ADV BROCHURE

DeWitt Capital Management dba InFocus Wealth Strategies dba MVP Money Moves 37 West Avenue, Suite 204B Wayne, PA 19087 Telephone: 610-910-9110 www.dewittcm.com October 7, 2026 FORM ADV PART 2A BROCHURE This Brochure provides information about the qualifications and business practices of DeWitt Capital Management. If you have any questions about the contents of this Brochure, please contact us at 610- 910-9110 or dtdewitt@dewittcm.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. DeWitt Capital Management is an investment adviser located in the State of Pennsylvania. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about DeWitt Capital Management is also available on the SEC's website at www.adviserinfo.sec.gov. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual amendment dated March 14, 2025, we have... • Form ADV Part 2 was submitted as the firm's application for registration with the U.S. Securities and Exchange Commission. • Clients are subject to a minimum $2,000 fee for Portfolio Management services, as described in Item 5. Currently, our Brochure may be requested by contacting David T. DeWitt, President, at 610-910-9110 or dtdewitt@dewittcm.com. Additional information about DeWitt Capital Management is available by accessing the SEC's web site at www.adviserinfo.sec.gov. The SEC's web site also provides information about any persons affiliated with DCM who are registered, or are required to be registered, as investment adviser representatives of the firm. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State-Registered Advisers Item 20 Additional Information Page 1 Page 2 Page 3 Page 4 Page 8 Page 10 Page 10 Page 10 Page 13 Page 13 Page 14 Page 14 Page 15 Page 16 Page 16 Page 16 Page 17 Page 17 Page 17 Page 17 3  Item 4 Advisory Business DeWitt Capital Management ("DCM") is an investment adviser located in the State of Pennsylvania. The firm was founded in 1996 by David T. DeWitt, owner and President of the firm. The firm's main office is located in Wayne, Pennsylvania. As of 2024, DCM may also offer investment advisory services under the d/b/a InFocus Wealth Strategies. DMC may conduct marketing and business development activities under the d/b/a "MVP Money Moves." MVP Money Moves is not a separate legal entity and does not provide advisory services independently of DeWitt Capital Management. All investment advisory services are provided by DeWitt Capital Management pursuant to its advisory agreements and regulatory registrations. The MVP Money Moves brand is used to market the firm's services to certain client segments, including current and former athletes. Portfolio Management Services DCM offers investment management services to its clients for a fee. DCM provides investment management services to clients on a discretionary or non-discretionary basis. DCM monitors clients' portfolios on a continuous basis and makes appropriate changes to the portfolio holdings as needed to maintain the objectives and policies of the account. DCM is responsible for the monitoring, review and trading recommendations in the managed account. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us 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 typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. If you engage us for non-discretionary portfolio management, we will obtain your consent (verbal or in writing) before effecting any transactions in your account and such consent will be document in DCM's books and records. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. DCM also offers services to other investment advisors whereby DCM acts as sub-advisor to certain client accounts. DCM offers a strategy of investment management that creates portfolios made up of master limited partnerships ("MLPs"). MLPs are limited partnerships that are publicly traded on securities exchanges. DCM designs strategies to take advantage of the tax benefits offered by limited partnerships, while allowing for the liquidity afforded by publicly traded exchanges. In addition to offering these investment strategies to its own clients, DCM acts as sub-advisor to other investment advisors who wish to utilize DCM's expertise in this area to benefit their own clients. DCM enters into written agreements with these other investment advisors to provide sub-advisory services. 4  As part of our portfolio management services, clients may engage us to provide advice related to held- away retirement assets, such as 401k plan assets. We use a third-party platform to faciliate the management of these assets. The platform allows us to avoid being deemed to have custody of these assets since neither the firm nor a person associated with the firm, has direct access to client log-in credentials to affect trades in these held-away accounts. We are not affiliated with the platform in any way and are not compensated by the platform for use of their services. In order to establish access to the held-away accounts for discretionary management, a link is provided to the client allowing them to connect a held-away account to the platform. Once this connection is established, we will review a client's investment allocations and will rebalance an account, as needed, consistent with a client's investment goals, risk tolerance, and objectives. Discretionary authority to manage these held-away assets is granted to us through an agreement executed by the client. Model Portfolios As part of our portfolio management services, we may invest your assets according to one or more model portfolios developed by our firm or by a third-party. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not be able to set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. For the benefit of no commissions or transactions fees, fully digital account opening, a large variety of security options and complete integration with software tools, DCM recommends Altruist Financial LLC, an unaffiliated registered broker/dealer, member FINRA/SIPC, as introducing broker to Apex Clearing Corporation, an unaffiliated registered broker/dealer, member FINRA/SIPC, which acts as the clients' custodian for these model portfolios. We participate in the Model Marketplace offered by Altruist LLC, a registered investment adviser and affiliate of Altruist Financial LLC. We may select model portfolios generated by Altruist LLC as part of their fully digital account program, or we may place client assets in other models available through Altruist LLC's Model Marketplace. Any applicable Altruist LLC advisory fees are charged directly to client accounts and are disclosed in the Altruist LLC disclosure brochure. Prior to introducing any clients to another investment adviser, DCM is responsible for determining if the other investment adviser is properly licensed, notice filed or exempt from registration in the jurisdiction in which the client resides and advisory services are offered. Financial Consulting Services DCM offers financial consulting services that primarily involve advising clients on specific financial- related topics. The topics DCM addresses may include, but are not limited to, asset allocation, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Clients may elect to engage us for financial consulting services on any of these topics, at the client's discretion and based on their needs. Clients may also engage us for other services, such as Model Portfolios described above, for example, and any such additional service will be described in a separate asset management agreement signed with DCM. Sub-Advisory Services to Independent Registered Investment Advisers 5  We offer sub-advisory services to unaffiliated third party investment advisers (the "Primary Investment Adviser"). As part of these services, we will manage assets delegated to our firm by the Primary Investment Adviser. While we are responsible for the overall management of the assets delegated to our firm, we will not communicate investment recommendations or selections directly to the Primary Investment Adviser's individual clients. Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. General Information Related to Investment Recommendations DCM continually seeks the best security candidates for client investment. Although DCM may choose client investments from the universe of securities available, DCM specializes in choosing investments from the pool of publicly traded companies or private offerings located within the "Delaware Valley" of Pennsylvania. DCM analyzes a potential company for investment by reviewing such factors as: earnings per share trends; balance sheet strengths and weaknesses; and discovery of additional information in companies which have little or any research coverage which makes the company more valuable than its current market capitalization in DCM's opinion, and technical factors such as: trading volume, moving average changes, and net insider buying and selling, and other technical factors identified in study materials provided by the Market Technicians study material. DCM also evaluates management through such sources as: personal meetings, evaluating information in the local news; and ascertaining the views of competitors, suppliers, and customers towards the company and its management. DCM offers an investment strategy it calls Energy Income Strategy, which is designed to produce high cash distributions by investing in publicly traded securities that have a history of raising their distributions. This strategy uses incoming generating master limited partnerships which trade on the NYSE or NASDAQ to provide increasing income to clients. 6  Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Assets Under Management As of December 31, 2025, we provide continuous management services for $101,042,830 in client assets on a discretionary basis, and $22,187,592 in client assets on a non-discretionary basis. 7  Item 5 Fees and Compensation Portfolio Management Services As compensation for the Portfolio Management Services described in Item 4 above, DCM charges an annual fee, based on a percentage of the total market value of the client's assets at the end of each quarter. All clients are subject to at least a minimum annual fee of $2,000. The asset management fee is payable quarterly in advance and will be pro-rated for the portion of a quarter in which an account is established or terminated. This means a client will be refunded any unearned fees as of the date of termination, calculated on the basis of the remaining days in the quarter for which services are not rendered. Fees will generally be deducted directly from the client's brokerage account pursuant to a written standing authorization from the client. If a client engages us to provide portfolio management services to include 401k or other outside account (held-away) assets, the assets will be included in the overall portfolio to which the asset management fee is applied and a third-party platform will typically be utilized to faciliate the management of these held-away assets and the debiting of our portfolio management fee. See Item 4 for a description of the services provided to held-away assets. In some cases, DCM may allow clients to pay fees directly, by check, following the presentation of an invoice. Fees are generally based on the fee schedule listed below: ASSET MANAGEMENT FEE SCHEDULE Fee: Account Balance 1.25% Up to $5,000,000 Next $5,000,000 1.10% Above $10,000,000 1.00% In addition to the above fees, clients may be subject to administrative, transaction or custodial fees imposed by the custodian at which the client's assets are held. For sub-advisory services, DCM receives a portion of the advisory fee charged to the client by the investment advisor with whom DCM has established the sub-advisory relationship. The specific fee earned by DCM for its sub-advisory services will be detailed in the written agreement executed by DCM and the