4. A. Advisory Firm Description Van Den Berg Management I, Inc. (the “Company” or “Advisor”), a Texas corporation, was founded by Arnold Van Den Berg in 1974 in order to provide investment management and financial planning services. Today, the Advisor offers a complete suite of wealth management and financial planning services under the name Century Management Financial Advisors. In addition, the Advisor serves as the investment adviser to The CM Advisors Family of Funds under the name CM Fund Advisors. The Advisor also conducts business under the names Century Management and Century Management Investment Advisors. The Advisor’s principal owner is Arnold Van Den Berg. 4.B. Types of Advisory Services The Advisor offers comprehensive wealth management services under the name Century Management Financial Advisors. These services include the investment management of equity, fixed income, and mutual fund portfolios; the investment management of retirement plans; and financial planning services. The Advisor also serves as the investment advisor of a mutual fund. Each of these services is described in more detail below. Investment Management Services The Advisor manages equity, fixed income, and mutual fund portfolios on behalf of its clients, primarily on a discretionary basis, pursuant to an investment advisory agreement with the client. These services are typically provided through separate accounts. For most portfolio management clients, the Advisor will implement an investment strategy based on the client’s risk tolerance and investment objectives. However, for 401(k) plan clients (“401(k) Clients”), the Advisor will typically provide plan sponsors with a mutual fund line-up that will allow for broad diversification so that that a plan participant can actualize a specific investment objective. To implement these investment strategies (and, in the case of 401(k) Clients, objectives), the Advisor will use an investment method selected by the client. Each of these investment strategies and methods is described below. Investment Strategies: The Advisor’s investment strategies are broadly defined in the following table: Strategy Risk Tolerance Investment Objective Objective Defined Aggressive An aggressive investor is willing to accept a substantial amount of risk in order to maximize returns Aggressive Growth Long-term growth is the primary objective Moderately Aggressive A moderately aggressive investor values higher long-term returns and is comfortable with higher volatility Growth Long-term growth is primary objective, income is secondary Moderate A moderate investor values growth, income, and risk reduction equally Balanced Long-term growth and current income are equally important Moderately Conservative A moderately conservative investor values preserving principal but is willing to accept a small amount of risk to seek some appreciation Income & Growth Income is primary objective, long-term growth is secondary Conservative A conservative investor values income and capital preservation over asset appreciation and is comfortable with lower returns in exchange for protecting principal Income Income and capital preservation is the primary objective Methods of Investing: There are three primary methods of investment (each, a “Method”) in which the client may choose for the Advisor to use when implementing the investment strategy or objective.
• Method 1: Mutual Funds, ETFs, and Closed-End Funds: This Method primarily invests in mutual funds, including open-end mutual funds, closed-end mutual funds, and exchange traded funds (“ETFs”), to implement the client’s investment strategy.
• Method 2: Individual Stocks and Bonds: This Method primarily invests in individual stocks and bonds to implement the client’s investment strategy.
• Method 3: Any Type of Investment: This Method may invest in any type of investment, including mutual funds set forth in Method 1 above and individual stocks and bonds as set forth in Method 2 above, to implement the client’s investment strategy. Cash and Cash Equivalent Holdings: Regardless of which Method is authorized by the client, the Advisor may invest discretionary advisory clients in cash or cash equivalent positions in any percentage for any length of time (including extended periods of time) when the Advisor, in its sole judgement, believes markets offer limited investment opportunities or are overpriced. Conflict of Interest: The Advisor may recommend its separately managed account program, its managed mutual fund program, or its mutual fund (CM Advisors Fixed Income Fund, a series of the CM Advisors Family of Funds (the “CM Fund”)) to the client if the Advisor deems such products appropriate based on the client’s goals, objectives, risk tolerance, and time horizon. The client should understand that the Advisor’s recommendation of its own products and services creates a potential conflict of interest in that the Advisor has an incentive to recommend its own products and services rather than similar products and services of third parties. The client is under no obligation to invest in the Advisor’s separately managed account programs, its managed mutual fund program, or the CM Fund. Retirement Plan Services We provide discretionary investment management services to retirement plans (including, without limitation, defined benefit pension plans (e.g., traditional defined benefit and cash balance pension plans), profit sharing plans, and 401(k) plans) (“Plans”) and non-discretionary investment management services to 401(k) Clients on an ongoing basis, as requested by the Plan sponsor. We are willing to accept “Investment Manager” status under Section 3(38) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) (for discretionary investment management services) or the designation as a “Co-Fiduciary” under Section 3(21)(A) of ERISA as part of our normal course of business. Depending on the needs and requests of the Plan sponsor, both our discretionary and non- discretionary services for Plans generally include assisting Plan sponsors with (1) policy guidance; (2) investment selection; (3) employee education; and (4) collaboration with the Plan’s third-party advisors and service providers.
