SENTRY MANAGEMENT INC

Sentry Management, Inc Form ADV-Part 2A December 31, 2024 S E N T R Y M A N A G E M E N T, I N C . INVESTMENT ADVISERS Item 1-Cover Page Sentry Management, Inc. 5 Eureka Circle, Suite E Telephone 940/696-2100, 800/677-8606 Fax 940/696-2810 Email murphy@sentrymanagement.com Website www.sentrymanagement.com December 31, 2024 This brochure provides information about the qualifications and business practices of Sentry Management, Inc. (“Advisor”). If you have any questions about the contents of this brochure, please contact us at 940/696-2100 or email us at murphy@sentrymanagement.com . The information in this brochure has not been approved or verified by the Unites States Securities and Exchange Commission (“SEC”) or by any state securities authority. Sentry Management, Inc. is a registered investment advisor in the state of Texas. Registration of an investment advisor does not imply any level of skill or training. The oral and written communications of an Advisor provides you with information you can use in deciding whether to hire or retain an Advisor. Additional information about Sentry Management, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 2-Material Changes December 31 2024 We are required to deliver information about our qualifications and business practices to clients on account opening and at least annually thereafter. Pursuant to SEC regulations, we will ensure that you receive a summary of any material changes to this and subsequent brochures within 120 days of the close of our fiscal year, December 31st. We may further provide other ongoing disclosure information about material changes as necessary. There have been no material changes during the previous year other than Niley Church fully retiring. Our current brochure is available by contacting Murphy Davis, Sr., Chief Compliance Officer, at 940/696/2100 or Murphy@sentrymanagement.com . Additional information about Sentry Management, Inc. is also available via the SEC’s website www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with Sentry Management, Inc. who are registered, or are required to be registered as investment advisor representatives of Sentry Management, Inc. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 3-Table of Contents Form ADV Part 2A Item 1 – Cover Page Item 2 – Material Changes Item 3 – Table of Contents Item 4 – Advisory Business Item 5 – Fees and Compensation Item 6 – Performance Based Fees and Side-by-Side Management Item 7 – Types of Clients and Account Requirements Item 8 – Method of Analysis, Investment Strategies and Risk of Loss Item 9 – Disciplinary Information Item 10 – Other Financial Industry Activities and Affiliations Item 11 – Code of Ethics, Participation or interest in Client Transactions and Personal Trading Item 12 – Brokerage Practices Item 13 – Review of Accounts or Financial Plans Item 14 – Client Referrals and Other Compensation Item 15 – Custody Item 16 – Investment Discretion Item 17 – Voting Client Securities Item 18 – Financial Information Form ADV Part 2A, Appendix 1 (Wrap Fee Brochure) Sentry Management, Inc. does not participate in any Wrap Fee Programs 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 4-Advisory Business Sentry Management, Inc. (Firm) is an investment advisory firm registered with the Securities and Exchange Commission under the Investment Advisers Act of 1940. The Firm manages over $9.5 billion in assets for clients in seven states. Clients include financial institutions, trust departments, pension plans, individuals, foundations, tax-exempt agencies, municipalities and corporations. The Firm is a privately held C-Corporation with Murphy Davis, Sr. as the primary shareholder. The money managers of the Firm have over ninety-three (78) years of combined experience in direct management of fixed income portfolios and specializes in fixed income management. The range of experience includes managing money for endowment funds, employee benefit plans, banks, trust departments, universities, municipalities, corporations, and individuals. The Firm also serves as a financial advisor to municipalities in preparing official statements and structuring and financing capital debt. Initial meetings with clients are utilized to determine risk tolerance and return requirement objectives. Also discussed are the client’s time horizon, liquidity needs, tax and legal matters, and any specific or unique considerations. Special attention is given to the proper asset allocation necessary to compliment the client’s goals and constraints. An investment policy is then suggested as a guideline or plan-of-action for accomplishing the client’s objectives. The Firm’s investment philosophy is conservative and dynamic. Quality and liquidity are prerequisites for