................................................................ 1 Fees and Compensation ............................................................................................... 2 Description ................................................................................................................. 2 Fee Billing .................................................................................................................. 2 Termination of Agreement ......................................................................................... 2 Disclosures Regarding Employer-Sponsored Retirement Plans and IRAs ................ 3 Types of Clients............................................................................................................. 4 Description ................................................................................................................. 4 Conditions for Managing Accounts ............................................................................ 4 Methods of Analysis, Investment Strategies and Risk of Loss ................................. 5 Methods of Analysis ................................................................................................... 5 Investment Strategies ................................................................................................ 5 Risk of Loss ............................................................................................................... 6 Disciplinary Information ............................................................................................... 7 Other Financial Industry Activities and Affiliations ................................................... 7 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................... 8 Code of Ethics............................................................................................................ 8 Participation or Interest in Client Transactions ........................................................... 8 Personal Trading........................................................................................................ 8 Brokerage Practices ...................................................................................................... 9 Selecting Brokerage Firms ......................................................................................... 9 Order Aggregation ................................................................................................... 10 Internal Crossing of Client Orders ............................................................................ 10 Review of Accounts .................................................................................................... 11 Periodic Reviews ..................................................................................................... 11 TOC 1 Provident Investment Management, Inc.  Review Triggers ....................................................................................................... 11 Regular Reports ....................................................................................................... 11 Client Referrals and Other Compensation ................................................................ 12 Incoming Referrals ................................................................................................... 12 Referrals Out ........................................................................................................... 12 Other Compensation ................................................................................................ 12 Custody ........................................................................................................................ 13 Account Statements ................................................................................................. 13 Investment Discretion ................................................................................................. 13 Discretionary Authority for Trading ........................................................................... 13 Voting Client Securities .............................................................................................. 14 Proxy Votes ............................................................................................................. 14 Financial Information .................................................................................................. 14 Financial Condition .................................................................................................. 14 Business Continuity Plan ........................................................................................... 14 General .................................................................................................................... 14 Disasters .................................................................................................................. 14 Alternate Offices ...................................................................................................... 14 Steps Clients Need to Take ..................................................................................... 14 Information Security Program .................................................................................... 15 Information Security ................................................................................................. 15 Privacy Notice .......................................................................................................... 15 Brochure Supplement ................................................................................................. 16 Education and Business Standards ......................................................................... 16 Professional Certifications ....................................................................................... 16 About Scott D. Horsburgh, CFA ............................................................................... 