Brochure - ADV Part 2A

August 12, 2025

Item 1 - Cover Page

This Brochure provides information about the qualifications and business practices of Vann Equity Management, LLC ("VEM," "us," "we" or "our"). When we use the words "you," "your" and "client" we are referring to you as our client or our prospective client. We use the term "supervised person" when referring to our officers, employees, and all individuals providing investment advice on behalf of VEM. If you have any questions about the contents of this Brochure, please contact us at 214-983-0346 or jvann@vannequity.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority.

VEM is a registered investment adviser. The registration of an investment adviser does not imply any level of skill or training. The oral and written communications made to you by VEM, including the information contained in this Brochure, should provide you with information to determine whether to hire or retain VEM as your adviser.

Additional information about VEM is also available on the SEC's website at www.adviserinfo.sec.gov. The SEC's website also provides information about any persons affiliated or registered with, and or required to be registered, as investment adviser representatives of VEM.

Item 2 - Material Changes

Please note that there were no material changes to this Brochure since our last delivery or posting of our Brochure on the SEC's public disclosure website ("IAPD") at www.advisorinfo.sec.gov, however, this Brochure does include a number of minor editorial changes, and updated information on our assets under management.

Currently, our Brochure may be requested by contacting John A. Vann, Chief Compliance Officer at 214-983-0346. Our Brochure is also available on our website, which is located at www.vannequitymanagement.com, free of charge.

Item 4 - Advisory Business

Vann Equity Management LLC, which is formerly known as Precision Capital Management (referred to herein as "VEM," the "Firm," "us" and "we"), is an investment adviser that is registered with the United States Securities and Exchange Commission ("SEC"), and is a Limited Liability Company formed pursuant to the laws of the State of Texas.

VEM primarily provides customized discretionary portfolio management services to individuals, families, pension and profit-sharing plans, corporations or other businesses and non-profit institutions. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is granted by the investment management agreement you sign with our firm. VEM generally invests client assets in domestic and international stocks, bonds, mutual funds, options, exchange traded funds ("ETFs") and other public or private securities or investments. Advisory Representatives are available to offer advice on most types of investments owned by a client and at the specific request of a client, will explore investment options not currently owned by a client.

Ownership

VEM is owned and controlled 100% by Vann Partners LLC, formally known as LFAM Investment Counsel and Advisors LLC ("Vann"). The JAV 2020 Irrevocable Trust and Aaron Vann are members of Vann, as of November 2020. VEM has been in the advisory business under the current ownership since November 2020.

Some Investment Advisory Representatives ("IAR's") operate under Austin Wealth Specialists, a "doing business as" ("DBA") trade name and logo, which they use for marketing purposes. Clients should understand that even though Vann's IARs operate under this DBA, when those IARs offer or provide advisory services through Vann, they do so under the supervision of Vann.

Services Offered

• Financial planning services
• Portfolio management services for individuals and/or small businesses
• Portfolio management for businesses or institutional clients (other than investment companies)
• Pension consulting services

Assets Under Management

VEM managed $203,644,459 in client assets on a discretionary basis, as of December 31, 2024.

Overview of Services Offered

Asset Management Services

VEM provides advisory services through its Asset Management Services program. Asset Management Services involve providing clients with continuous and on-going management over client accounts. This means that VEM will continuously monitor a client's account and make trades in client accounts, when necessary, in accordance with the client's investment objective.

VEM's services are always provided based on the individual needs of each client. VEM Advisory Representatives are instructed to consider the individual needs of each client when recommending an advisory platform. VEM's Advisory Representative will conduct a complimentary initial meeting with the client for an information and data-gathering session. At this initial meeting, the Advisory Representative will assist the client in determining the advisory services needed. Clients are given the ability to impose restrictions on their accounts including specific investment selections and sectors. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account.

When client accounts are managed using models, investment selections are based on the underlying models, and we do not develop customized (or individualized) portfolio holdings for each client. However, the determination to use a particular model or models is always based on each client's individual investment goals, objectives, and mandates.

US Large Cap Growth Model

A pure growth portfolio of typically between 60-75 US large cap stocks with diversified exposure across industries. We seek to invest in competitively advantaged businesses at various stages of their corporate life cycle, leveraging innovation and change to drive rapid growth in earnings and cash flow. We look to identify stocks with the potential to deliver sustainable earnings growth, capitalizing on both secular and cyclical growth. We are patient investors, aiming to invest in companies trading at attractive valuations relative to their long-term potential and taking advantage of cyclical opportunities to build positions in high conviction names.