investments. A heavy emphasis is placed on yield curve and historical, sector yield analysis in determining optimum maturity and security selection. Market and economic developments are continually monitored and dictate transaction activity. Credit analysis on corporate and municipal securities is completed prior to committing funds. Fundamental and technical analysis is utilized in timing of transactions. Because of the homogeneous nature of fixed income securities, technical analysis is significantly more effective as a management tool for bonds versus equities. Meaningful support and resistance levels, trend analysis, long and short- term moving averages and divergences are used to help determine timing while yield curve and sector yield spreads help determine the type security and maturity to be purchased or sold. The Firm attempts to maximize risk-adjusted returns with reduced transaction expenses by concentrating on capturing the majority of significant market moves while maintaining a highly- liquid, high-quality portfolio. Sentry Management, Inc. has the expertise, experience, and resolve to meet the unique needs of a diverse client base seeking above-average, risk-adjusted returns from fixed income securities. The firm managed approximately $260MM in discretionary assets and $7,813MM in non-discretionary assets as of 12/31/2024 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 5-Fees and Compensation Sentry Management, Inc. fees are normally based on a percentage of assets under management or may be negotiated as a fixed fee based off services provided. On Municipal advisory, the fees are transaction based on the municipal bond issue. Clients may receive a refund on a pro-rata basis if a forward fee is paid and the contract is terminated prior to service provided. Sample fee agreements follow: 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 DISCRETIONARY LETTER OF AGREEMENT This Agreement is made, and entered into by __________________ (Client) and Sentry Management, Inc. (Manager) on this _______ day of ___________, 20__. Whereas, the Client requests the Manager to serve as Investment Manager for specifically enumerated assets in Schedule I owned by the Client. Now, therefore, it is covenanted and agreed as follows: The Client appoints and employs the Manager as investment manager for those assets itemized in Schedule I (Assets) as of this __ day of ________, 20__. The Manager is given full discretion in managing the Assets of the Client with respect to purchases, sales, exchanges, and other generally accepted actions which, in the opinion of the Manager, enhances the Assets’ total return. The Manager is specifically prohibited from directing money to be transferred out of the Client’s account. for the Client’s assets. The Assets will be held in custody for the Client at __________________. The custodian is authorized to accept instructions from the Manager in executions of transactions All assets, investments, and cash will remain with the Custodian. The Manager shall maintain separate records of each transaction executed for the Client. Additionally, the Client will be furnished a confirmation on each transaction on a timely basis. The Manager will provide a summary performance report of the Client’s assets no less frequently than quarterly. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 The fee for services described in this Agreement will be calculated from the attached Exhibit A. Fees are payable quarterly in advance, and based on the Assets’ values as of the end of the previous quarter. The Assets’ values shall be based on third party valuations and will include cash. Fees for partial quarters shall be pro-rated based on the proportion of days in the quarter for which services are provided. SMI recognizes the information received from the Client is private and for the expressed use of producing the above described reports and services and the information is not to be used by SMI for any other purposes without the expressed approval of the Client. SMI will take all reasonable actions to assure the privacy of the Client’s information, including instructions to all employees and the safeguarding and segregation of the Client’s files. This Agreement may be canceled, without penalty, within five (5) business days of the date of this Agreement’s execution. After five (5) business days, the Agreement may be canceled by the Client or Manager with thirty (30) days written notice. This Agreement may not be assigned and need not be formally renewed. ACKNOWLEDGED AND AGREED SENTRY MANAGEMENT, INC. ________________________________ By ________________________________ Date ACKNOWLEDGED AND AGREED ____________________________ By ____________________________ 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Date EXHIBIT A FEE SCHEDULE - DISCRETIONARY TAXABLE FIXED INCOME PORTFOLIOS .35% On First $ 5,000,000 .30% On Next $20,000,000 .25% On All Over $25,000,000 MUNICIPAL (TAX-FREE) PORTFOLIOS .15% On First $ 20,000,000 .10% On All Over $20,000,000 NOTE: Fees are payable quarterly, in advance. Minimum Annual Fee - $3,000. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 – SAMPLE – NON-DISCRETIONARY LETTER OF AGREEMENT This Agreement is made, and entered into, by _____________ (Client) and Sentry Management, Inc. (Manager). The Client requests the Manager perform as investment adviser to the Client and, in serving as investment adviser, the Manager agrees to provide the following: Initially, meet with Management and/or Board Members to discuss the Investment Portfolio’s (IP) credit quality, maturity distribution, risk/reward considerations, generally strong and weak points, and suggested investment action. Work with Management to develop a written investment policy and funds management policy consistent with the Client’s overall goals while considering the economic and regulatory environment. Develop a written investment strategy which will serve as a plan- of-action to implement the investment program. The written strategy will be updated at least quarterly, and more frequently as dictated by material market changes. a third-party monthly Provide computer accounting/management report for the Client’s IP. The report will include current market appraisals, accruals, and management summary schedules. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Provide a quarterly, third-party current and projected asset/liability (A/L) exposure analysis to measure potential interest rate risks (IRR). The Manager will assist the Client in interpreting and analyzing A/L or IRR reports, provide interest rate projections, assumptions, and structure the IP to compliment the A/L IRR. Execute orders (purchases and sales) for the Client only at the direction of the Client. The Client retains exclusive authority to transfer funds and/or securities. Actively develop and maintain respected and reliable sources of market information. Receive direct broker/dealer and dealer bank contact including verifying transaction figures, and serving as intermediary and facilitator on delivery problems. Continuously monitor the portfolio for appropriate Group orders, when investment opportunities. possible, to provide the Client with volume negotiating power. Analyze the Client’s financial statements, asset allocation, past and projected local economic activity and future liquidity requirements to develop an active investment strategy for taking advantage of current markets’ investment alternatives. Individual investment recommendations will be made which the Manager determined would complement the Client’s existing investments and most efficiently reach the Client’s long-term goals given current and projected market opportunities. Meet with the Client’s Management and/or Board of Directors at least annually to describe the past, present, and projected economic environment and interest rate movements in general. Also to be analyzed is previous investment activity, current status of the IP, and recommended investment action. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 The fee for the above described services is a function of the par value of the Client’s IP (See Exhibit A). The IP includes marketable securities such as Treasuries, agencies, municipals, corporates, mortgage-backed securities, and derivatives, but excludes certificates of deposit, bankers acceptances, and Federal Funds. The fee is reviewed each calendar quarter and adjusted to reflect the IP’s then current size. The initial rate of ______ per month is based on the Client’s current IP of ________. This agreement authorizes all regulatory agencies of the Client to enter the offices of Sentry Management, Inc. and inspect all records related to the Client. The visit or inspection may be with or without prior notice and does not require approval of Sentry Management, Inc. or the Client. However, any visit or inspection must be made during normal business hours of Sentry Management, Inc. between 8:00a.m. and 5:00p.m. Central Standard Time (CST). The regulatory agencies include, but are not limited to, the FDIC, OCC, Federal Reserve, and State banking regulatory agencies. Sentry Management, Inc (SMI) provides investment and asset advisory services, investment portfolio appraisal and accounting reports, and dynamic interest rate risk analysis reports for the Client. It is necessary for the Client to share certain information concerning individual investments within the investment portfolio and general balance sheet information for the interest rate risk analysis in order for SMI to process the reports and provide the services described above. SMI recognizes the information received from the Client is private and for the expressed use of producing the above described reports and services and the information is not to be used by SMI for any other purposes without the expressed approval of the Client. SMI will take all reasonable actions to assure the privacy of the Client’s information, including instructions to all employees and the safeguarding and segregation of the Client’s files. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 This Agreement may be canceled, without penalty, within five (5) business days of the date of the Agreement’s execution. After five (5) business days, the Agreement may be canceled by the Client or Manager with sixty (60) days written notice. This Agreement may not be assigned and need not be formally renewed. SENTRY MANAGEMENT, INC. Murphy Davis, Sr. __________________________ By CFA/Chairman __________________________ Date ACKNOWLEDGED AND AGREED ___________________________ By ___________________________ Date 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 EXHIBIT A NON-DISCRETIONARY FEE SCHEDULE MINIMUM - $625 MONTHLY FEE INVESTMENT PORTFOLIO FEE INCREASE PER MILLION DOLLAR INCREASE $ 10,000,000 $ 625 $20 $ 20,000,000 $ 825 $15 $ 25,000,000 $ 900 $10 $ 50,000,000 $1,150 $ 8 $100,000,000 $1,550 $ 6 INTEREST RATE RISK ANALYSIS PER ANALYSIS $ 400 NOTE: MONTHLY FEE IS ROUNDED TO NEAREST $5.00 AND ADJUSTED QUARTERLY. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 6-Performance based Fees and Side-by-Side Management Sentry Management, Inc. does not utilize any performance based fees. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 7-Type of Clients Sentry Management, Inc. provides fixed income investment advice to financial institutions, trust departments, charitable organizations, municipalities, high net-worth individuals, individuals, insurance companies and corporations. While we have a minimum fee of $3000 per year, the minimum may be negotiated on a client-by-client basis. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 8 Methods of Analysis, Investment Strategies, Risk of Loss Initial meetings with clients are utilized to determine risk tolerance and return requirement objectives. Also discussed are the client’s time horizon, liquidity needs, tax and legal matters, and any specific or unique considerations. Special attention is given to the proper asset allocation necessary to compliment the client’s goals and constraints. An investment policy is then suggested as a guideline or plan-of-action for accomplishing the client’s objectives. The Firm’s investment philosophy is conservative and dynamic. Quality and liquidity are prerequisites for investments. A heavy emphasis is placed on yield curve and historical, sector yield analysis in determining optimum maturity and security selection. Market and economic developments are continually monitored and dictate transaction activity. Credit analysis on corporate and municipal securities is completed prior to committing funds. Fundamental and technical analysis is utilized in timing of transactions. Because of the homogeneous nature of fixed income securities, technical analysis is significantly more effective as a management tool for bonds. Meaningful support and resistance levels, trend analysis, long and short-term moving averages and divergences are used to help determine timing while yield curve and sector yield spreads help determine the type security and maturity to be purchased or sold. Sentry Management, Inc. limits the fixed income investments it recommends to a minimum of investment grade securities in both discretionary and non-discretionary accounts. The majority of our assets are held by financial institutions which are limited to investments approved by bank regulators. Sentry utilizes the same guidelines for all client accounts, and recommends only fixed income securities where principal return is the highest priority. While all securities have some chance of loss due to credit conditions, Sentry attempts to minimize this risk through the selection of the highest quality assets. Clients may also experience a loss if a security is liquidated before maturity due to changes in interest rates, but all securities purchased are highly liquid. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 9 Disciplinary Information Sentry Management, Inc. has no information applicable to this item. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 10 Other Financial Industry Activities and Affiliations Sentry Management, Inc. does not have any affiliation or activities with any other companies or associations. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Sentry Management, Inc. maintains a strict code of ethics that we will ensure best execution of a client transactions and that selected securities will be appropriate for the client’s portfolio. In addition, the three advisers are prohibited from any transactions that involve securities purchased for clients in the adviser’s personal accounts. Our code of ethics is available to any client or potential client upon request. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 12 Brokerage Practices Sentry Management, Inc. currently has approximately 50 broker/dealers(B/D) on its approved broker dealer list to ensure that we execute at the best level for all clients. Sentry utilizes Bloomberg to access dealer inventories, messaging B/D groups for different types of fixed income purchases if there is a specialty such as municipals or mortgage-backed securities, searching messages for specific types of investments, and electronic execution on generic item’s such as Treasuries. Sentry uses the information we receive to ensure that we see the entire market and execute at the best level for our clients. Sentry maintains a soft-dollar agreement with Capital Institution Services (CAPIS) to provide Bloomberg terminals for execution of transactions and general economic/fixed income research. Although Sentry received soft dollar benefits for Bloomberg services and could have a conflict of interest in recommending CAPIS, Sentry applies the same standard on every transaction to put the client’s best interest first. After researching the market among all broker dealers, transactions are only executed if CAPIS ties or beats other available offers. Because we only execute with CAPIS if their offer ties or beats other brokers in competition, we do run deficits and make up any shortcomings for Bloomberg services. Bloomberg is the premier platform for fixed income research and execution, and all clients benefit from the use of the service. Sentry receives no client referrals from broker dealers. Sentry executes trades at the best level on every client transaction. Because we work with financial institutions, there may be times a client does a transaction directly with a broker dealer or instructs us to use a certain broker dealer. In those cases, Sentry cannot guarantee best execution, because we have not put all dealers in competition. Item 13 Review of Accounts 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Sentry Management, Inc. has two investment advisers that discuss client accounts on a regular basis. The advisers will also meet regularly (once to twice a month) to review all accounts’ cash positions, current strategy and any regulatory issues associated with financial institutions. Sentry is also in regular contact with clients and maintains a call/meeting list in the meetings to ensure regular client contact. Sentry provides clients with portfolio reports from Hilltop Securities on a monthly or quarterly basis which includes all information that is relevant to fixed income portfolios including but not limited to yield-to-call, yield-to-maturity, duration, weighted average life, full accrual and accretion, cash flow scenarios in a +/- 400bp rate shock and book and market values. Sentry pays Hilltop a direct fee to provide portfolio reports. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 14 Custody Sentry Management, Inc. does not have custody of any client assets. Clients chose their custodian, and Sentry’s portfolio reports are for management and informational purposes. Clients should review reports from custodians to ensure that assets held match the securities listed in the Hilltop portfolio reports. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 16 Investment Discretion Sentry Management, Inc. does accept discretionary authority on behalf of some clients. Before we accept this authority, we require a discretionary letter of agreement to provide limited trading authority. We also form an investment strategy to fit the client’s risk profile and notify the client if there is any variance from the initial strategy. Sentry never maintains custody over any client assets, and the discretion is limited to executing the strategy agreed to by the client. All bank clients have non-discretionary letters of agreement. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 17 Voting Client Securities Sentry Management, Inc. does not accept authority to vote client securities. Clients will receive proxy statements or other solicitations directly from their custodian. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Item 18 Financial Information (Not Required) 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com  Sentry Management, Inc Form ADV-Part 2A December 31, 2024 Form ADV Part 2A Appendix 1 (Wrap Fee Brochure) Sentry Management, Inc. Does not participate in any WRAP Fee agreements. 940-696-2100 5 Eureka Circle, Suite E Wichita Falls, Texas 76308 www.sentrymanagement.com 