17 About Daniel J. Boyle, CFA ..................................................................................... 17 About Miles G. Putnam, CFA .................................................................................. 18 About James M. Skubik, CFA .................................................................................. 18 About Eric Wathen, CFA…………………………………………………………………..19 TOC 2 Provident Investment Management, Inc.  Advisory Business Firm Description Provident Investment Management, Inc. is a money management firm founded in 1981. We specialize in managing portfolios of individual securities that we have researched ourselves. Our goal is the growth of client portfolios and improved investment performance. We aim to “beat the market.” Investments may include: growth equities (stocks), dividend equities, corporate debt securities, municipal securities, mutual funds, exchange-traded funds (ETFs) and U.S. government securities. Growth stock portfolios are structured to emphasize companies with above- average long-term earnings growth potential, while attempting to keep risk commensurate with the overall stock market. Dividend equities prioritize return of capital to shareholders through dividends, share buybacks, and debt reduction. Fixed income investments are utilized as necessary to meet client needs for income or a lower risk profile. Pursuing these goals limits the degree to which a stock portfolio is tailored to each client. Prospective clients of Provident Investment Management will be offered a complimentary discussion and broad review of their personal circumstances in order to understand whether our firm is an appropriate fit for them. Together with the client, we will determine the investment objectives that govern the assets we are to manage. Upon establishing a new client relationship, we will review the securities entrusted to our management and make such changes as we deem appropriate in keeping with client objectives. We review accounts on a continuous basis and make such changes as we judge desirable on a discretionary basis, unless otherwise agreed to with the client. Clients have the right to place reasonable restrictions on the management of their accounts (e.g., no manufacturers of tobacco or alcohol). We write articles and reports about investments that are featured in unaffiliated publications. Provident is compensated for this work. Provident recommends a large national brokerage firm as custodian of client assets, but Provident itself does not act as custodian. Clients always maintain control over their own accounts. Provident manages client portfolios under a limited power of attorney that does not include the power to withdraw funds. As of December 31, 2024, Provident Investment Management managed approximately $1.23 billion in assets for 349 clients. Approximately $1.1 billion is managed on a discretionary basis, and $101 million is managed on a non- discretionary basis. Principal Owners Provident Investment Management, Inc. is organized as a Corporation. Scott Horsburgh, Daniel Boyle, Miles Putnam, and James Skubik are its only shareholders. - 1 - Provident Investment Management, Inc.  Fees and Compensation Investment Management Fees Investment management fees are billed quarterly, in advance, meaning that we invoice clients as the three-month billing period begins. We request, but do not require, that fees be deducted from investment accounts. Doing so facilitates the reporting of performance net of fees and also reduces the accounts receivable burden on our staff. Clients give their written consent in advance to direct payment from their investment accounts, and this election can be changed at any time by notifying Provident Investment Management. Management fees are based on combined market value (as stated on the quarterly appraisal) of accounts under one household as follows: 1.0% per year of the first $1 million 0.8% of the amount from $1 million to $3 million 0.7% of the amount from $3-$5 million, and 0.6% of the amount over $5 million. Clients with Provident prior to the effective date of Department of Labor Rule Prohibited Transaction Exemption 2020-02 on July 1, 2022 are afforded a lower fee on the fixed income portion of their portfolio. These clients are “grandfathered” under this prior schedule. Termination Beyond a minimum commitment of ninety days, our relationship may be canceled on thirty days written notice by either party. In the event that an investment management relationship is terminated before the next billing cycle, a prorated portion of unused fees will be refunded by us within 30 days. Services are deemed to have been provided for the month that includes the notice of termination, but no further even if minor services (reporting, facilitating transfers) are performed. Unused fees are calculated on the basis of entire months rather than days. Other Considerations There are some circumstances in which we will use mutual funds and/or exchange traded funds (ETFs). Clients should be aware that investing in mutual funds and EFTs involves paying expenses to the fund as well as our management fee. If an account grows to a size which makes investing in individual securities practical, we make every effort to convert the portfolio from mutual funds and ETFs to individual securities. Fees are negotiable for client relationships of $10 million or more. - 2 - Provident Investment Management, Inc.  