US Large Cap Value Model

A best ideas portfolio of 60-65 US large cap companies with hidden value and upside potential that we believe are overlooked by the market. We are looking for high quality companies with effective management teams where we believe they can materially improve the business. We focus on relative value, searching for companies with solid businesses, strong balance sheets, and durable earnings profiles that are inexpensive relative to their history, sector, or the market. We balance our valuation analysis with qualitative factors to identify the most compelling valuation opportunities.

US Small/Mid Cap Core Model

Mid Cap Core Equity Fund seeks long-term growth of capital. The portfolio management team aims to construct a portfolio of companies that have high or improving return on invested capital, quality management, a strong competitive position and which are trading at compelling valuations. The investment seeks to provide long-term capital growth. The fund will normally invest at least 80% of its net assets (including any borrowings for investment purposes) in stocks of small companies. The advisor defines a small company as one whose market capitalization falls (i) within or below the current range of companies in either the Russell 2000® Index or the S&P SmallCap 600 Index or (ii) below the three-year average maximum market cap of companies in either index as of December 31 of the three preceding years. While most assets will typically be invested in U.S. common stocks, the fund may invest in foreign stocks in keeping with its objectives.

Non-US International ADR Core Model

International ADR core is a thematic growth portfolio that is geographically, economically, and demographically diversified, and seeks long-term capital appreciation by investing in non-U.S. securities of varying market capitalizations.

Index Advantage Fixed Income ETF

The Index advantage Fixed Income strategy is constructed using Mutual Funds and ETF's consisting of investment grade, hi-yield, U.S and Non-U.S. denominated securities varying in yield, credit and duration. The strategy looks to be consistently 95% invested. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the Fixed Income market.

Index Advantage Domestic ETF

The Index Advantage Domestic US strategy seeks investment results that produce higher returns than the S&P 500 Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in the US equity market. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the US equity market.

Index Advantage International ETF

The Index Advantage International Non-US strategy seeks investment results that produce higher returns than the MSCI EAFE Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in NON-US equity markets. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, country, developed vs. emerging, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to the Non-US equity markets.

Index Advantage Global ETF

The Index Advantage Global strategy seeks investment results that produce higher returns than the MSCI All Country World Index. This portfolio is constructed using ETF's that can measure Large, Mid, or Small capitalization companies, as well as individual asset styles of Growth, Blend or Value in US and NON-US equity markets. The strategy employs a 50% Strategic/50% Tactical asset allocation while maintaining individual cash, country, developed vs. emerging, sector and leverage constraints. The strategy is meant to be part of an overall comprehensive portfolio allocation, or extension of an existing allocation with an objective for exposure to equity markets available across the world. This strategy can also be considered a complete allocation to equity markets.

Third-Party Portfolio Management Program

VEM may recommend our Third-Party Portfolio Management Programs ("Program") to Clients to supplement our advisory services. The Program is typically managed by third-party portfolio manager ("TPPM") on a discretionary basis, and each TPPM may offer different types of investment programs and/or services. TPPM programs offer access to a variety of investment portfolio models and strategies, with varying levels of risk. After consultation with their VEM financial professional, a Client may select a TPPM investment management program that is appropriate for their objectives, goals, financial situation and risk tolerance. When using a TPPM, the Client may incur additional platform and investment management fees. The TPPM fees are generally not included in the fees charged by Vann but are disclosed in the Advisory Firm's investment management agreement, which each Client is provided and must sign in order to access the services of the TPPM. Such additional fees are only incurred on the portion of Client's portfolio managed by the TPPM. TPPMs are separately registered investment advisers, and are not affiliated with VEM.

Freedom Platform

VEM offers asset management services to advisory clients utilizing Freedom Investment Management, Inc.'s ("Freedom") portfolios on the Freedom platform. The client can elect to authorize VEM discretionary authority within the Investment Advisory Agreement, full discretion to hire and fire sub-advisors within the Freedom platform. Freedom shall have discretionary authority for the investment and reinvestment of the designated assets with full authority to buy, sell or otherwise effect investment transactions involving the designated assets in the client's name and for the client's account.

Realized Financial, Inc. Sub-Advisory Services

VEM has entered into a sub-advisory agreement with Realized Financial, Inc. ("Realized") as a sub-advisor to directly manage portions of the overall client portfolio concerning Delaware Statutory Trusts ("DSTs"), Qualified Opportunity Zone Funds ("QOZFs"), certain real estate investment trusts (including 721 exchanges, also known as UPREITS) offered by the sponsors of such securities, and 1031-like exchanges involving such securities. VEM continues to serve as a client's primary advisor. In this capacity, VEM remains responsible for the ongoing monitoring of Realized managed accounts as well as for whether Realized remains suitable in the context of a client's overall investment program. VEM will recommend adjustments to Realized allocations when we believe such changes would be in a client's best interest. Clients are provided with the Form ADV Part 2A (or similar disclosure) for any sub-advisor recommended, which provides complete detail on the sub-advisory fees, billing schedule, and payment procedures.

