Adviser was founded as an independent investment management firm by Daniel F. Dent in 1976. Adviser is wholly employee-owned and is unaffiliated with any other financial organization. Adviser provides investment management services to clients. In connection with that role, Adviser provides the following types of advisory services:
• 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 a 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 and DFSGX), an open-end small cap growth mutual fund.
• Serves as a sub-adviser to other managers, mutual funds other than the DF Dent Growth Funds, 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, depending on type, able to be entered as trading restrictions on Adviser’s order management system. Adviser receives discretionary authority from all 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, 2023, Adviser managed approximately $8,146 billion in assets using the SEC’s definition of regulatory assets under management and not including assets attributable to its Unified Managed Account programs. Adviser does not now and has no plans in the future to sponsor any wrap-fee program. 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, 2023, Adviser currently acts as a sub-adviser in 20 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.