Disclosures Regarding Employer-Sponsored Retirement Accounts and IRAs Department of Labor Prohibited Transaction Exemption 2020-02 requires that when providing investment advice regarding your employer-sponsored retirement plan account, we acknowledge that we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, a law governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: investment • Meet a professional standard of care when making recommendations (give prudent advice); financial interests ahead of yours when making • Never put our recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about potential conflicts of interest which are discussed on pages 3, 8, 9, and 13 of this document. We are required to provide a written analysis when a client or prospective client is considering rolling over a workplace retirement account to an IRA under Provident’s management. Clients considering doing so are advised that Provident has an economic incentive and corresponding conflict of interest to recommend its own investment management services compared to the option of remaining in the employer-sponsored retirement plan. Clients and prospective clients considering retaining Provident’s investment management services for other types of retirement accounts (including IRAs, Roth IRAs, SEP IRAs and SIMPLE IRAs) should also be aware of Provident’s status as fiduciaries along with the potential conflicts of interest found on pages 3, 8, 9, and 13 of this document. Performance-based Fees No personnel of Provident Investment Management receive compensation for the sale of securities or other investment products, such as commissions for selling mutual funds or annuities. - 3 - Provident Investment Management, Inc.  Types of Clients Description Provident Investment Management provides investment advice to individuals, trusts, estates, pension and profit sharing plans, charitable organizations, partnerships, corporations, business entities, and private investment funds. We provide an additional service known as Pontera for accounts not directly held at Schwab, but where we do have discretion, and may leverage an Order Management System to implement investment strategies on behalf of the client. These are primarily 401(k) accounts, HSAs, and other assets generally held in accounts away from Schwab. Investment decisions are made the same way as with clients’ other accounts which are held at Schwab, but implementation differs because of the separation of custodians. Provident has less control over trade execution for these accounts, and prices paid for securities purchased and received for securities sold may be less favorable than at Schwab. Investment management fees for managed held-away accounts, such as 401(k)s, cannot be billed to those accounts and will instead be assigned to the client’s taxable accounts. If the client does not have a taxable account, those fees will be billed directly to the client. Any agreements with clients cannot be transferred to another party without written client consent. Conditions for Managing Accounts Our minimum account size is $500,000. The minimum is applied to all the assets managed for a particular household added together, not on an account-by- account basis. This minimum and other account policies may be waived when, in the judgment of Provident Investment Management, there are valid reasons for doing so. By entering into an investment relationship with Provident, clients agree to our use of the services of Chicago Clearing Corp. (CCC) to process class-action securities litigation claims, if any. CCC monitors litigation, collects the applicable documents, files the appropriate claim form, interacts with the administrators, and distributes awards to clients. It charges a 15% contingency fee which is subtracted when an award is paid. Provident does not receive any money from CCC, and there is no relationship between the firms except as described herein. We conducted due diligence on CCC, including interviews with investment firms that have used its services for as long as a decade. An annual audit of the effectiveness of CCC’s policies, including data security, is conducted by Plante Moran, one of the 15 largest accounting firms in the U.S. - 4 - Provident Investment Management, Inc.  Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis Provident Investment Management’s method of securities analysis is known as fundamental analysis. Our primary sources of information include annual reports, company press releases, conference calls with management, and filings with the Securities and Exchange Commission. Investment Strategies Provident’s growth equity management strategy involves the pursuit of sustained growth in earnings per share at a reasonable share price. Our strategy is further identified as a “bottom up” approach that begins with a deep assessment of each company’s operations from a financial point of view. Annual reports, quarterly earnings announcements, conference calls, and filings with the Securities and Exchange Commission are reviewed to look for companies with characteristics of growth, quality, and, when investing for income, dividend policy. Appealing companies are monitored for a period of time as we learn their individual characteristics. Companies that are most appealing, and that are available at what we deem to be a reasonable price, are considered for inclusion in client portfolios. Diversification of the portfolio by economic sector and by company size is also considered when crafting portfolios. Decisions to sell can be made for considerations such as weakening growth prospects, attainment of price objectives, or the emergence of an investment opportunity with more favorable prospects. Fixed income investments are made using an approach of “laddered” maturities of high-quality taxable or tax-exempt securities as appropriate. Laddered portfolios consist of bonds with maturities spread across the desired range of typically no more than ten years. Laddering can help stabilize clients; investment income while also reducing the risk that many bonds might mature at a time when there are few desirable investment opportunities. Provident periodically employs what we call “fixed income alternatives.” These can consist of fixed income mutual funds or Exchange Traded Funds (ETFs) used as “placeholders” as we identify individual bonds for purchase. We may also invest in income-oriented securities such as Real Estate Investment Trusts (REITs) or Limited Partnerships that lack specific maturities and generally come with higher risk than traditional bonds. Information about individual fixed income securities is obtained through offering documents available through online information repositories. We expect to hold bonds until maturity. In between growth stocks and bonds, our “Dividend Total Return strategy” (“DTR”) attempts to obtain greater returns than traditional fixed income securities with less risk than growth equities. Dividend-oriented companies are characterized by lower potential growth of sales and earnings compared to growth stocks. Under this strategy, Provident focuses on companies that we expect to offer sales growth at least as strong as growth in nominal Gross Domestic Product (GDP), about 5%. - 5 - Provident Investment Management, Inc.  