Sentry Management, Inc. Form CRS Customer Relationship Summary 12/31/24 Introduction: Sentry Management Inc. is registered with the Securities and Exchange Commission (SEC) as an investment adviser. Brokerage and investment advisory services and fees differ and it is important for you to understand these differences. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which also provides educational materials about broker/dealers, investment advisers, and investing. Relationships and Services: Sentry Management, Inc. is a fee-based investment advisor. Sentry’s principal advisory service for retail investors is in fixed income, and we create portfolios based on our client’s needs and specifications. Monitoring: Sentry utilizes Hilltop Holdings fixed income portfolio system to monitor yields, average life, credit information and other relevant information monthly, and also monitors cash at various safe-keeping institutions for our clients. Investment Authority: In Sentry’s retail accounts, Sentry has discretionary authority to execute trades as an agent for our clients based on the strategy we establish at the accounts opening. Limited Investment Offerings: Sentry’s expertise is in fixed income. We purchase municipals or taxable securities for clients depending on the type of account, and all purchases are investment grade. Account Minimums and Other Requirements: Sentry’s stated minimum account fee for individuals is $3000 per year and there are not account size minimums. Additional Information: More specific information about our fee schedule for discretionary accounts and detailed information about our firm may be found at: https://crd.finra.org/IAD/Content/ViewOrg/crd_iad_Voi_Brochure.aspx?BRCHR_VRSN_ID=633727 Conversation Starters: Below are questions a retail investor should ask a financial professional: (i) (ii) (iii) (iv) Given my financial situation, should I choose a brokerage service? Sentry is a financial advisor and has a fiduciary responsibility to act in our client’s best interest. Broker dealers may take positions and act in their own best interest. We are not affiliated with any broker dealer, and always compare offerings to ensure best execution. Given my financial situation, should I choose an investment advisory service? Sentry is an investment advisor, so we act in the client’s best interest and all of our accounts are fee based only. How will you choose investments to recommend for me? Sentry utilizes 50 different broker dealers and puts them in competition to ensure we execute at the best available market price. Sentry determines your investment parameters based on tax rate, investment horizon, credit specifications and also only invests in investment grade or higher securities. Most investments we purchase for retail accounts are rated A or higher What is your relevant experience, including licenses, education and other qualifications? Sentry has been a registered investment adviser since 1991, and the three advisors have combined experience in fixed income of approximately 115 years. Murphy Davis Sr. graduated from Rice University, is a Chartered Financial Analyst and has a Series 7 and Series 63. Niley Church has an MBA from Dallas Baptist University and a Series 7 and Series 63. Murphy Davis, Jr. has an MBA from Texas Christian University and has a Series 7 and Series 65. In addition, Sentry Management is a Municipal Advisor to municipalities, and Murphy Davis, Sr. has a Series 50, Murphy Davis, Jr. a Series 50 and Series 52. Fees, Costs, Conflicts and Standard of Conduct: A. What Fees will I pay? (i) (ii) (iii) Description of Fees and Costs-Sentry charges a flat fee to retail clients, and our fee is charged quarterly based on assets under management. Although our fee schedule shows .0035% as our base fee, we may negotiate a lower fee for retail investors. B. 1) There may be other fees incurred by Sentry’s clients such as sake-keeping(custodial fee where bonds are kept) fees, but Sentry does not share in these fees and the costs are imposed by the custodian. Sentry will review any custodian agreement at the client’s request. 