Overview
- Headquarters
- Clayton, MO
- Average Client Assets
- $13.4 million
- Minimum Account Size
- $150,000
- SEC CRD Number
- 107930
Fee Structure
Primary Fee Schedule (ARGENT CAPITAL MANAGEMENT LLC PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.80% |
| $3,000,001 | and above | 0.65% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $39,000 | 0.78% |
| $10 million | $71,500 | 0.72% |
| $50 million | $331,500 | 0.66% |
| $100 million | $656,500 | 0.66% |
Clients
- HNW Share of Firm Assets
- 65.26%
- Total Client Accounts
- 1,160
- Discretionary Accounts
- 1,151
- Non-Discretionary Accounts
- 9
Services Offered
Services: Portfolio Management for Individuals, Portfolio Management for Companies, Portfolio Management for Institutional Clients
Regulatory Filings
Additional Brochure: ARGENT CAPITAL MANAGEMENT LLC PART 2A (2026-03-27)
View Document Text
100 S. Brentwood Blvd., Suite 110
St. Louis, Missouri 63105
314-725-6000
www.argentcapital.com
Form ADV Part 2A - Disclosure Brochure
March 31, 2026
Item 1 : Cover Page
This disclosure brochure provides information about the qualifications and business practices of
Argent Capital Management, LLC. If you have any questions about the contents of this brochure, please
contact us at (314) 725-6000. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Argent Capital Management, LLC is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training. The oral and written communications of an
investment adviser provide you with information about which you determine to hire or retain an
investment adviser. Additional information about Argent also is available on the SEC’s website at
www.adviserinfo.sec.gov.
A copy of our current brochure may be requested by contacting Suzanne Hammer, Chief Compliance
Officer, at (314) 725-6000 or shammer@argentcapital.com. Our brochure is also available free of charge
on our website at www.argentcapital.com.
The SEC’s website also provides information about any persons affiliated with Argent who are
registered, or are required to be registered, as investment adviser representatives of Argent.
Item 2: Material Changes
There have been no material changes to Argent Capital Management, LLC’s brochure.
Pursuant to SEC rules, the Adviser will ensure that its clients receive a summary of any material
changes to this and subsequent Brochures within 120 days of the close of its business fiscal year.
Argent Capital Management, LLC — 2026 Disclosure Brochure
Page ii
Table of Contents
Item 1. Cover Page … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … … ...i
Item 2. Material Changes ............................................................................................................... Error! Bookmark not defined.
Item 3. Table of Contents ............................................................................................................ Error! Bookmark not defined.ii
Item 4. Advisory Business ............................................................................................................. Error! Bookmark not defined.
Item 5. Fees and Compensation .................................................................................................................................................................... 3
Item 6. Performance-Based Fees and Side-By-Side Management.................................................................................... 4
Item 7. Types of Clients ........................................................................................................................................................................................ 4
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .............................................................................. 4
Item 9. Disciplinary Information ...................................................................................................................................................................... 5
Item 10. Other Financial Industry Activities and Affiliations ....................................................................................................... 5
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................... 5
Item 12. Brokerage Practices .......................................................................................................................................................................... 6
Item 13. Review of Accounts ........................................................................................................................................................................... 7
Item 14. Client Referrals and Other Compensation ......................................................................................................................... 8
Item 15. Custody ....................................................................................................................................................................................................... 8
Item 16. Investment Discretion ....................................................................................................................................................................... 8
Item 17. Voting Client Securities.................................................................................................................................................................... 8
Item 18. Financial Information ......................................................................................................................................................................... 9
Table 1: Risks Associated with Investments ....................................................................................................................................... 10
Brochure Supplement
Argent Capital Management, LLC — 2026 Disclosure Brochure
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Item 4: Advisory Business
Argent Capital Management, LLC (“Argent”) was founded in 1998 and is a registered investment
adviser. We are a Missouri limited liability company that is 100% owned by current employees, of which
Steven L. Finerty is the principal owner.
Our Mission
Argent’s mission is to provide superior investment management in conjunction with a level of personal
service and communication that is unique in the investment management community. We provide
investment advice to endowments, foundations, pension funds, investment companies and high net
worth individuals.
As of December 31, 2025, Argent had approximately $3,987,501,445 in assets under management,
including $3,801,321,413 of discretionary assets and $186,180,032 of non-discretionary assets.
In addition to advising on publicly traded equity securities, we may provide advice with respect to a
client’s investments in mutual funds, exchange-traded funds, investment grade corporate bonds,
government bonds, commercial paper, certificates of deposit, warrants, limited partnerships, real
estate investment trusts and money market funds. Investing in securities involves risk of loss that
clients should be prepared to bear. Please see Table 1 at the end of this disclosure for an important
summary of the primary investment risks and the steps taken by Argent to manage these risks.
Investment Philosophy
Argent provides investment management services for domestic equity portfolios. We have built all of
our strategies upon a similar investment philosophy. Argent invests in high quality, enduring businesses
that have growing cash flows, a durable competitive position and allocate capital wisely. This results
in a concentrated portfolio of best ideas for our clients.
Argent employs a team approach to portfolio management, with each of the firm’s investment
strategies being managed by a portfolio manager, who is supported by a team of analysts. The firm’s
Investment Committee is responsible for the oversight and management of Argent Capital
Management’s investment strategies. Argent is built on the concept of collaborative investment
processes and empowered investment professionals. The purpose of the Investment Committee is to
formalize the sharing of ideas and foster communication across and between Argent’s portfolio
management teams. This team approach allows us to make prompt investment decisions while
avoiding the burden of a large bureaucratic structure.
Large Capitalization Strategy
The goal of the Large Cap Strategy is to outperform our benchmarks, either the S&P 500® or the
Russell 1000 Growth® Index, over the long term. Our review begins with a universe of all U.S.
companies with a market capitalization of $3 billion or more.
Argent Capital’s® Large Cap Strategy consists of a portfolio of 30-35 stocks. Each of these stocks must
demonstrate the characteristics consistent with our investment approach. Argent invests in high
quality, enduring businesses that have growing cash flows, a durable competitive position and allocate
capital wisely. Argent’s Large Cap process results in a concentrated, low turnover portfolio of
companies that we seek to own for the long term.
Argent is also the sub-advisor to the Argent Large Cap ETF® (ticker: ABIG).