investment advisor. Model Portfolios For clients whose assets are placed in model portfolios with Altruist Financial LLC as introducing broker to Apex Clearing Corporation, custodian of assets, DCM charges a 1.00% annual fee, billed quarterly in advance based on the total market value of the client's assets at the end of the preceding quarter. Fees are negotiable, in DCM's sole discretion. For clients who participate in the Altruist Model Marketplace, fees will be disclosed in the account opening documents and DCM's fee will not exceed 1.00% of assets under management, billed quarterly in advance based on the value of the assets on the last business day of the preceding quarter. Altruist Model Marketplace will charge a separate asset-based fee, not to exceed .20%, which means the total fee charged to the client (DCM's fee plus Altruist's fee) will not exceed 1.20%. All fees are disclosed in the account opening documents and agreements signed by the client. Financial Consulting Services DCM charges a fixed annual subscription fee for financial consulting services and may charge and an initial onboarding fee, if specified in the agreement signed by the client. The specific fee to which a client is subject is identified in the Financial Consulting agreement the client signs. The initial 8  onboarding fee is payable in advance upfront or in three equal payments over the first three months of the engagement. The onboarding fee ranges from $1,200 to $5,000 based on the complexity of the client's financial situation and the services specified in the agreement and as invoiced to the client. Clients may select from various consulting services including: Income Analysis/Cash Flow/Budget Analysis • Investment Analysis/Asset Allocation • Education Needs Analysis/Planning • Retirement Needs Analysis/Planning • Retirement Plan Review • Life Insurance Review • Disability Insurance Review including Policy Analysis • Estate Analysis/Estate Planning Service • Charitable Giving • Employee Benefit Analysis • Investment Counseling • Portfolio Monitoring • Annual tax planning and analysis. In some cases, the onboarding fee may be negotiable in DCM's sole discretion. The fixed annual subscription fee begins in the fourth month of the engagement, and ranges from $250 to $600 per month, depending on the client's financial situation and the complexity of the engagement from the number of services selected. In some cases, the ongoing annual subscription fee may be negotiable in DCM's sole discretion, and the specific fee to which the client is subject will be specified in the agreement signed by the client. For on-going financial consulting services, the annual subscription fee will be renewed each anniversary date of the execution of the Financial Consulting agreement and priced according to the fixed subscription fee schedule in effect at the time the agreement is renewed. The annual fee is payable in advance on an annual, semi-annual, quarterly, or monthly basis as indicated in the agreement. Subscription fees can be paid by check or by credit card payment, upon presentation of an invoice. If a client engages DCM for on-going financial consulting services, the client will receive an invoice with fees due for consulting services provided during the billing period. The Financial Consulting Services agreement can be terminated by any party upon written notice to the other party, and the client will be subject to any fees earned on a pro-rata basis for services rendered prior to the termination of the agreement. Any unearned fees paid in advance will be refunded on a pro-rata basis as of the date of termination. If a client engages DCM for any of the asset management services described in Item 4, separate asset management fees will be charged according to the asset management agreement the client signs with DCM. Sub-Advisory Services for Registered Investment Advisers Fees and payment arrangements are negotiable and will vary on a case-by-case basis. General Information Related to Fees and Compensation While DCM has established the above referenced fee schedule, the firm may negotiate fees under certain, limited circumstances, at its sole discretion. Multiple accounts from the same investor may be combined for fee purposes. Factors considered when determining whether a different fee will be negotiated include, among other things, the complexity of the client's financial situation, related accounts under management, portfolio style, and the provision of other services provided to the client. Clients will receive advance written notice of any change in their applicable fee schedules. Investment advisory services provided by DCM may cost a client more or less than advisory services offered by other investment advisors. For clients who utilize third-party managers through DCM's asset management services (such as Altruist described above), total fees (DCM fees + third-party manager) will never exceed a total of 3%, above which is typically considered as excessive in the financial services industry. DCM will not be compensated on the basis of a share of capital gains in a client's account. In addition to advisory fees, clients may be subject to custodial and account fees charged by account custodians or broker/dealers with whom clients establish accounts. Such additional fees may include, but are not limited to, transaction charges, custodial fees, IRA fees and other account administrative fees. Please see additional disclosure made for Item 12, Brokerage Practices, later in this brochure. Clients may also be subject to internal management fees or other product fees as disclosed in applicable product prospectuses or offering materials. 