2) Since Sentry charges an asset based fee, the higher the amount of assets, the more retail customers will be charged, so Sentry has an incentive to increase assets under management. Description of Other Fees and Costs- Sentry only charges a flat fee for retail investors. Additional Information- You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investment over time. Please make sure you  understand the fees and costs you are paying. A sample fee structure may be found in our brochure in part 5: https://crd.finra.org/IAD/Content/ViewOrg/crd_iad_Voi_Brochure.aspx?BRCHR_VRSN_ID=633727 B. Standard of Conduct (i) (ii) (iii) (iv) When we act as your investment adviser, we have to act in your best interest and always put your best interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts of interest because they can affect the investment advice we provide you. An example of a conflict of interest is our relationship with CAPIS: Sentry maintains a soft-dollar agreement with Capital Institution Services (CAPIS) to provide Bloomberg terminals for execution of transactions and general economic/fixed income research. Although Sentry receives soft dollar benefits for Bloomberg services and could have a conflict of interest in recommending CAPIS, Sentry applies the same standard on every transaction to put the client’s best interest first. After researching the market among all broker dealers, transactions are only executed if CAPIS ties or beats other available offers. We only execute with CAPIS if their offer ties or beats other brokers in competition, we do run deficits and make up any shortcomings for Bloomberg services. Bloomberg is the premier platform for fixed income research and execution, and all clients benefit from the use of the service. How might conflicts of interest affect me and how will you address them? Sentry may use CAPIS to execute new issue callable agency trades if they are the best available option. Sentry checks the new issue and secondary fixed income before every trade and we always execute at the best price. Most of our retail accounts are municipal accounts and we do not execute any municipal trades through CAPIS. Additional Information may be found in our brochure: https://crd.finra.org/IAD/Content/ViewOrg/crd_iad_Voi_Brochure.aspx?BRCHR_VRSN_ID=633727 C. How do your financial professionals make money? (i) Sentry’s financial professionals are all paid a salary and use a team approach to manage all clients. We are not compensated in any kind of non-cash payment and the salaries are not based on any external factors Discipline History Do you or your financial professionals have a legal or disciplinary history? Yes SENTRY MANAGEMENT,INC.(SMI) IS REGISTERED & REGULATED BY THE SEC, HOWEVER, SMI ALSO REGISTERS BY NOTIFICATION WITH THE TEXAS STATE SECURITIES BOARD(THE BOARD). BEGINNING DEC.31, 2002, THE SEC REQUIRED ALL ADVISERS TO FILE ELECTRONICALLY ONLY THEN REDISTRIBUTE THE FILING TO CO-REGISTERING AGENCIES(THE BOARD). WE CONTINUED TO TIMELY FILE AND REGISTER EACH YEAR (03- 05) WITH THE SEC ASSUMING ALL OUR FILINGS WERE PASSED ON TO CO-REGISTRATION AGENCIES(THE BOARD). WE RECEIVED CORRESPONDENCE FROM THE BOARD ON MAY 18, 2006 THAT WHILE THE FIRM'S REGISTRATION INFORMATION HAD BEEN PASSED ON TO THE BOARD, THE REQUIRED INFORMATION ON THE FIRM'S INVESTMENT ADVISERS HAD NOT BEEN TRANSMITTED. THIS MEANT THAT THE COMPANY WAS REGISTERED, BUT THE ADVISERS WERE NOT FOR THE 3 YEARS SINCE THE REQUIRED ELECTRONIC FILING. THE NON- FILING(REGISTRATION) WITH THE STATE WAS DIRECTLY ATTRIBUTABLE TO A PROBLEM WITH THE ELECTRONIC FILING CONVERSION. EVEN THOUGH WE HAVE BEEN TIMELY FILING EACH YEAR, THE COMPUTER SYSTEM HAS NOT BEEN SENDING THE INFORMATION ON TO THE BOARD. THE FOLLOWING IS ALSO MATERIAL: 1. WE RECEIVED A NOTICE FROM THE BOARD, DATED OCT.24, 2002, WHICH STATED RENEWAL NOTICES WOULD NO LONGER BE MAILED TO OUR FIRM, "ALL FEES DUE FOR RENEWAL WILL BE COLLECTED BY THE NASD THROUGH THE CRD/IARD SYSTEMS," AND "NOTICE FILED INVESTMENT ADVISERS WILL NO LONGER RECEIVE CERTIFICATES OF AUTHORIZATION." 2. SINCE THE 2002 NOTICE WAS CONSISTENT WITH THE "ELECTRONIC-ONLY" SEC FILING, WE TOOK NO ADDITIONAL ACTION AND FELT WE WERE IN FULL COMPLIANCE WITH ALL APPLICABLE REGISTRATION REQUIREMENTS. WE DO NOT DISAGREE WITH THE "FINDINGS OF FACTS" BY THE BOARD, HOWEVER, WE STRONGLY DISAGREE WITH THE STATE'S REPRIMAND FOR AN UNINTENTIONAL AND WIDESPREAD ELECTRONIC CONVERSION PROBLEM IN TEXAS. I REQUESTED THAT NO ORDER BE PLACED AGAINST OUR RESPECTIVE NAMES FOR THIS CLEARLY CONFUSING TRANSITION FROM MAIL FILINGS TO COMPULSORY ONLINE FILLINGS, BUT THE BOARD CHOSE TO ISSUE THE ORDER. Sentry is no longer required to register with the state and only registers with the SEC. You may go to Investor.gov/crs for a free search tool to research the firm and your financial professionals. Additional Information: A) You can find additional information in our brochure (linked in this summary above) on our website at www.sentrymanagement.com or by emailing murph@sentrymanagement.com You may call 940-696-2100 to request up-to-date information and the Relationship Summary B) C) Who is my primary contact person? Murphy Davis Jr. Murphy Davis Jr is an investment adviser, and you may contact Murphy Davis Sr with any concerns about Murphy Davis Jr.