Earnings per share are expected to rise at least as fast. Cash flow is usually strong and expected to remain favorable, creating opportunities for capital return through current dividends, dividend increases, and stock buybacks. We attempt to purchase these stocks at P/E ratios approximately equal to or below their historical average. We believe that investing in modest growth businesses include different investment risks, including the risk that these stocks lack sufficient growth to offset significant declines in one or more holdings. To address this risk, a greater number of securities are included in dividend portfolios. Security types employed include common stocks, convertible securities, preferred stocks, REITS, and Limited Partnerships. Risk of Loss All investment programs have certain risks that are borne by the investor. Investors may face one or more of the following investment risks: • Market Risk: The price of an equity, bond, mutual fund, or ETF may drop in response to general economic, political, and psychological factors. • Business Risk: These are the risks associated with a particular industry or a particular company within an industry. • Financial Risk: Excessive borrowing to finance a business’s operations increases risk to profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in a declining market value and even bankruptcy. This can affect the price of particular corporate bonds or stocks, or even the broader stock market. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds and high-dividend stocks may become less attractive, which typically causes their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar next year will not buy as much as a dollar today because purchasing power is eroded at the rate of inflation. • Reinvestment Risk: This is the risk that future proceeds from investments may be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. For example, Treasury Bills are highly liquid, while real estate properties are not. Under periods of extreme market duress, liquidity of most investments may be significantly reduced. Equity securities contain considerable risk of fluctuation, i.e., market risk. The stock market, as represented by the Standard & Poor’s 500, has declined in - 6 - Provident Investment Management, Inc.  seventeen of the seventy-nine years since World War II. Three of those declines were greater than 20%. There are considerable differences between Provident’s growth and dividend investment styles and any broad indicator of market performance such as the Standard & Poor’s 500. The volatility of a Provident portfolio may be materially different than that of the S&P 500 index because there are differences in portfolio structure and methodology. In particular, we emphasize economic sectors that we believe are fundamentally superior for long-term growth and may disregard others that are unappealing. This narrow targeting introduces the risk that we may focus on the wrong sectors at times. Client assets are also invested in small, mid-sized, and non-U.S. companies that are not part of the S&P 500. The fixed income investing methodology employed by Provident Investment Management attempts to moderate inevitable interest rate and inflation risk by utilizing a ladder of securities. Laddering may stabilize clients’ investment income and serve to moderate reinvestment risk by spreading maturities broadly to reduce the risk of many securities potentially maturing at the same time. Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other Financial Industry Activities and Affiliations Financial Industry Activities and Affiliations None - 7 - Provident Investment Management, Inc.  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics to keep our clients’ information and Provident Investment Management employees must adhere to a Code of Ethics and are required to sign an annual compliance statement to that effect. The basis of our Code of Ethics is that all employees of the company have a fiduciary duty to place the interest of clients ahead of their own and the company’s. For example, employees must give priority to investment opportunities for clients first before considering taking similar action for their own accounts. Employees have a responsibility investment activities confidential. A system of reporting is maintained in order to monitor compliance with this Code of Ethics. A copy of the Code is available upon request. Participation or Interest in Client Transactions Provident Investment Management, Inc. does not, as a principal, sell securities to or buy securities from investment advisory clients or others, nor does it effect securities transactions for compensation as a broker or agent. Personal Trading The owners, associates, and employees of Provident Investment Management, Inc. may buy, hold, or sell the same securities that are being recommended for purchase, retention, or sale by clients. This can present a conflict of interest. We manage this conflict by adopting the relevant part of the Standards of Professional Conduct of the CFA Institute which prohibits investment decision-making personnel from trading before clients. We employ trading “blackout” periods during which members of our Investment Committee are prohibited from trading most securities. Non-discretionary clients are given three business days to respond