Retirement Plan Services

We offer various levels of advisory and consulting services to employee benefit plans ("Plan"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible Plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status. VEM services may also include planning services for retirement plan participants and consulting with the retirement plan sponsor on methods of improving or enhancing the retirement plan. The exact suite of services provided to a client will be listed and detailed in the Retirement Plan Services Agreement.

Retirement Accounts – DOL Disclosure

We are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 ("ERISA") and/or the Internal Revenue Code ("Code"), as applicable, when we provide investment advice regarding portfolio assets held in an IRA, Roth IRA, Archer Medical Savings Account, a Plan covered by ERISA, or a plan described in Section 4975(e)(1)(A) of the Code (collectively referred to sometimes herein as ("Retirement Accounts").

Financial Planning Services

VEM provides advisory services in the form of financial planning and consulting services. Financial planning services do not involve the active management of client accounts, but instead focus on a client's overall financial situation. Financial planning can be described as helping individuals determine and set their long-term financial goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas.

Wrap Program

VEM does not provide a wrap program, however, through the Program described above, it does provide access to third-party portfolio managers who offer wrap programs. The TPPM's services are further described in their respective Form ADV Wrap Brochure, which will be provided to you should you elect to engage a TPPM.

Item 5 - Fees and Compensation

Type of Compensation

• A percentage of assets under management
• Hourly charges
• Fixed fees (other than subscription fees)

Asset Management Service Fees

For VEM asset management services, we will charge an annual fee based upon a percentage of the market value of the assets being managed. Our fee for asset management services is set forth in the following fee schedule. Our fees are negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with you, etc.).

Fee Schedule

Minimum Amount	Maximum Amount	Fee (%)
$0.00	$50,000,000.00	1.50%
$50,000,001.00	And Above	Negotiable

You will be charged a 1.5% advisory fee when your account is valued at $50,000,000 or less. If greater than $50,000,000 the fees are negotiable. Since our fees are negotiable, the exact fee you will pay may be different from those reflected above. The fees you will pay will be clearly stated in the advisory agreement that you sign with our firm.

Freedom Platform Fees

The Freedom Platform Fee will be charged as a percentage of assets under management. For Clients utilizing the Freedom platform, Freedom will charge all fees including the Vann Advisory Fee.

Investor Household AUM	Fee Range
<$250,000	0.34%-0.76%
Next $250,000	0.32%-0.70%
Next $1,500,000	0.30%-0.62%
Next $3,000,000	0.28%-0.45%
$5,000,001+	Discretionary

Realized Sub-Advisory Fees

Pursuant to the Sub-Advisory Agreement, Realized may be engaged by VEM to provide discretionary investment advisory services to certain portions of the portfolios of specified clients of VEM. Realized is paid a portion of the asset management fee paid by clients to VEM based on the value of the client's account as shown below. Fees are calculated on an annual basis and deducted from your account quarterly, in arrears, by VEM with Realized's portion of the overall fee paid directly by VEM to Realized.

Minimum Amount	Maximum Amount	Fee (%)
$300,000	$500,000	1.60%
$500,001	$1,000,000	1.55%
$1,000,001	$2,500,000	1.50%
$2,500,001	$5,000,000	1.45%
$5,000,001	$10,000,000	1.38%
$10,000,001	$15,000,000	1.33%
$15,000,001	$20,000,000	1.30%
$20,000,001	$30,000,000	1.20%

Retirement Plan Service Fees

For the retirement plan engagements, fees are negotiated on a case-by-case basis and are determined with each client depending upon the size and complexity of the retirement plan and the services rendered. We also take into consideration special situations or conflicts of interest where charging a fee is prohibited under ERISA law. The exact fee assessed, and payment arrangements will be quoted and disclosed in the Retirement Plan Services Agreement prior to commencing such services. Upon termination of an agreement, any fees paid in advance will be prorated and any unearned fees will be refunded.

Financial Planning Service Fees

VEM will charge a fixed fee and/or hourly fee for consulting services. Our consulting fees are negotiable. We utilize the following financial planning fee schedules:

Fixed Fees: VEM will charge a fixed fee that ranges from $1,000.00 to $20,000.00, for broad-based planning services. In limited circumstances, the total cost could potentially exceed $20,000.00. In such cases, we will notify the client and may request that the client pay an additional fee.