Dividend Select Strategy
The goal of the Dividend Select Strategy is to outperform the Russell 1000 Value® over the long term.
Our review begins with a universe of all U.S. companies with a market capitalization of $3 billion or
more.
Argent Capital Management, LLC — 2026 Disclosure Brochure
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Argent Capital’s® Dividend Select Strategy consists of a portfolio of 30-35 dividend paying stocks. Each
of these stocks must demonstrate the characteristics consistent with our investment approach. Argent
invests in high quality, enduring businesses that have growing cash flows, a durable competitive
position and allocate capital wisely. Argent’s Dividend Select process results in a concentrated, low
turnover portfolio of companies that we seek to own for the long term.
Mid Capitalization Strategy
The goal of the Mid Cap Strategy is to outperform the Russell Mid Cap® Index over the long term.
Argent’s Mid Cap process begins by screening the approximately 1,500 companies with market
capitalizations in the range of the Russell Midcap Index® and average daily trading volume of $20
million.
Argent Capital’s® Mid Cap Strategy consists of a portfolio of 40-50 stocks. The Mid Cap Strategy
utilizes an integrated blend of quantitative and fundamental research to identify opportunities to
purchase ownership stakes in good businesses that meet our criteria of investing in high quality,
enduring businesses that have growing cash flows, a durable competitive position and allocate capital
wisely. Argent’s Mid Cap process results in a concentrated, low turnover portfolio of companies that
we seek to own for the long term.
Argent is also the sub-advisor to the Argent Mid Cap ETF® (ticker: AMID).
Focused Small Capitalization Strategy
The goal of the Focused Small Cap Strategy is to outperform its benchmark the Russell 2000® Index
over the long term. We will typically invest in stocks within the market capitalization range of the
Russell 2000® at the time of investment/purchase.
Argent Capital’s® Focused Small Cap Strategy consists of a portfolio of 35-45 stocks. Each of these
stocks must demonstrate the characteristics consistent with our investment approach. Argent invests
in high quality, enduring businesses that have growing cash flows, a durable competitive position and
allocate capital wisely. Argent’s Focused Small Cap process results in a concentrated, low turnover
portfolio of companies that we seek to own for the long term.
Argent is also the sub-advisor to the Argent Focused Small Cap ETF® (ticker: ALIL).
SMID Capitalization Strategy
The goal of the SMID Cap Strategy is to outperform the Russell 2500® Index over the long term.
Argent’s SMID Cap process begins by screening the approximately 2,500 companies with market
capitalizations in the range of the Russell SMID Cap Index®.
Argent Capital’s® SMID Cap Strategy consists of a portfolio of 40-50 stocks. The SMID Cap Strategy
utilizes an integrated blend of quantitative and fundamental research to identify opportunities to
purchase ownership stakes in good businesses that meet our criteria of investing in high quality,
enduring businesses that have growing cash flows, a durable competitive position and allocate capital
wisely. Argent’s SMID Cap process results in a concentrated, low turnover portfolio of companies that
we seek to own for the long term.
All of Argent’s strategies are available as separately managed accounts.
Sell Discipline
In implementing our strategies, we generally purchase a security with the intent of holding it for the
long term. If a company’s execution deteriorates and/or valuation becomes excessive relative to our
investment thesis, we sell and direct the assets to a more attractive opportunity.
Argent Capital Management, LLC — 2026 Disclosure Brochure
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Specifically, we may sell a security for any reason, including but not limited to: excessive valuation;
poor execution; permanent impairment of the company; an individual stock holding representing
greater than a predetermined percentage of the total portfolio; or a source of cash for a better
opportunity.
Item 5: Fees and Compensation
Separate Account Fees
Argent’s fees are established in a written Investment Advisory Agreement, and are typically calculated
as a percentage of assets under management according to the following schedule:
Standard Fee Schedule (All Strategies)
1.00% on first $1,000,000
0.80% on next $2,000,000
0.65% on balance
Institutional Fee Schedule (All Strategies)
0.75% on first $10,000,000
0.55% on next $15,000,000
0.50% on balance
Standard and Institutional account fees are typically billed quarterly in advance, based on the market
value of each client account as of the last day of the prior quarter. We may negotiate or waive fees in
certain circumstances. We pro-rate fees for accounts that have been funded less than a calendar
quarter at the time of billing.
in selecting broker-dealers for client
transactions and determining
Argent’s fees do not include custodian fees, brokerage commissions or securities transaction fees
charged by a client’s custodian and/or broker/dealer. Our fees also do not include any fees that may
be charged by mutual fund companies for accounts that hold mutual fund shares. Such charges, fees
and commissions incurred by the client are in addition to our fee, and we shall not receive any portion
of these charges, fees and commissions. Please see “Brokerage Practices” on page 9 for the factors
that we consider
the
reasonableness of their commissions.
Argent will assist clients in establishing a custodial account at the client’s request. Clients typically
grant us authority to deduct our fees directly from the client’s custodial account, although we may
send an invoice directly to clients upon their request. Argent will direct the custodian to send clients a
statement reflecting the deduction of all fees from the account The client is responsible for verifying
the accuracy of the fee calculation, as the client’s custodian will not determine if the fee was properly
calculated. Clients retain ownership of all funds and securities in their accounts.
Clients may terminate an Investment Advisory Agreement upon written notice to Argent, or as
otherwise noted in their Investment Advisory Agreement with Argent. Clients will receive a pro-rata
refund of any advisory fees paid, but not yet earned, as of the date of termination.
Argent may act as an independent investment manager pursuant to an agreement where an
unaffiliated investment manager may allocate a portion of a client’s investment assets to implement
an Argent strategy. The investment management fee charged by Argent is separate from, and in
addition to, unaffiliated investment manager advisory fee.
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Item 6: Performance-Based Fees and Side-By-Side Management
Argent previously offered performance-based fee arrangements for certain investment strategies. A
performance fee arrangement is a method of compensating an investment adviser based on a share
of the gains or appreciation of the assets under management. For any measurement period, a
performance-based fee may be higher or lower than Argent’s current fee schedule. Performance fee
arrangements are no longer offered to new Argent clients for any of Argent’s investment strategies.
Argent will continue to maintain historical performance-based fee arrangements with existing clients
who previously qualified and were subject to such fees.