to investment recommendations before Provident employees are considered free to act on investment recommendations in their own accounts. Deviations from this three-day waiting period require written approval from the Chief Compliance Officer (CCO). The CCO may lengthen this waiting period at his discretion. PRIORITY OF TRANSACTIONS “The Chartered Financial Analyst shall conduct himself in such a manner that transactions for his customers, clients and employer have priority over personal transactions, do not operate adversely to their interests and that he act with impartiality with respect to customers and clients. Thus, if an analyst has decided to make a recommendation as to the purchase or sale of a security, he shall give his customers, clients and employer adequate opportunity to act on such recommendations before acting on his own behalf.” Statements of activity for investment decision-making personnel are reported and reviewed quarterly for such compliance. - 8 - Provident Investment Management, Inc.  Brokerage Practices Selecting Brokerage Firms Provident Investment Management utilizes the brokerage and custodial services of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member SIPC, as our preferred custodian. Schwab is an independent broker-dealer and is not affiliated with Provident. Directing trading activities through one firm may leave us unable to achieve the most favorable execution of client transactions, which could cost clients money. Schwab offers independent registered investment advisors services which include custody of securities, trade execution, and clearance and settlement of transactions. Advisors such as Provident Investment Management receive certain benefits from our clients’ custodian. Clients and prospective clients should understand that Schwab provides Provident with account monitoring software and materials related to investment research. Such research may include general market commentary, market strategies, and advice on managing an investment advisory business. This research may benefit other clients regardless of the amount of assets we manage for them. The research and services received by Provident could represent a conflict of interest that causes us to recommend clients use the services of Schwab. It is the policy of Provident Investment Management that clients may choose their own broker/custodian if their invested assets are at least $10 million. Clients who do so accept that the timing and cost of transactions will differ, perhaps materially, from transactions executed at our preferred brokerage firm. Not all investment advisors place restrictions on their clients’ ability to direct brokerage and custody. Provident Investment Management may request that clients authorize us to utilize the services of other broker-dealer firms. In recent years, this has only affected our fixed income trading. Because fixed income securities are traded through dealers and not in a central market, it is advantageous to seek out the best opportunities through multiple vendors, including a client’s primary broker and custodian. Custodians charge additional fees for trades not placed through their own brokerage division, and these are paid by clients as part of their transaction costs. - 9 - Provident Investment Management, Inc.  Order Aggregation It is Provident Investment Management’s policy to aggregate client orders for the same security and trade them as a block. This policy helps Provident fulfill its duty to treat all clients fairly and to seek best execution for its clients. Provident plans each trade to include clients for whom the proposed action is appropriate. The individual client orders are aggregated and traded as one block. The completed trades are then allocated to the participating clients, each one receiving the same average price. When the entire block is not completed in one day, Provident follows its Block Trade Allocation policy. Under this policy, the order of allocation is determined by starting with client surnames beginning with a randomly selected letter of the alphabet. Internal Crossing of Client Orders When clients need to sell bonds, we obtain purchase offers in the market, but we may also request an “internal cross price.” The internal cross price is a price in between a bond dealer’s buy price and sell price. Internal cross prices are higher than the price to sell the bond in the market and would therefore be advantageous to our client who needs to sell. If it is also the best opportunity for a client or clients with money to invest in bonds, we will consider having one client sell the bond to another client at the internal cross price. We believe this action is consistent with an investment advisor’s duty to seek out the best execution for clients. - 10 - Provident Investment Management, Inc.  Review of Accounts Periodic Reviews Provident Investment Management believes that the holdings in client accounts are under continuous review rather than being reviewed on a fixed, periodic basis. Accounts are managed by our investment team and are not specifically assigned to any particular associate. Industry regulators require us to inform clients that our services are performed for all Provident clients and are not exclusive to any one client. Review Triggers Reviews of assets and client portfolios may be triggered by factors unique to a security, changes in a client’s own situation, or new tax or investment considerations. All assets are periodically reviewed in terms of the characteristics for which they were purchased. Any material deviation from expected value is discussed by the investment team at Provident Investment Management, and an appropriate conclusion is reached with respect to the holdings in each account. Suitable replacements are selected if an issue is sold and an immediate reinvestment of the proceeds is deemed appropriate. Regular Reports Provident Investment Management provides each client with a currently priced account statement no less frequently than quarterly. This is transmitted to the client by a personal letter discussing portfolio changes during the past quarter and their relevance to client objectives. When appropriate, tables and charts helpful to the client’s understanding of the status and progress of the account may be included. The broker-custodian sends each client prompt trade confirmations, monthly statements, and an annual report of income and capital gains for income tax purposes. Clients are urged to compare the custodian’s statements with those received from Provident. Each client receives Provident Investment Management’s monthly “Investment Comments.” This sets forth our view of the economy and securities markets. - 11 - Provident Investment Management, Inc.  