Davidson Capital Management, Inc. (DCM) is a subchapter S Corporation organized under the laws of the state of Texas. DCM is a registered investment adviser with the United States Securities and Exchange Commission, the Texas State Securities Board, and has been registered since November 1989. DCM is owned by William Jeffrey Davidson, President, and John Kyle Davidson Senior Vice President. DCM is not publicly owned or traded. There are no indirect owners of DCM. DCM provides independent, fee-only investment management to its clients under three different investment management programs: Individually Managed Account, Asset Builder Account, and 401(k) Retirement Plan Advisory Services. Individually Managed Account/Asset Builder Account DCM’s investment advisor representatives (IAR), William Jeffrey Davidson, John Kyle Davidson, and Joe Carroll Rust Jr. develop asset allocation strategies using a mix of stocks, exchange traded funds, bonds, and no-load mutual funds. Through continuous monitoring of asset class segment returns and risk factors, DCM adjusts portfolio asset mixes to meet investment objectives. The specific percentages allocated to each asset class may vary due to the nature of asset performance and/or the strategy selected. It is DCM’s intent to maintain a risk exposure commensurate with each client’s objectives by using the various investment portfolio choices available under the asset allocation strategy selected by the client. DCM’s IAR’s consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify DCM if there are changes in their financial situation or if they wish to adjust their asset allocations. Clients may not impose unreasonable restrictions on the management of their accounts if DCM determines, in its sole discretion, the restrictions will materially impact the performance of an asset allocation strategy or prove overly burdensome to DCM’s management efforts. The investment management program for each client will be determined by the amount of client assets available to invest. The client’s asset allocation will be determined by the clients’ risk tolerance, investment objective, and income requirements. DCM generally limits the types of securities used for client investment to the following: common stocks, exchange traded funds, government bonds, investment grade corporate bonds, State of Texas municipal bonds, and no-load mutual funds. 401(k) Retirement Plan Advisory Services 401(k) Retirement Plan Advisory Services consists of helping employer plan sponsors establish, monitor, and review their company's 401(k) retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. DCM offers management of retirement plans both on a plan level and on the individual participant level. At the plan level DCM manages the investment line-up, making changes as necessary as well as providing risk-based investment models for the participants. At the individual participant level, DCM manages risk-based models using the current investment lineup based on the risk tolerance of the individual plan participant. Plan Level DCM will establish the plan’s needs and objectives through an initial meeting to collect

data, review plan information, assist in developing or updating the plan’s provisions and provide a comprehensive review of existing 401(k) plan investment options. DCM will also assist with converting from incumbent service providers to a new service provider if appropriate. Ongoing services will include selection and review of unaffiliated mutual funds that, in DCM’s judgment, are suitable for plan assets to be invested, and DCM will draft an Investment Policy Statement (IPS) providing ongoing monitoring of the mutual funds in the 401(k) plan to ensure compliance with the IPS and will provide custom designed asset allocation models that can be used by plan participants. Participant Level DCM will use its proprietary method of selecting mutual funds to create a list of mutual funds available for investment in each 401(k) plan. Plan participants can design their own 401(k) portfolio the following ways: (1) Plan participants can select from various risk-based asset allocation models designed by DCM or asset allocation models designed by the third party recordkeeper which will contain pre-set allocations of mutual funds from the list of mutual funds selected by DCM. (2) Plan participants can design their own portfolio asset allocation from the list of mutual funds chosen by DCM. (3) If the Third Party Administrator permits, plan participants can create portfolios from a combination of both (1) & (2). The mutual funds available to 401(k) participants are continually reviewed by DCM. When any mutual fund(s) fails to meet the investment standards outlined in the IPS, DCM will replace those mutual fund(s). Conflicts of Interest – IRA Rollover Recommendations When recommending that a client rollover his or her account from a 401(k) plan managed by DCM to an IRA also managed by DCM, DCM and its investment adviser representatives have a conflict of interest. DCM and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA managed by DCM; however, DCM and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds from the 401(k) plan. Thus, DCM and its investment adviser representatives have an economic incentive to recommend a rollover of the 401(k) plan account to an IRA account managed by DCM, which is a conflict of interest. DCM has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA. DCM and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with DCM’s fiduciary status, (ii) not recommend investments which result in the firm receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by DCM and its supervised persons and any material conflicts of interest related to DCM recommending the rollover of funds from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. As of December 31, 2023, DCM managed on a discretionary basis $503,131,479 in 846 accounts. DCM has no non-discretionary assets under management. DCM does not participate in any wrap account programs.