• Policy Guidance - If the Plan has not yet established an investment policy statement (“IPS), the Advisor may help the Plan sponsor in recommending an appropriate IPS that describes the Plan’s objectives, risk tolerance, and goals. If the Plan has established an IPS, the Advisor may review and monitor the IPS for consistency with the Plan’s objectives, and recommend any changes that the Advisor deems necessary,
• Investment Selection – The Advisor will generally perform the following investment selection services: o With respect to Plans receiving discretionary services (“Discretionary Plans”), select or construct appropriate investments or investment options for the Plan, and with respect to Plans receiving non-discretionary services (“Non-Discretionary Plans”), recommend appropriate investments or investment options for the Plan. o With respect to Plans that include participant-directed investments, select (with respect to discretionary Plans) or recommend (with respect to Non-discretionary Plans) a default investment option for the Plan that is a “qualified default investment alternative” under Section 404(c)(5) of ERISA; o Monitor the investments or investment options for their continued appropriateness for the Plan; and o Provide the Plan, upon request, with comments, analysis, and supporting information regarding the investments and/or investment options. In selecting investments for Plans, the Advisor typically uses the investment strategies and methods described above, under “Investment Management Services.” However, for 401(k) Clients, the Advisor will typically provide plan sponsors with a mutual fund line-up that will allow for broad diversification so that a plan participant can actualize one of the investment objectives described in the chart under “Investment Management Services – Investment Strategies,” above.
• Employee education – Upon request, the Advisor will generally provide Plan participants with the following services, subject to travel, expense reimbursement, and quantity limitations: o Distribution of plan materials, including enrollment books, information regarding investment options, and other materials, and those provided by the Plan Administrator, to participants involved in sessions; o Make available, or direct Plan participants to, written or electronic materials discussing generally accepted investment principles, including asset allocation and diversification, for participants involved in sessions; o Lead virtual or in-person group educational sessions; and o Conduct virtual or in person individual participant calls or meetings as requested.
• Collaboration – The Advisor will share information with third-party administrators, accountants, auditors, attorneys, and other advisors to the Plan, as authorized by the Plan. If the client accounts are part of the Plan, and we accept appointments to provide our services to such accounts, we acknowledge that we are a fiduciary within the meaning of section 3(38) of ERISA with respect to the provision

of services identified as “Services Provided as an ERISA Fiduciary” in the Addendum to the Plan’s investment advisory agreement with the Advisor. Financial Planning The Advisor offers three different types of financial plans to clients: (1) Focused Wealth Plans, (2) Comprehensive Wealth Plans, and (3) Social Security Optimization Plans (collectively, the “Wealth Plans”). Each of these Wealth Plans is described below. Focused Wealth Plan: A Focused Wealth Plan is created for new clients as well as existing clients who don’t have or need a Comprehensive Wealth Plan. The Focused Wealth Plan provides the client with the following:
• Family Index Number: The individual rate of return designed to help you work towards achieving your goals and objectives.
• Personalized Cash-Flow Based Planning: Narrowly tailored to identify and address your specific goals and objectives. Will consider clients’ current assets (stocks, bonds, mutual funds, CD’s, annuities, real estate holdings, etc.), earned income, investment income, social security, the possibility of inheritance, gifting, and miscellaneous income and expenses.
• Risk Management Planning: Comprehensive analysis of life, disability, long-term care, and other risk management solutions.
• Social Security Analysis and Optimization: Custom analysis and comparison of the social security claiming options that are available.