Client Referrals and Other Compensation Incoming Referrals From time to time, Provident Investment Management has entered into marketing arrangements with third parties who receive compensation for referring prospective clients to Provident. Each such marketing arrangement is governed by a written agreement between Provident and the third party in compliance with SEC Rule 206(4)-3. Clients referred to Provident under such an arrangement will be provided with copies of Provident Investment Management’s regulatory brochure, a separate disclosure of the nature of the marketing or referral arrangement, and any other document required by law. Any referral fees paid by Provident to these third parties will not be passed on to, or paid by, the client. Referrals Out Provident Investment Management does not accept referral fees or any form of compensation from other professionals to whom we refer a prospect or client. Other Compensation The only compensation Provident Investment Management receives for providing investment management services to clients is the fee paid by the client. We receive no fees, commissions or profit sharing from anyone else. - 12 - Provident Investment Management, Inc.  Custody Account Statements All assets are held by qualified custodians. The custodian mails account statements directly to clients at their address of record on a monthly basis. Clients may instead elect to receive monthly statements by email. Provident Investment Management provides quarterly statements that accompany each client’s quarterly review letter. Clients are urged to compare the custodian’s statements with those received from Provident. Provident does not have “custody” of client funds under the legal definition because it follows the safeguard procedures regarding deduction of client fees, forwarding of third-party checks within three business days, and prompt return of any securities delivered or checks improperly made out to Provident rather than the custodian. Provident will facilitate client requests to obtain money out of their brokerage accounts either on a recurring or periodic basis, and whether by check, wire, or through Automated Clearing House (ACH) transfers to their bank. When a client requests transfers to a bank account not already on file, Provident personnel must call the client at a number already known to us prior to accepting the request. Investment Discretion Discretionary Authority for Trading Provident Investment Management accepts discretionary authority to manage securities accounts on behalf of clients. Provident has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. Clients grant discretionary trading authority to Provident by executing the broker/custodian’s limited power of attorney. This limited power of attorney is restricted to trading authority and does not permit withdrawal of client funds. Provident occasionally accepts non- discretionary accounts, but non-discretionary clients bear the risk that trading priority may be given to discretionary clients. Provident Investment Management, Inc. does not maintain any investment monitoring or performance responsibility for assets and/or accounts designated as unmanaged or “memo.” The client and/or its other investment professionals retain exclusive responsibility for the monitoring and performance of such assets and/or accounts. Provident does not charge a fee on such assets. Voting Client Securities Proxy Votes Except for one institutional client, Provident Investment Management does not vote proxies on securities. The custodian provides clients with proxy voting - 13 - Provident Investment Management, Inc.  materials. When assistance on voting proxies is requested, Provident may provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. In the case of the one institutional client, proxy voting decisions are made by the analyst following the stock and will be reported to the client upon request. Financial Information Financial Condition Provident Investment Management does not have any financial impairment that would preclude the firm from meeting commitments to clients. Business Continuity Plan General Provident Investment Management has a Business Continuity Plan in place that provides detailed steps to maintain our ability to serve clients in the event of a disruption in our business. Disasters The Disaster Recovery Plan covers natural disasters and other risks such as the loss of electrical, telephone or internet connectivity. Critical data is backed up continuously in the cloud. Alternate Offices Alternate space is available to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location. Steps Clients Need to Take In the event that communications between Provident Investment Management and its clients are interrupted other than temporarily, clients need to note the following procedures: • Telephone communications will be re-established through our toll-free number, 800-449-6970. • Clients will be contacted within five business days, if possible. • The offices of our clients’ broker/custodian will serve as our last emergency point of communication. Contact Schwab at 800-435-4000 or ask for assistance through any Schwab branch office. - 14 - Provident Investment Management, Inc.  