Argent’s performance-based fee arrangements were in compliance with Section 205(e) of the
Investment Advisers Act of 1940. According to Section 205(e) (see Rule 205-3 thereunder), only natural
individual clients meeting the SEC’s definition of “Qualified Clients” may enter into agreements
providing for performance-based compensation to Argent, with Qualified Clients defined as having
either $1,100,000 under management with Argent or a net worth of $2,200,000 (excluding the value of
the Client’s primary residence and debt secured by the residence, up to the estimated value of the
residence). Argent required performance-based fee accounts to have a minimum account size of
$500,000, which may be waived at Argent’s discretion based on individual client circumstances.
Qualified Clients that were charged a performance fee were not otherwise charged an annual asset
management fee.
Item 7: Types of Clients
Argent provides investment advice to endowments, foundations, pension funds, investment
companies and high net worth individuals. For new standard (non-institutional) accounts, we have
established minimum initial account values of $150,000 and for institutional accounts a minimum of
$2,000,000 for all strategies, which may be waived or lowered at our discretion. Accounts maintained
at levels below the stated initial account values will be periodically reviewed with the client.
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss
Argent’s primary activity is advising on publicly traded equity securities. In addition, we may provide
advice with respect to a client’s investments in other securities such as mutual funds, exchange-traded
funds, investment grade corporate bonds, government bonds, commercial paper, certificates of
deposit, warrants, limited partnerships, real estate investment trusts and money market funds.
Investing in securities involves risk of loss that clients should be prepared to bear. It is important that
clients understand that risk of loss must generally be assumed in order to achieve long-term
investment objectives. Argent does not offer any guarantee that the strategies it recommends and/or
employs within client portfolios will produce desired results or avoid loss. Investing money in the
financial markets carries with it numerous risks. The primary risk is market risk, including the possibility
of loss stemming from market declines in various asset classes, rising interest rates, and rising credit
spreads, among other influences.
While Argent strives to construct portfolios that are diversified, there is no guarantee that market forces
will not overwhelm diversification efforts, subjecting clients to correlation risk. Recognizing that
assuming some type of risk is unavoidable, Argent takes a risk-based approach to reduce the
probability and magnitude of losses. Such risk management steps include proper asset and sector
allocation, proactive tactical shifts to exploit opportunities or avoid risks, in-depth and independent
research, and regular portfolio monitoring and client reviews.
Please see Table 1 at the end of this disclosure for an important summary of the primary investment
risks and the steps taken by Argent to manage these risks. Please note this list is intended to highlight
primary risks of investing assets with Argent, but it does not capture all such risks.
Argent provides investment management services for domestic equity portfolios which are comprised
primarily of large capitalization, mid capitalization or small capitalization companies. For more
Argent Capital Management, LLC — 2026 Disclosure Brochure
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information on our Investment Strategies and Methods of Analysis, please refer to “Advisory Business”
on page 1.
Item 9: Disciplinary Information
A registered investment adviser is required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of the adviser or the integrity of the
adviser’s management. Argent has no legal or disciplinary actions to report.
Item 1 0: Other Financial Industry Activities and Affiliations
Logan Finerty, President of Argent, is a current partner of Moneta Group Investment Advisors, LLC
(“Moneta”), a registered investment adviser that offers comprehensive financial planning services.
Steven L. Finerty, Chairman and CEO of Argent, was a partner of Moneta until December 31, 2024.
Moneta partners may refer to Argent those clients requesting individual equity management services.
Argent charges an advisory fee as described in “Fees and Compensation” on page 6. Moneta and its
partners may also receive fees from clients for managing client portfolios, including the assets that are
managed by Argent, although Steven Finerty and Logan Finerty credit any Argent fees against Moneta
fees. No client is obligated to use Argent for equity management services as a result of a referral by
Moneta partners.
Argent provides investment management services to certain clients pursuant to a sub-advisory
agreement. Argent receives a sub-advisory fee based on a percentage of assets under management.
Argent may act as an independent investment manager pursuant to an agreement where an
unaffiliated investment manager may allocate a portion of a client’s investment assets to implement
an Argent strategy.
Item 1 1 : Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Argent has adopted a Code of Ethics for all supervised persons of the firm describing its high standard
of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to
personal trading procedures, the confidentiality of client information, a prohibition on insider trading,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
entertainment items, among other things. The Code of Ethics also requires all covered persons to
comply with federal securities laws and avoid activities, interests, and relationships that might interfere
with making decisions in the best interest of client portfolios. All Argent supervised persons certify their
knowledge of and obligations under the Code of Ethics annually.
The Code of Ethics is designed to assure that the personal securities transactions, activities and
interests of our employees will not interfere with making decisions in the best interest of Argent’s
advisory clients. Subject to the Code of Ethics and applicable laws, officers, directors and employees
of Argent may trade for their own accounts in securities which are recommended to and/or purchased
for our clients. In addition, the Code of Ethics requires pre-clearance of many transactions, and restricts
trading in close proximity to client trading activity. Employee trading is monitored under the Code of
Ethics to reasonably prevent conflicts of interest between Argent and its clients.
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated
basis when consistent with Argent’s obligation of best execution. In such circumstances, the affiliated
and client accounts will receive the average price paid or received for the entire aggregated trade. We
will retain records of the trade order (specifying each participating account) and its allocation, which
will be completed prior to the entry of the aggregated order. Completed orders will be allocated as
specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any
exceptions will be explained on the order.
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We will not affect any principal transactions for client accounts and cross trades between client
accounts are allowed in limited circumstances when in the best interest of the client and properly
documented with all parties.
You may obtain a copy of Argent’s Code of Ethics by sending a written request to: Code of Ethics
Information Request, Argent Capital Management, LLC, 100 South Brentwood Boulevard, Suite 110, St.
Louis, Missouri 63105.
Item 1 2: Brokerage Practices
Argent typically has the discretion to select the broker/dealer that will provide the best execution of a
portfolio transaction at the best price for client accounts. When we select a broker/dealer, we are
responsible for exercising discretion regarding commissions paid by client accounts. For each specific
transaction, we use our best judgment to select the broker/dealer most capable of providing the
necessary services to obtain the best available price and the most favorable execution. Best available
price and most favorable execution generally describe a policy of executing portfolio transactions at
prices which provide the most favorable total cost or net proceeds that are reasonably obtainable
under the circumstances.
for
transactions
In addition to price, we may consider additional broker/dealer services when selecting a
broker/dealer
trading ability, capital strength,
including among others:
communications, settlement processing, automation, knowledge of other buyers or sellers,
administrative ability, underwriting, and provision of information on the particular security or market.