Hourly Fees: VEM charges an hourly fee of $350 for clients who request specific services (such as a modular plan or hourly consulting services) and do not desire a broad-based written financial plan.

Additional Fees and Expenses

In addition to the advisory fees we charge, VEM also assesses an annual technology and administrative fee to each individual account. The amount of that fee is determined based on the platform under which the account is managed, as follows:

Account Fee per Registration - $75.00

This flat fee will be charged in addition to our advisory fees and will be charged regardless of the value of each account. Upon a client terminating their relationship with VEM, the annual technology fee will be prorated for the time the account is active during the current calendar year.

Investing in securities involves risk of loss that clients should be prepared to bear.

Item 6 - Performance-Based Fees and Side-By-Side Management

VEM does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or engage in side-by-side management.

Item 7 - Types of Clients

Client Types

• Individuals
• Families
• High net worth individuals
• High net worth families
• Pension and profit-sharing plans (other than participants)
• Charitable organizations
• Trusts
• Estates
• Private business owners
• Private foundations
• Retirement plans

Account Minimum Requirements

For accounts managed in investment strategies developed by VEM, a minimum of $40,000 is required for asset allocation models and $250,000 for equity portfolios. A minimum of $50,000 is required for Unified Managed Account Program accounts. However, subject to applicable law, actual advisory fees and the required minimum dollar value of assets may be negotiated. Fees may also vary due to the particular circumstances of the client, additional or differing levels of service, or as otherwise agreed upon with specific clients.

Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss

Investing in securities involves risk of loss that clients should be prepared to bear.

Analysis Methods

VEM Advisory Representatives use various methods of analysis and investment strategies. Methods and strategies will vary based on the VEM Advisory Representative providing advice. Models and strategies used by one Advisory Representative may be different than strategies used by other Advisory Representatives. Some VEM Advisory Representatives may use just one method or strategy while other Advisory Representatives may rely on multiple. VEM does not require or mandate a particular investment strategy to be implemented by its Advisory Representatives. Further, VEM has no requirements for using a particular analysis method and VEM Advisory Representatives are provided flexibility (subject to VEM supervision and compliance requirements) when developing their investment strategies. Security analysis methods utilized by VEM include the following:

• Charting
• Fundamental
• Technical
• Cyclical
• Quantitative
• Macro Analysis

Sources of Information

The main sources of information that VEM uses to analyze these investment strategies is:

• Financial newspapers and magazines
• Inspections of corporate activities
• Research materials prepared by others
• Corporate rating services
• Timing Services
• Annual reports, prospectuses, filings with the SEC
• Company press releases
• Advisor Intelligence
• World Wide Web

Investment Strategies

Numerous model portfolios are developed by VEM at any one time, but generally speaking, portfolios will be designed based on the following objectives:

• Large cap growth
• Large cap value
• International
• Asset allocation

The investment strategies VEM uses to implement any investment advice given to clients includes the following:

• Long term Purchases (securities held at least a year)
• Short-term purchases (securities sold within a year)
• Trading (securities sold within 30 days)
• Option writing, including covered options, uncovered options or spreading strategies
• Utilization of Alternative Investments (partnerships, hedge funds, commodity pools, etc.)

Investment Strategy Risks

Investing in securities involves risk of loss that clients should be prepared to bear.

All investment programs have certain risks that are borne by the investor. Our investment approach seeks to keep the risk of loss in mind. Investors face the following investment risks:

• Quantitative Process, Model and Technology Risks
• Reliance on Third-Party Managers/Sub-Advisers
• General Risks (Lack of Diversification, Cash, Interest Rate Fluctuation)
• Long term Purchases (Liquidity Risk)
• Short-term purchases (Market Risks)
• Trading (Market Risks, Speculative Nature, Turnover)
• Margin Risk (Leverage)
• Option writing, including covered & uncovered options or spreading strategies
• Utilization of Alternative Investments
• Mutual Funds and ETFs
• Information Security Risk

Item 9 - Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of VEM or the integrity of VEM's management. VEM has no information which is applicable to this Item.

Item 10 - Other Financial Industry Activities and Affiliations

Rastegar Real Estate Investment Firm(s)

Vann has known Ari Rastegar, the Rastegar Real Estate Investment Firm(s), and affiliated entities (collectively "Rastegar") since 2015. Vann introduced Rastegar to clients while with a prior firm during the 2015-2016 period, and two clients ultimately invested with Rastegar. Those clients subsequently made direct investments in the following years. This conflict of interest has been mitigated by VEM by not recommending Rastegar for new portfolio holdings for clients of VEM.