• Solutions Center: a proprietary cloud-based platform licensed through eMoney Advisors, LLC, where you will gain access to your own personal financial management website. The Solutions Center will give you access to your financial information through an interactive portal, and allow for up-to-date account balances, provide for comprehensive account aggregation, and allow for multiple customized cash flow and net worth scenario analyses to be performed. You will also be provided a client vault (“Client Vault”), which will allow you to share and store documents. Comprehensive Wealth Plan - The Comprehensive Wealth Plan includes everything in the Focused Wealth Plan explained above, plus we analyze in detail the areas of insurance, investment, tax, retirement, and estate planning. We will work with your outside tax, estate, and insurance advisors to give you more comprehensive specialized knowledge and advice. During this part of the planning process, we will be your advocate and help you coordinate this advice. The Comprehensive Wealth Plan will also give you access to the Solutions Center and a Client Vault. One key element of Solutions Center for Comprehensive Wealth Plans is that your tax, estate, and insurance advisor can be granted limited access to portions of your financial website that pertain to their work. Social Security Optimization Plan- This personalized plan will help clients analyze claiming strategies, show clients their Social Security income stream under different claiming scenarios, and help clients take advantage of innovative strategies designed to maximize benefits. Limitations: The projections or other information generated and presented by the Advisor in Wealth Plans regarding the likelihood of various investment outcomes are hypothetical in nature and do not reflect actual investment results. There are risks associated with investing, including the risk of losing all or a portion of your invested capital. We recommend that in addition to working with the Advisor, clients work closely with their attorneys, accountants, insurance agents, real estate brokers and other investment professionals. Separate Agreement: Clients are required to sign a separate agreement engaging the Advisor to prepare Wealth Plans, which outlines the terms of the service. Wealth Plans generally are provided on a one-time basis and are not intended to be used as the basis for an ongoing financial planning arrangement; however, the Advisor may agree to perform ongoing financial planning services to clients in certain cases. The results contained in Wealth Plans rely heavily on information the client has provided to the Advisor. Some or all of the information, goals, and/or objectives furnished by the client to the Advisor may change after the Wealth Plan has been presented to the client. It is important to note that any changes to the inputs, variables, or information provided to the Advisor may render the Plan less useful and, in some cases, obsolete. Business Succession and Exit Planning Consulting Services The Advisor offers business succession and exit planning consulting services to businesses and business owners. The business succession and exit planning consulting services are designed to assist businesses and business owners prepare for leadership transition or sale. The business succession and exit planning consulting services include development of a summary report of business succession or exit plan readiness and development of a business succession or exit plan assessment and plan (“Business Exit Plan”), which includes a detail analysis of one or more of the following areas: (i) finance, (ii) planning, (iii) revenue and profit, and (iv) operations. The Advisor will work with your outside legal, accounting, tax, estate, and other professional advisors to give you more comprehensive specialized knowledge and advice. In addition, the Advisor offers to assist clients in implementing the Business Exit Plan. Limitations: The reports, assessments, plans or other information generated and presented by the Advisor regarding business succession and exit planning recommendations and the likelihood of various outcomes are hypothetical in nature and do not reflect actual success. Changes in various circumstances, including changes in economic and market conditions and employee and family related issues may affect the outcome of the Business Exit Plan and its implementation. The Business Exit Plan and its implementation may not be successful as anticipated. We recommend that in addition to working with the Adviser, clients work closely with their attorneys, accountants, tax advisors, insurance agents, business brokers and other investment professionals. Separate Agreement: Clients are required to sign a separate agreement engaging the Advisor to provide the business succession and exit planning consulting services. The results contained in the reports, assessments or plans rely heavily on information the client has provided to the Advisor. Some or all of the information, goals, and/or objectives furnished by the client to the Advisory may change after the reports, assessments or plans have been presented to the client. It is important to note that any changes to the inputs, variables, or information provided to the Advisor may render the reports, assessments and plans less useful and, in some cases, obsolete. General Consulting Services In addition to the foregoing services, the Advisor may provide general consulting services to clients. These services are provided as and when requested by the client and agreed to by the Advisor and may include the provision of non-discretionary investment advisory services. Mutual Fund Advisory Services CM Fund Advisors serves as investment advisor and portfolio manager to the CM Fund, which has an investment strategy that generally corresponds to the Conservative Strategy for separate accounts. 4.C. Client Investment Objectives/Restrictions At the outset of each client engagement, the Advisor spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, tolerance for risk, and broadly identifying major goals of the client. This information provided by the client guides our management of the client’s account. It is the client’s responsibility to promptly inform the Advisor if the information provided to the Advisor becomes materially inaccurate, or if the client’s investment objective or risk tolerance has changed. Discretionary advisory clients may request certain reasonable restrictions on the Advisor in the management of their accounts, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship, with written notice to the Advisor. Each client should note, however, that restrictions, if accepted by the Advisor, may adversely affect the composition and performance of the client’s investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of the Advisor. 4.D. Wrap-Fee Programs The Advisor typically does not participate in wrap-fee programs at this time. 4.E. Assets Under Management As of January 31, 2024, the Advisor had $500,531,825 in assets under management. This figure includes all accounts, including the CM Advisors Fixed Income Fund, for which the Advisor has discretion and is paid a management fee.
• Discretionary basis: $500,531,825.
• Non-Discretionary basis: $0