The specific criteria used vary depending upon the nature of the transaction, the market, and number
of broker/dealers capable of affecting the transaction.
In recognition of the value of these factors, transactions will not always be executed at the lowest
commission rate available. Negotiated rates will be based upon our judgment of the rates, which
generally reflect the execution requirements of the transaction regardless of whether the broker
provides research services to Argent. We may also consider utilizing brokers who supply research or
brokerage services to us. Client accounts may pay commission rates in excess of those that another
broker/dealer would have charged for effecting the same transaction if we determine, in good faith,
that the commission paid is reasonable in relation to the value of the research or brokerage services
provided as permitted by Section 28(e) of the Securities Exchange Act of 1934.
Argent receives both research services that are proprietary to broker/dealers effecting transactions,
and third-party research and brokerage services provided by broker/dealers through “soft dollars.” We
receive a benefit because we do not have to produce or pay for the services. We may use research
and brokerage services furnished by broker/dealers to service any or all of our clients, including
accounts other than those that pay commissions to the broker/dealer providing the services. We may
allocate brokerage for research and brokerage services that are also available for cash, where
appropriate and permitted by law and may pay cash for certain research services received from
external sources.
through meetings with corporate and
Research services provided may include, among other things, economic or company information,
accounting and tax law/interpretations, political and legal developments, technical market action,
quotes, pricing systems, market index information, appraisal services, or analysis. Research services
may be in the form of computer-generated data, software, support and related maintenance costs.
Research services may also be provided
industry
spokespersons, economists, academicians and government representatives. Brokerage services may
include, among other things, our order management system and messaging database utilized to
execute trades.
In all circumstances where research or brokerage services are provided by broker/dealers with “soft
dollars,” and such research or brokerage services are also used by us for administrative purposes (such
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as the preparation of client account valuations), a reasonable allocation is made by us so that the value
of the service for making investment and brokerage decisions is borne by client accounts, and the
value attributable to administrative functions is borne by Argent (and paid in cash by us.)
Clients should be aware that they have brokerage options. Argent will execute transactions through a
particular brokerage firm as a result of a client’s direction or if Argent were to participate in a Wrap Fee
Program. If a client decides to participate in a wrap-fee program, the client will be responsible for
negotiating the commission rates paid by the client for the execution of transactions. In directed broker
arrangements, the client should be aware of Argent’s inability to negotiate commissions, obtain volume
discounts and that best execution may not be achieved for transaction in the client’s account(s). As a
result, transactions in accounts directed by a client to a particular brokerage firm may result in higher
commissions, greater spreads or less favorable net prices than would be the case if Argent were
authorized to choose the brokerage firm through which to execute transaction for the client’s
account(s). Argent currently does not participate in wrap-fee programs.
Argent frequently aggregates client orders for execution, which generally results in lower commission
rates. When the aggregate order is executed at various prices on a given day, each participating client’s
proportionate share of such order reflects the average price paid or received with respect to the total
order. In limited circumstances, due to low liquidity, orders may be executed over multiple days with
the average price paid or received applied to accounts participating on that day. For trades taking
multiple days to complete, the order in which accounts participate is rotated so as not to give
advantage to any particular group of accounts. In managing accounts, Argent attempts to allocate
securities fairly among client accounts based on each account’s investment style, applicable
restrictions, other holdings and availability of cash and securities, but cannot ensure that all accounts
will participate equally, or even at all, in every investment. Personal trades for employees of Argent
will from time to time be included in aggregated orders with trades in client accounts.
If Argent makes an error in submitting a trade order on a client’s behalf, Argent will follow its formal
trade error policy. In general, this policy states that if an erroneous trade cannot be broken, then Argent
will place a correcting trade with the broker-dealer (the “correcting trade”). If the correcting trade
results in a loss to the broker-dealer, Argent will issue a check to cover the loss from company funds
and the client account will not be affected in any way. If the correcting trade results in a gain, Argent
will review the circumstances and, if appropriate, will apply the gain to the client’s account; if, however,
the correcting trade affects several client accounts or is not appropriate, then the gain will be retained
by the broker-dealer or directed to a charitable organization. In all cases, any correcting entries will be
made in the best interest of the client.
Item 1 3: Review of Accounts
Argent reviews portfolios to confirm that each is being managed consistent with the client’s stated
goals and objectives and Argent’s investment strategies. All portfolios are reviewed at least annually
by the portfolio managers, along with representatives from the Client Services, Operations, and
Compliance Teams.
In addition to these reviews clients may receive regular written reports from Argent regarding their
account. The nature and frequency of these reports are determined primarily by the particular needs
of each client. Generally, large capitalization strategy clients receive monthly reports of all trades for
that period, unless they opt out. Generally, small and mid capitalization strategy clients receive
quarterly reports that include summary information on strategy holdings, returns, characteristics and
sector weights unless they opt out. Additionally, our portfolio managers are available, upon reasonable
request, to conduct special reviews or meet with clients to discuss investment policies and strategies
employed to achieve clients’ investment objectives.
Clients will retain ownership of all funds and securities in their accounts. Additionally, clients will
receive monthly or quarterly reports from the client’s broker/dealer and/or custodian that include
Argent Capital Management, LLC — 2026 Disclosure Brochure
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confirmation of all securities transactions in their account during that month. Please see “Custody” on
page 9 for further information.
Item 1 4: Client Referrals and Other Compensation
Argent does not enter into written agreements with third-party individuals to function as solicitors or
to receive cash compensation for referral of client accounts. If such arrangements are approved in the
future, Argent will comply with the Testimonials, Endorsement and Solicitation provisions of The
Marketing Rule (Rule 206(4)-1 by providing all parties full disclosure and proper documents of the
arrangement. Note that Argent’s officers, directors, or employees may receive compensation for
referring clients as a part of their normal course of work.