9  Clients have the option of purchasing investment products through any broker/dealer of their choice; however, DCM may not be able to provide discretionary investment management services for assets purchased away from custodians recommended by DCM, as custodians will typically require an institutional agreement with an adviser that maintains discretion over client assets. Clients may terminate investment advisory agreements at any time upon prior written notice. If an agreement is terminated within the first 5 business days, clients are entitled to a full refund of any fees paid without penalty. If an investment advisory agreement is terminated after more than 5 business days, clients will be assessed fees on a pro-rata basis, and any unearned pre-paid fees will be refunded where applicable. Clients are responsible to pay fees for services rendered up until notice of termination is received by or provided by DCM. Item 6 Performance-Based Fees and Side-By-Side Management DCM does not accept performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of a capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. DCM's fees are calculated as described in the Fees and Compensation section above, and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in a client's advisory account. Item 7 Types of Clients DCM provides investment advisory services to individuals, high-net worth individuals, trusts, and estates. DCM will typically only engage clients with a minimum of $500,000 in assets under management. This minimum account size may be waived or householded at the sole discretion of DCM. Clients are subject to a minimum $2,000 fee for Portfolio Management services, as described in Item 5. For clients who participate in the Model Portfolio services described in Item 4, DCM will not impose a minimum account size so long as DCM determines it can manage the assets consistent with the model portfolios. We also provide sub-advisory services to unaffiliated, independent registered investment advisers. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss DCM typically requires a college degree and several years' experience in the securities industry, including experience in money management or analysis of securities is required for individuals who are directly involved in the decision-making process concerning the portfolios. DCM may choose client investments from the universe of securities available, and seeks investments it believes are most advantageous for a client's investment objectives. DCM analyzes a potential company for investment by reviewing such cyclical factors as: earnings per share trends; balance sheet strengths and weaknesses; and discovery of additional information in companies which have little or any research coverage which makes the company more valuable than its current market capitalization in DCM's opinion, and technical factors such as: trading volume, moving average changes, and net insider buying and selling, and other technical factors identified in study materials provided by the Market Technicians study material. DCM also evaluates management through fundamental sources such as some or all of the following: personal meetings, evaluating information in 10  the local news; and ascertaining the views of competitors, suppliers, and customers towards the company and its management. A risk associated with this type of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. In addition, the lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of a cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Artificial Intelligence Risk: We may use artificial intelligence ("AI") in our business operations, in order to promote operational efficiency and augment our client service. We currently do not knowingly utilize AI in our investment selection process or to formulate the specific investment advice we render to you. AI models are highly complex and may result in output that is incomplete or incorrect. Our use of AI includes certain third-party technologies aimed at driving operational efficiency by automating meeting prep, meeting notes, CRM updates, meeting recap notes, task management, and other client service related functions. We believe the use of this technology allows us to reduce administrative time, prepare for client engagement, and improve overall client experience. The use of AI poses risks related to the challenges the Company faces in properly managing its use. Content generated by AI technologies may be deficient, inaccurate, or biased, and the use of AI tools may lead to errors in decision-making. Use of AI tools could also pose risks related to the protection of client or proprietary information. Such risks may include the exposure of confidential information to unauthorized recipients, violation of data privacy rights, or other data leakage events. For example, in the case of generative AI, if confidential information, including material non-public information or personal identifiable information is input into an AI application, such information is at risk of becoming part of a dataset accessible by other AI applications and users. The regulatory environment relating to AI is rapidly evolving and could require changes in our adoption and implementation of AI technology in the future. The use of AI may also expose us to litigation risk or regulatory risk. DCM offers an income and growth strategy called the Energy Income Strategy. This is a long-term strategy designed to provide rising tax deferred income as well as growth in principal. The investment process relies primarily on investing in Master Limited Partnerships (MLPs) which compose an emerging asset class. MLPs trade on the NYSE or NASDAQ and are involved in the transportation, processing, storage, production, exploration and distribution of non-renewable forms of energy. This includes oil, natural gas, natural gas liquids, and coal. The tax from the distributions is deferred until the MLP is sold. Under current tax law, units held at death will receive a stepped-up cost basis with the elimination of the deferred tax liability. MLPs pay no corporate income tax, thereby allowing the more cash to flow to the unit holders. The unit holder receives the depreciation