Information Security Program Information Security Appropriate data security software and procedures are maintained in order to safeguard clients’ personal data. Privacy Notice In the course of managing portfolios, we acquire personal information about our clients such as name, Social Security number, and assets owned. It is the policy of Provident Investment Management, Inc. not to disclose information about any client to any third party for any purpose. This policy operates automatically for all clients and does not have to be requested. However, if a client specifically requests, we will send information to a third party such as an attorney or accountant. All client information is maintained in a secure environment and is shredded or otherwise destroyed when no longer needed. We may also be required to divulge personal information in response to orders issued by the court or other governmental bodies, including routine investment advisor examinations conducted by our regulator, the Securities and Exchange Commission. It is Provident’s policy to comply with such orders. We will disclose these orders and our response to an affected client, except in the case of SEC examinations which are intended to test Provident’s business practices and are not directed toward any particular client. We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing. - 15 - Provident Investment Management, Inc.  Brochure Supplement General This brochure supplement provides information about Scott Horsburgh, Daniel Boyle, Miles Putnam, James Skubik, and Eric Wathen to supplement the Provident Investment Management brochure. Education and Business Standards Investment Management, Inc. requires that senior investment Provident management personnel possess a bachelor's degree and sufficient experience and certification to demonstrate knowledge of securities analysis and portfolio management. Professional Certifications Chartered Financial Analyst (CFA): Chartered Financial Analysts are licensed by the CFA Institute to use the CFA mark. CFA certification requirements: • Hold a bachelor's degree from an accredited institution or have equivalent education or work experience. • Successfully complete all three exam levels of the CFA Program. • Have 48 months of acceptable professional work experience in the investment decision-making process. • Fulfill society requirements, which vary by society. Unless upgrading from affiliate membership, all societies require two sponsor statements as part of each application; these are submitted online by a candidate’s sponsors. • Agree to adhere to and sign the Member's Agreement, a Professional Conduct Statement, and any additional documentation requested by CFA Institute. - 16 - Provident Investment Management, Inc.  SCOTT D. HORSBURGH, CFA President Personal: • Born 1965 Educational Background: • B.A., Economics, Hillsdale College (1986) Professional Certification: • Chartered Financial Analyst (1990) Business Experience: • Provident Investment Management, Inc. (1992 – present) • NBD Bancorp, Inc. (1986-1992) Disciplinary Information: none Other Business Activities: none Additional Compensation: none Supervision: Scott Horsburgh supervises the work of Daniel Boyle, Miles Putnam, James Skubik, and Erik Wathen. DANIEL J. BOYLE, CFA Senior Vice President Personal: • Born 1964 Educational Background: • M.B.A., University of Michigan (1991) • B.A., Economics, University of Michigan (1985) Professional Certification: • Chartered Financial Analyst (2001) Business Experience: • Provident Investment Management, Inc. (2004 – present) • White Pines Ventures, LLC (1997-2004) • Fame Information Services, Inc. (1984-1987, 1992-1997) • Chrysler Corporation (1987-1992) Disciplinary Information: none Other Business Activities: none Additional Compensation: none Supervision: Dan Boyle is supervised by Scott Horsburgh, President. Scott Horsburgh’s contact information is: 248-380-1700 or ScottH@investprovident.com - 17 - Provident Investment Management, Inc.  MILES G. PUTNAM, CFA Vice President Personal: • Born 1982 Educational Background: • M.S.I., University of Michigan (2009) • B.A., Economics, University of Michigan (2005) Professional Certification: • Chartered Financial Analyst (2013) Business Experience: • Provident Investment Management, Inc. (2010 – present) • Fun Inc. (2006-2007) • Ocean Tomo Inc. (2005) Disciplinary Information: none Other Business Activities: none Additional Compensation: none Supervision: Miles Putnam is supervised by Scott Horsburgh, President. Scott Horsburgh’s contact information is: 248-380-1700 or ScottH@investprovident.com JAMES M. SKUBIK, CFA Senior Portfolio Manager Personal: • Born 1973 Educational Background: • M.B.A. (Finance), Case Western Reserve University (1999) • B.A., History, University of Michigan (1995) Professional Certification: • Chartered Financial Analyst (2005) Business Experience: • Provident Investment Management, Inc. (2017 – present) • Long Lake Capital Management (2015-2017) • R.H. Bluestein & Co. (2012-2015) • J.P. Morgan Securities (2003-2012) Disciplinary Information: none Other Business Activities: none Additional Compensation: none Supervision: James Skubik is supervised by Scott Horsburgh, President. Scott Horsburgh’s contact information is: 248-380-1700 or ScottH@investprovident.com - 18 - Provident Investment Management, Inc.  ERIC S. WATHEN, CFA Research Analyst Personal: • Born 1981 Educational Background: • M.B.A., Oakland University (2010) • B.A., Finance, Oakland University (2006) Professional Certification: • Chartered Financial Analyst (2013) Business Experience: • Provident Investment Management, Inc. (2023 – present) • ESW Management Services, LLC (2018-2022) • Ameriprise Financial Services, Inc. (2015-2018) • Raymond James & Associates, Inc. (2005-2015) Disciplinary Information: none Other Business Activities: none Additional Compensation: none Supervision: Eric Wathen is supervised by Scott Horsburgh, President. Scott Horsburgh’s contact information is: 248-380-1700 or ScottH@investprovident.com - 19 - Provident Investment Management, Inc.