Item 1 5: Custody
Clients retain ownership of all funds and securities held in their accounts, which are maintained by a
broker-dealer, bank, or other qualified custodian. Clients should receive account statements from the
custodian, at least quarterly, and are advised to review such statements carefully. Clients should
compare these custodial statements with any account statements or reports provided by Argent, as
discrepancies may occur due to differences in accounting procedures, reporting dates, or valuation
methodologies for certain securities.
Argent is generally authorized to deduct advisory fees directly from client accounts. Such fee
deductions will be reflected in the custodian’s account statements. The custodian does not verify the
accuracy of advisory fee calculations; therefore, clients should review all fee deductions for accuracy.
Additional information regarding the deduction of advisory fees is provided in Item 5.
Item 1 6: Investment Discretion
Argent typically manages discretionary accounts. Accordingly, we usually receive discretionary
authority from the client at the outset of an advisory relationship to determine which securities are
bought and sold for each client’s account and the amount of such securities bought or sold. We
exercise such discretion in a manner consistent with the stated investment objectives for the particular
client account, and clients may impose reasonable restrictions on particular securities. We record
investment guidelines and restrictions in writing.
Item 1 7: Voting Client Securities (Proxy Voting)
Argent has adopted policies and procedures governing the voting of client proxies (the “Proxy Voting
Policy”), which are designed to meet the requirements of the United States Securities and Exchange
Commission and to fulfill the fiduciary duties owed to clients. The Proxy Voting Policy is intended to
provide Argent employees with principles to guide their voting of proxies in an informed and
responsible manner in the best interests of our clients by using a defined process for evaluating proxy
issues. We have retained Broadridge Proxy Policies & Insights (PPI) Shareholder Value Template to
provide proxy-related services to us. The SV Template provides data-driven vote instructions based
on the annual voting trends from publicly disclosed vote records of top fund families, selected by
assets under management, and whose goal is to maximize shareholder value. We generally intend to
follow the recommendations of the Broadridge SV Template in a manner consistent with our Proxy
Voting Policy.
The guidelines in the Proxy Voting Policy address a broad range of topics including, but not limited to,
those related to corporate governance, changes to corporate structure, the board of directors, and
compensation. Argent shall make a reasonable effort to monitor corporate actions and obtain sufficient
information to make an informed voting decision in your best long-term interests. While we believe
this process will result in most voting decisions being made in accordance with the Policy, each vote
will be determined based upon a number of relevant factors. As a result, votes occasionally may
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deviate from the guidelines set forth in the Proxy Voting Policy. Argent’s Investment Committee will
make the voting decision in the case where an individual responsible for making proxy voting decisions
on your behalf proposes to make a voting decision that deviates from the Policy, or when the decision
involves a conflict of interest.
Clients may retain their rights to vote any or all proxies for their account. Clients must provide specific
voting instructions to Argent in writing and prior to the voting deadline.
You may obtain a copy of Argent’s Proxy Voting Policy or information regarding how we vote with
respect to your securities by sending a written request to: Proxy Voting Information Request, Argent
Capital Management, LLC, 100 South Brentwood Boulevard, Suite 110, St. Louis, Missouri 63105.
Item 1 8: Financial Information
We have no financial commitment that impairs our ability to meet our contractual and fiduciary
commitments to clients.
Argent Capital Management, LLC — 2026 Disclosure Brochure
Page 9
Table 1 : Risks Associated with Investments
As previously noted in Item 8, please read this important summary of primary investment risks and the
steps taken by Argent to minimize these risks. Please note this list is intended to highlight primary risks
of investing assets with Argent, but it does not capture all such risks.
Risk
Disclosure Statement
Mitigation
Risk of Loss –
General
Investing in securities involves risk of loss, including
the possibility of total loss, that clients should be
prepared to bear.
Diversification, asset
allocation, tactical
changes in allocation
Market
Fluctuation
Investment plan suited to
client objectives, liquidity
needs, and time horizon
Financial markets and the value of investments
fluctuate substantially over time, which may lead to
losses in the value of client portfolios, especially in
the short run.
times of market
Asset Class
Correlations
During
turmoil, correlations
between asset classes may break down, which may
result in higher-than-expected losses for diversified
portfolios.
Continuous monitoring,
rebalancing,
communication, and
disclosure
Mutual Funds
Portfolio construction
and diversification
Mutual fund investing involves risk; principal loss is
possible. Investors will pay fees and expenses, even
investment returns are flat or negative.
when
Investors cannot influence the securities bought and
sold, nor the timing of transactions which may result
in undesirable tax consequences.
Portfolio construction
and diversification
Exchange-
Traded Funds
(ETFs) and
Exchange
Traded Notes
(ETNs)
ETFs and ETNs are subject to risks similar to those of
stocks and are not suitable for all investors. Shares
can be bought and sold through a broker, and the
selling shareholder may have to pay brokerage
commissions in connection with the sale. Investment
returns and principal value will fluctuate so that
when shares are redeemed, they may be worth
more or less than original cost. Shares are only
redeemable directly from the fund. There can be no
assurance that an active trading market for the
shares will develop or be maintained, and shares
may trade at, above or below their NAV. Additionally,
ETNs and some ETFs are not structured as
investment companies and thus are not regulated
under the Investment Company Act of 1940. An
ETN’s value generally depends on the performance
of the underlying index and the credit rating of the
issuer. Additionally, the value of the investment will
fluctuate in response to the performance of the
underlying benchmark. ETFs and ETNs incur fees
that are separate from those fees charged by Argent.
Accordingly, our investments in ETFs and ETNs will
result in the layering of fees and expenses.
Fixed Income
Vary maturities, careful
selection of securities to
match client risk
Prices of fixed income (debt) securities typically
decrease in value when interest rates rise. This risk is
usually greater for longer-maturity debt securities.
Investments in debt with lower credit ratings (and
Argent Capital Management, LLC — 2026 Disclosure Brochure
Page 10
Risk
Disclosure Statement
Mitigation
tolerance and time
horizon
non-rated credits) are subject to a greater risk of loss
to principal and interest than those with higher credit
ratings.
Inflation Risk
Asset allocation and
security selection
Risk that increases in the prices of goods and
services, and therefore the cost of living, reduce
consumer purchasing power.