Other than Rastegar, VEM does not have any other Financial Industry Activities or Affiliations.

Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

General

VEM has adopted a Code of Ethics for all of our supervised persons describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at VEM must acknowledge the terms of the Code of Ethics annually or as amended.

Personal Trading

VEM and our related persons are allowed to purchase and sell securities for their own account. To prevent conflicts of interest, all employees of VEM must comply with our Code of Ethics, which imposes restrictions on the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons.

Cross Trades

It is VEM's policy that we will not affect any principal or agency cross-securities transactions for client accounts. We will also not cross trades between client accounts.

Insider Information

Further, the Code of Ethics and our Compliance Manual impose certain policies and procedures concerning the misuse of material non-public information that are designed to prevent insider trading by any officer, partner, or supervised person of VEM.

Item 12 - Brokerage Practices

General

VEM generally requires clients to establish brokerage accounts with FINRA registered broker-dealers and members SIPC (collectively "Custodians"), to maintain custody of clients' assets and to effect trades for their accounts. VEM is independently owned and operated and not affiliated with either Custodian.

Best Execution

As a fiduciary, VEM must seek best execution for client transactions, which includes consideration of a client's total costs or proceeds and the quality of broker-dealer services. The determinative factor is not the lowest possible commission cost, but whether the transaction represents the best qualitative execution.

Directed Brokerage

VEM does not permit clients to direct the execution of investment transactions (referred to as "directed brokerage") to any broker-dealer other than Charles Schwab & Co. and Goldman Sachs Custody Solutions.

Trade Aggregation/Block Trades

In some instances, trades for more than one client's account may be aggregated (block trades) and executed as a single trade in order to provide fair and equitable prices among managed client accounts. All clients will receive equal treatment.

Soft Dollar Arrangements

Our Custodians make available to us products and services that benefit us but may not directly benefit our client's accounts. These include software and other technology that provide access to client account data, facilitate trade execution, provide research, and assist with back-office functions. This creates a potential conflict of interest which we mitigate through disclosures.

Item 13 - Review of Accounts

Account Review

For clients to whom VEM provides investment management services, VEM monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least a quarterly basis. More frequent reviews can be triggered by a specific client request, a change in client goals, an imbalance in a portfolio, or market conditions.

Reports

The client's custodian provides account statements directly to the client no less frequently than quarterly. Clients should compare the account statements they receive from their custodian with those they receive from VEM. The custodian's statement is the official record.

Third Party Money Managers Review

Accounts established through referral relationships with other investment advisers will have their accounts reviewed upon receipt of statements or reports from the other investment advisers, which are usually generated on a quarterly basis.

Item 14 - Client Referrals and Other Compensation

Client Referrals

VEM may enter into a Solicitor Agreement with unaffiliated registered investment advisors ("Solicitor") whereby the Solicitor may refer clients to us. For each client referral, we will pay a percentage of the management fees earned to the Solicitor. This creates a conflict of interest; however, we address this by disclosing the referral relationship.

VEM also has an agreement with certain Investment Advisory Representatives ("IAR's"), to which VEM compensates IAR's for client referrals made in compliance with the Advisers Act.

Item 15 - Custody

VEM is deemed to have custody of client funds and securities whenever VEM is given the authority to have fees deducted directly from client accounts. VEM has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client's name. Account statements are delivered directly from the qualified custodian to each client at least quarterly.

Standing Letters of Authority

VEM has been deemed to have inadvertent custody as a result of your providing us with Standing Letters of Authorization ("SLOA(s)") to withdraw funds from your portfolio account to pay third parties. We rely on the conditions set forth in the SEC No-Action letter from February 21, 2017, which negates the need for a surprise examination under specific protective conditions.

Item 16 - Investment Discretion

Discretionary Authority

VEM usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account.

Item 17 - Voting Client Securities

General Policy

It is the policy of VEM to not vote proxies for clients, and Clients specifically retain the responsibility for receiving and voting proxies. Notwithstanding the above, upon special request, and upon the approval of VEM, VEM will vote a proxy for a Client under its discretionary management authority.

Conflicts of Interest

If a material conflict of interest is identified, VEM will use one of several methods to resolve the conflict, including disclosing the conflict to the client and obtaining consent, providing the client an opportunity to vote themselves, or receiving an independent third-party recommendation.

Item 18 - Financial Information

VEM does not require the prepayment of fees of $1,200 or more, six months or more in advance. VEM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of bankruptcy proceedings.

Item 19 - Requirements for State-Registered Advisers

Item 19 is not applicable to Federally registered investment advisers.