of the pipelines and other energy infrastructure assets which reduces the taxes due on the cash flow received. The investor receives a yearly K1 which gives an accounting of his or her share of the partnership. The taxable portion of distributions received by the unit holder is disclosed in the K1. MLPs are subject to various risks, including tax consequences, interest rate risk, volatility risk and legislation risk. Investors in MLPs may incur taxable income, even within an IRA. MLPs are also sensitive to changes in interest rates, and rising interest rates could make MLPs less advantageous. MLPs also may experience higher volatility than more traditional investments, such as stocks. Finally, changes to the tax code or to Federal and State legislation could affect the attractiveness of a MLP. DCM offers the DeWitt Capital Wealth Management Solutions , which are globally diversified model portfolios consisting of equity and fixed income investments. Based upon the client's stated investment objectives and risk tolerance, DCM allocates each client's investment management assets into model portfolios on a discretionary or non-discretionary basis primarily among mutual funds and exchange 11  traded funds. Portfolios are diversified across Country, Sector/Industry, Region, Duration, Style, Size, Strategy and Asset Class. Analysis and investment selection process of investments can include but are not limited to various fundamental and quantitative filters, methods, screens and systems, including SRI (Socially Responsible Investing) and ESG (Environmental, Social and Governance) criteria. The strategy is typically rebalanced annually, but more frequent rebalancing may occur if economic conditions warrant action. DCM uses research from a variety of sources including most of the major research provided by firms who conduct investment banking, as well as third parties who have no investment banking relationships, and our own internal valuation metrics. In addition, meeting with industry contacts and management, participating in conference calls, analyzing quarterly and annual reports, 10ks and 10qs, make up the bulk of DCM's research efforts. DCM will also utilize certain analytical tools to assist in asset allocation and security selection. One of the analytical tools utilized by the firm was developed by fnTech LLC, a technology company owned by Scott Frank. Neither DCM nor any DCM client directly pays for the analytical tool offered by fnTech LLC and neither fnTech LLC nor Mr. Frank are directly compensated for the specific use of this tool provided to DCM. The methods of analysis used for Financial Consulting services related to the analysis, selection and asset allocation of investments and the sizing of investments in portfolios can include but are not limited to various fundamental and quantitative filters, methods, screens and software systems. As with all investments, there are inherent risks, including loss of principal. Clients who elect to invest in securities must be willing to bear this risk. Investments may also be subject to the risk of illiquidity and clients should refer to product offering material for disclosure related to liquidity. Fixed Income investments are subject to inflationary, credit, market and interest rate risks. Stock markets, especially foreign markets, are volatile and can decline significantly in response to adverse issuer, political, regulatory, market, or economic developments. Sector investments, including a specialization in the Delaware Valley of Pennsylvania, for example, concentrate in a particular sector, industry or geographical region, and the investments' performance could depend heavily on the performance of that sector and be more volatile than the performance of less concentrated investment options and the market as a whole. Securities of companies with smaller market capitalization tend to be more volatile and less liquid than larger company stocks. Smaller companies may have no, or relatively short, operating histories or be newly public companies. Foreign securities are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the 12  costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs (exchange traded funds) typically trade like stocks and are subject to investment volatility and the potential for loss. The principal amounts invested in ETFs are not protected, guaranteed or insured. Diversification into many ETFs does not ensure a profit or protect an investor from loss. The risks above are particularly significant for ETFs that focus on a single country or region. High frequency trading could result in lower returns due to an increase in trading costs, as well as an increase in realized capital gains/losses. Derivatives are types of investments where the investor does not own the underlying asset. There are many different types of derivative instruments, including, but not limited to, options, swaps, futures, and forward contracts. Derivatives have numerous uses as well as various risks associated with them, but they are generally considered an alternative way to participate in the market. Investors typically use derivatives for three reasons: to hedge a position, to increase leverage, or to speculate on an asset's movement. The key to making a sound investment is to fully understand the characteristics and risks associated with the derivative, including, but not limited to counter-party, underlying asset, price, and expiration risks. The use of a derivative only makes sense if the investor is fully aware of the risks and understands the impact of the investment within a portfolio strategy. Due to the variety of available derivatives and the range of potential risks, a detailed explanation of derivatives is beyond the scope of this disclosure. The Firm may utilize derivatives on a limited basis, and only when such instruments are consistent with a client's investment objectives, risk tolerance, and stated guidelines. A private placement (nonpublic offering) is an illiquid security sold to qualified investors and are not publicly traded nor registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to illiquidity. Most securities that are acquired in a private placement will be restricted securities and must be held for an extended amount of time and therefore cannot be sold easily. The range of risks are dependent on the nature of the partnership and are disclosed in the offering documents. 