Liquidity Risk
Asset allocation and
security selection
Risk evident when investors do not have full access
to their funds and/or when assets cannot be
converted into cash according to normal market
settlement standards. Liquidity risk is generally
higher for small capitalization stocks, alternative
assets, and private placement securities.
Income Risk
Portfolio construction
and financial planning to
avoid asset depletion
Risk that an
investment strategy designed to
generate a sufficient income, resulting in the inability
to sustain a desired lifestyle and/or the need to sell
other assets to generate desired income.
Socio-political
Risk
the market
in general and
result
Understanding of client
objectives, liquidity
needs, and time horizon;
portfolio construction,
diversification, ongoing
monitoring, and
rebalancing
Sociopolitical risk is the possibility that instability or
unrest in one or more regions of the world will affect
investment markets. Terrorist attacks, war, and
pandemics are just examples of events, whether
actual or anticipated, that impact investor attitudes
toward
in
systemwide fluctuations in currencies as well as
prices of securities and commodities.
Cyber-Security
Risk
information
Established business
continuity plans and
information security risk
management systems
which include among
other controls, access
restrictions, cyber
training, security incident
response plan, and
cybersecurity insurance
the unauthorized
As the use of technology has become more
prevalent in the normal course of business, Argent
and other firms are more susceptible to operational
and information security risks. Cyber incidents can
result from deliberate attacks or unintentional
events and include, but are not limited to, gaining
unauthorized access to electronic systems for
purposes of misappropriating assets, personally
identifiable
(“PII”) or proprietary
information (e.g., trading models and algorithms),
corrupting data, or causing operational disruption,
for example, by compromising trading systems or
accounting platforms. Other ways in which the
business operations of Argent, other service
providers, or issuers of securities in which Argent
invests a client’s assets may be impacted include
interference with a client’s ability to value its
portfolio,
release of PII or
confidential information, and violations of applicable
privacy, recordkeeping and other laws. A client
and/or its account could be negatively impacted as
a result. While Argent has established internal risk
management security protocols designed
to
identify, protect against, detect, respond to, and
recover from cybersecurity incidents, there are
inherent limitations in such protocols including the
Argent Capital Management, LLC — 2026 Disclosure Brochure
Page 11
Risk
Disclosure Statement
Mitigation
nature
of
Argent
cybersecurity
cannot
possibility that certain threats and vulnerabilities
have not been identified or made public due to the
threats.
evolving
the
control
Furthermore,
cybersecurity systems of
third-party service
providers or issuers. While Argent does maintain
cybersecurity insurance coverage, there currently is
no insurance policy available to cover all the
incidents.
potential risks associated with cyber
Unless otherwise agreed to in writing by Argent or
required by applicable law, Argent shall not be
deemed a guarantor against, nor liable for, any
damages resulting from a cybersecurity related
incident.
Pandemics
Understanding of client
objectives, liquidity
needs, and time horizon;
asset allocation, portfolio
construction,
diversification, ongoing
monitoring, and
rebalancing
Occurrences of epidemics, pandemics, or other
widespread public health events may, depending on
their scale and duration, adversely affect global,
national, and local economies. Such events may
create significant uncertainty and rapidly changing
conditions, the full impact of which may be difficult
to predict or quantify. These conditions may
materially and adversely affect the volatility, value,
and performance of securities held
in client
accounts, as well as Argent’s ability to purchase or
sell such securities at advantageous times or prices.
Argent Capital Management, LLC — 2026 Disclosure Brochure
Page 12
Additional Brochure: ARGENT CAPITAL MANAGEMENT LLC PART 2B SUPPLEMENT (2026-03-27)
View Document Text
100 S. Brentwood Blvd., Suite 110
St. Louis, Missouri 63105
314-725-6000
www.argentcapital.com
March 31, 2026
Form ADV Part 2B - Brochure Supplement
Item 1 – Cover Page
This brochure supplement provides information about Argent’s Investment Team personnel that
supplements the Argent brochure. You should have received a copy of that brochure. Please contact
Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000 if you did not receive Argent’s brochure
or if you have any questions about the contents of this supplement.
As a firm, we believe that we make the best decisions for our clients when our collaboration is at its
highest. In 2022, we formalized this philosophy to better leverage the depth of talent and resources
across our investment team and broader organization.
We are structured as a team of generalists, with analysts working collaboratively across the
capitalization spectrum. This approach empowers our investment team and fosters an entrepreneurial
research environment characterized by frequent interaction, shared insight, and continuous idea
generation between team members daily. Within this structure, our investment team is positioned to
uncover the most compelling Enduring Businesses for our clients, regardless of sector or market
capitalization. This team-based approach also promotes continuity and consistency, enabling any
member of Argent’s portfolio management team to step in and seamlessly manage any Argent
strategy at a moment’s notice.
Additional information about Argent’s Investment Team personnel is available on the SEC’s website at
www.adviserinfo.sec.gov
Argent Capital Management, LLC Investment Team
Scott Harrison, CFA
M. Jed Ellerbroek, Jr., CFA
Peter Roy, CFA
Portfolio Manager:
Dividend Select
Portfolio Manager:
Large Cap
Portfolio Manager:
Focused Small Cap
SMID Cap
Kirk McDonald, CFA
Ward Brown
Bill Weeks, Ph.D., CFA
Director of Portfolio
Engagement
Senior Research Analyst,
Quantitative
Portfolio Manager:
Mid Cap
SMID Cap
Brian Reynolds, CFA, CFP
Steven K. Smith, CFA
Raymond Winter
Senior Research
Analyst
Senior Research
Analyst
Research
Analyst
Professional Certifications
Select employees have earned certifications which are explained in detail below.
Chartered Financial Analyst (CFA)
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment
credential established in 1962 and awarded by CFA Institute — the largest global association of
investment professionals.
There are currently more than 200,000 CFA charterholders working in 164 countries. To earn the CFA
charter, candidates must: 1) pass three sequential exams (Levels I, II, III); 2) have at least four years of
qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide
by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of
Professional Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active
professional conduct program, require CFA charterholders to:
• Place their clients’ interests ahead of their own
• Maintain independence and objectivity
• Act with integrity
• Maintain and improve their professional competence
• Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates
report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates
mastery of many of the advanced skills needed for investment analysis and decision making in today’s
quickly evolving global financial industry. As a result, employers and clients are increasingly seeking
CFA charterholders - often making the charter a prerequisite for employment.
Additionally, regulatory bodies in over 30 countries and territories recognize the CFA charter as a proxy
for meeting certain licensing requirements, and more than 125 colleges and universities around the
world have incorporated a majority of the CFA Program curriculum into their own finance courses.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for investment
decision making and is firmly grounded in the knowledge and skills used every day in the investment
profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental
and advanced investment topics, including ethical and professional standards, fixed-income and
equity analysis, alternative and derivative investments, economics, financial reporting standards,
portfolio management, and wealth planning.
The CFA Program curriculum is updated every year by experts from around the world to ensure that
candidates learn the most relevant and practical new tools, ideas, and investment and wealth
management skills to reflect the dynamic and complex nature of the profession. To learn more about
the CFA charter, visit: www.cfainstitute.org
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 2
Certified Financial Planner™ (CFP®)
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and
complete CFP Board-approved coursework at a college or university through a CFP Board
Registered Program. The coursework covers the financial planning subject areas CFP Board
has determined are necessary for the competent and professional delivery of financial
planning services, as well as a comprehensive financial plan development capstone course. A
candidate may satisfy some of the coursework requirements through other qualifying
credentials.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is
designed to assess an individual’s ability to integrate and apply a broad base of financial
planning knowledge in the context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal
financial planning process, or 4,000 hours of apprenticeship experience that meets additional
requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by the CFP Board’s Code of Ethics
and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice
standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board Certification
Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary when providing
financial advice, and therefore, act in the best interests of the client, at all times when providing
financial advice and financial planning. CFP Board may sanction a CFP® professional who does
not abide by this commitment, but CFP Board does not guarantee a CFP® professional’s
services. A client who seeks a similar commitment should obtain a written engagement that
includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code and
Standards.
The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to
hold the CFP® certification. To learn more about the CFP® certification, visit www.cfp.net.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 3
Item 2 – Educational Background and Business Experience
Scott A. Harrison, CFA
Portfolio Manager – Dividend Select Strategy
Scott has 29 years of industry experience and serves as the Portfolio Manager for the Argent Dividend
Select strategy. As the lead decision maker for this strategy since its inception in 2005, Scott plays a
key role in shaping investment decisions and overseeing risk management.
A long-time member of Argent’s team, Scott joined the firm in 2000 as one of its earliest employees.
His extensive experience within the firm spans multiple roles, from operations to investment analysis,
giving him a comprehensive understanding of the company’s processes and strategies.
Scott holds a B.S. in Finance from the University of Missouri-St. Louis. In addition to being a CFA
charterholder, he is also an active member of both the CFA Institute and the CFA Society of St. Louis.
Mr. Harrison was born in 1976.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation to report.
Item 6 – Supervision
Mr. Harrison is supervised by CEO, Steven L. Finerty.
Harrison and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 4
Kirk McDonald, CFA
Portfolio Manager – Mid Cap and SMID Cap Strategies
Senior Research Analyst – Quantitative
Kirk, with an engineer’s mindset honed as a pilot after graduation from the Air Force Academy,
leverages his expertise in quantitative research to lead Argent’s quantitative screening and risk
management efforts across all strategies. As Portfolio Manager of the Mid Cap Equity and SMID Cap
strategies, Kirk manages client portfolios and plays a key role in investment decisions. He developed
the Argent Mid Cap strategy, which the firm began marketing in March 2014. Kirk performs primary
market research, focusing his analysis across the universe of mid-capitalization stocks.
Kirk, a Chartered Financial Analyst, has 23 years of experience in the industry. Prior to joining Argent in
2011, he was a portfolio manager for Fiduciary Asset Management LLC (FAMCO). His background also
includes serving as a senior consultant for Arthur Andersen and as mentioned previously, serving as a
pilot in the United States Air Force.
He is a member of the Chicago Quantitative Alliance and co-founder and past president of the St. Louis
Chapter of the United States Air Force Academy Association of Graduates. In addition, Kirk is active in
the community, volunteering as a committee member for the annual Memorial Day Remembrance at
Jefferson Barracks National Cemetery, serves on the board of directors for Wings of Hope, and he is
also a member of the CQA Investment Challenge, serving as a mentor to a team of students at Webster
University.
Kirk earned a B.S. from the United States Air Force Academy and a Master of Business Administration
from the University of Oklahoma. In addition to being a CFA charterholder, he is also an active member
of both the CFA Institute and the CFA Society of St. Louis.
Mr. McDonald was born in 1967.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation to report.
Item 6 – Supervision
Mr. McDonald is supervised by CEO, Steven L. Finerty.
McDonald and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 5
Peter Roy, CFA
Portfolio Manager – Focused Small Cap and SMID Cap Strategies
Peter Roy, CFA, has specialized in small cap portfolio management and research for the last 27 years.
He brought that talent to Argent when he joined the organization in 2019. With his expertise, Argent
launched the Argent Focused Small Cap and SMID strategies. Peter has been the lead decision maker
for the Argent Focused Small Cap strategy since its inception in November 2022 and the Co-manager
for Argent SMID Cap since it was launched at the end of 2019. Peter plays a key role in investment
decisions for both strategies focusing on companies in the small capitalization range.
Prior to Argent, Peter successfully Co-Managed the PNC Select Equity Small Cap strategy for seven
years. Peter started his career in 2002 as an analyst on that investment team and progressed to senior
analyst and eventually portfolio manager.
Peter earned his Bachelor of Arts degree in English from the University of Dayton and an MBA with a
concentration in Finance from Washington University’s Olin School of Business. Peter played hockey
at Dayton and has helped coach three St. Louis area youth hockey teams to Blue Note Cup
Championships. In addition to being a CFA charterholder, he is also an active member of both the CFA
Institute and the CFA Society of St. Louis.
Mr. Roy was born in 1974.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation to report.
Item 6 – Supervision
Mr. Roy is supervised by CEO, Steven L. Finerty.
Roy and all Argent Investment Team professionals are supervised by policies and procedures relating
to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 6
M. Jed Ellerbroek, Jr., CFA
Portfolio Manager – Large Cap Strategy
Jed brings 20 years of industry experience to his role as Portfolio Manager for the Argent Large Cap
strategy. In this position, Jed plays a key role in guiding investment decisions and managing risk for the
strategy, applying his extensive background in financial analysis and portfolio management.
Before joining Argent in 2020, Jed spent over a decade at PNC Capital Advisors in St. Louis, where he
advanced from an analyst to an associate portfolio manager on the Select Equity Small Cap strategy.
His career also includes roles as an associate analyst at Wachovia Capital Markets and as an analyst at
Jeffrey Slocum & Associates, a consulting firm in Minneapolis, where he honed his analytical expertise
across various markets.
Jed holds dual degrees in Economics and Finance from the University of Northern Iowa. In addition to
being a CFA charterholder, he is also an active member of both the CFA Institute and the CFA Society
of St. Louis.
Mr. Ellerbroek was born in 1983.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation.
Item 6 – Supervision
Mr. Ellerbroek is supervised by CEO, Steven L. Finerty.
Ellerbroek and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 7
Ward Brown
Director of Portfolio Engagement
Ward serves as the Director of Portfolio Engagement. As Director, he serves as the liaison between the
investment team and the rest of the organization. He provides the investment teams with daily and
weekly technical analysis and market commentary.
Ward has 30 years of industry experience. Prior to joining Argent in 2013, he served as an Equity
Execution Consultant at Instinet LLC, where he managed a book of commission-based institutional
business. Ward began his career at Bridge Trading Company, where he held several positions, the
most recent as Co-Head of Institutional Trading. While at Bridge, Ward served in the company’s UK
office, developing its international brokerage arm. Ward earned a B.A. in Human and Organizational
Development from Vanderbilt University.
Mr. Brown was born in 1973.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation to report.
Item 6 – Supervision
Mr. Brown is supervised by CEO, Steven L. Finerty.
Brown and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 8
Brian J. Reynolds, CFA, CFP
Senior Research Analyst
Brian brings 19 years of industry experience to his role as Senior Research Analyst at Argent. In this
capacity, Brian is responsible for conducting fundamental investment research that supports all Argent
strategies, providing key insights to inform investment decisions.
Before joining Argent in 2022, Brian served as Assistant Vice President – Investment Research at
Concordia Plan Services, where he oversaw the management of pension plan assets for the Lutheran
Church – Missouri Synod. His career also includes experience as a Senior Research Analyst with PNC
Capital Advisors’ Select Equity Small Cap team, where he focused on in-depth fundamental research
on small and mid-cap companies.
Brian holds a B.S. in Business Administration with an emphasis in Finance and a minor in Accounting
from the University of Missouri – St. Louis. In addition to being a CFA charterholder, he is also an active
member of both the CFA Institute and the CFA Society of St. Louis.
Mr. Reynolds was born in 1985.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation.
Item 6 – Supervision
Mr. Reynolds is supervised by Director of Portfolio Engagement, Ward Brown.
Reynolds and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 9
Steven K. Smith, CFA
Senior Research Analyst
Steven brings over 11 years of industry experience to his role as a Senior Research Analyst at Argent,
where he conducts fundamental investment research to provide support across all Argent strategies.
Prior to joining Argent, Steven worked as an equity research analyst at Fidelity Investments Canada
from 2020 to 2022, specializing in the Consumer Staples sector. During his graduate studies in 2019, he
gained experience as a summer research analyst intern at Sunriver Management, a global long/short
equity investment firm. Earlier in his career, Steven served as an equity research associate analyst at
Edward Jones from 2014 to 2018, where he covered the Energy & Utilities and Technology & Telecom
sectors.
Steven holds a Master of Business Administration from the Value Investing Program at Columbia
Business School and a Bachelor of Science in Finance from St. Louis University. In addition to being a
CFA charterholder, he is also an active member of both the CFA Institute and the CFA Society of St.
Louis.
Mr. Smith was born in 1992.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation.
Item 6 – Supervision
Mr. Smith is supervised by Director of Portfolio Engagement, Ward Brown.
Smith and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 10
Bill Weeks, Ph.D., CFA
Senior Research Analyst, Quantitative
Bill brings 20 years of industry experience to his role as Senior Research Analyst, Quantitative at Argent.
Leveraging his background in artificial intelligence, Bill develops and applies machine-learning
algorithms to enhance Argent’s equity models, contributing to more advanced and effective
quantitative investment strategies.
Before joining Argent in 2020, Bill was a senior quantitative analyst at American Century Investments,
where he specialized in quantitative investment modeling. Prior to that, he served as Director of
Quantitative Research at the Kauffman Foundation, where he developed multifactor quantitative
models to inform investment decisions.
Bill earned dual degrees in Physics and Electrical Engineering from Washington University and went
on to complete his M.S. and Ph.D. in Electrical Engineering from the University of Illinois at Urbana-
Champaign. In addition to being a CFA charterholder, he is also an active member of the CFA Institute.
Dr. Weeks was born in 1972.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation.
Item 6 – Supervision
Dr. Weeks is supervised by Director of Portfolio Engagement, Ward Brown.
Weeks and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 11
Ray Winter
Research Analyst
Ray is a Research Analyst at Argent, where he contributes to the firm’s strategies by conducting
fundamental investment research.
Ray joined the firm in 2025, after completing his Bachelor’s Degree in Economics from Pomona College.
While completing his degree, Ray interned at Confluence Investment Management and Semper
Augustus Investments Group, gaining hands-on experience in macroeconomic analysis, equity
research, and investment evaluation. Ray is currently in pursuit of becoming a CFA charterholder.
Mr. Winter was born in 2001.
Item 3 – Disciplinary Information
There are no legal or disciplinary events that would be material to your evaluation of this supervised
person providing investment advice.
Item 4 – Other Business Activities
There are no outside business activities to report.
Item 5 – Additional Compensation
There is no additional compensation.
Item 6 – Supervision
Mr. Winter is supervised by Director of Portfolio Engagement, Ward Brown.
Winter and all Argent Investment Team professionals are supervised by policies and procedures
relating to the provision of investment advice. These policies include preauthorization of all marketing
materials, permanently recording all trading activity, reconciling accounts to custodians’ records daily,
and monitoring personal trading activities. For additional information regarding Argent’s supervisory
activities, please call Suzanne Hammer, Chief Compliance Officer, at (314) 725-6000.
Argent Capital Management, LLC — 2026 Disclosure Brochure Supplement
Page 12