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 DCM or the integrity of DCM' management. DCM has no reportable information applicable to this Item. Item 10 Other Financial Industry Activities and Affiliations DCM is engaged in no other business other than the businesses described herein, nor does it offer products or services other than those described herein. Scott Frank, investment adviser representative, is also the owner of Valor Consult LLC, a business consulting and research firm. Mr. Frank is also owner of Portfolio Catapult LLC, an investment research technology company. No DCM clients are involved. Compensation is retainer based. 13  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading DCM has adopted a Code of Ethics to promote the principles of honesty and integrity in its business practices, and to maintain DCM' reputation as a firm that operates with the highest level of professionalism. DCM recognizes its fiduciary responsibilities to its clients, and its duty and pledge to place clients' interests first and foremost. In connection with this duty, all employees of DCM are subject to the firm's Code of Ethics and are required to acknowledge their understanding of its terms. A copy of the DCM Code of Ethics will be provided to any client or prospective client upon request. DCM's Code of Ethics establishes procedures for employees to report personal securities transactions and personal securities holdings. The Code sets forth procedures for management review of these reports. In some cases, DCM employees may be required to obtain pre-approval for certain personal securities transactions or refrain from certain transactions altogether. DCM's Code of Ethics also sets forth the obligation of all DCM employees to comply with applicable state and federal securities laws, and the duty to cooperate in any investigation or inquiry conducted on or by DCM. Finally, DCM's Code of Ethics establishes procedures for the reporting of any potential violation of the firm's Code. DCM or its owners, officers and employees may buy or sell securities that are the same or different than those they recommend to clients. While buying or selling the same security as a client would be incidental, it may represent a potential conflict of interest, which would be fully disclosed to the client. DCM or its owners, officers and employees may not sell securities from their accounts directly to a client, nor may they purchase securities directly from a client. DCM, its owners, officers and employees are prohibited from trading on material nonpublic information. DCM does not trade ahead of clients, but instead puts clients' interests first. Employees may not purchase or sell any security prior to a transaction being implemented for an advisory client, unless the timing of such transaction was done without the employee's knowledge of a client's transaction. DCM endeavors to ensure that the personal trading activities of its owners, officers and employees do not interfere with the decision- making process for client investment recommendations. DCM also endeavors to ensure that the personal trading activities of its owners, officers and employees do not interfere with the implementation of investment recommendations made to clients. DCM prohibits its owners, officers, and employees from participating in any principal transactions, where securities are purchased directly from, or sold directly to a client. DCM also prohibits its owners, officers and employees from purchasing shares in initial public offerings or private placement offerings, unless express written permission is provided in advance, by the firm's Chief Compliance Officer. DCM, its owners, officers and employees, do not recommend to clients that they buy or sell securities in which a person associated with DCM has a material financial interest. Item 12 Brokerage Practices DCM will suggest those brokers or dealers which provide best execution taking into consideration, the reasonableness of commissions, the broker's ability to provide timely, professional client services, research and other services that assist DCM in its investment management business. DCM makes every effort to ensure that clients are receiving quality execution of investments, however, best execution can never be guaranteed. DCM generally recommends that clients maintain brokerage accounts at the Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab"), and will utilize Schwab as custodian for its discretionary management brokerage services. In some limited cases and at the request of a client, DCM may provide non-discretionary investment management services to clients who custody their 14  assets elsewhere. DCM does not earn any commissions for the execution of securities transactions at Schwab. DCM is typically not able to negotiate custodial fees and transaction costs charged by Schwab; however, DCM believes that the custodial and execution services provided by Schwab are of a quality and competitiveness that is beneficial to DCM clients. DCM cannot guarantee best execution. DCM will not purchase for its advisory client accounts any security that is part of a syndicate or underwriting offered by Schwab without the specific prior written approval of the client. DCM provides investment advisory services on a discretionary basis; however, clients are free to place restrictions on investment recommendations made by DCM. Transactions executed by Schwab are subject to the transaction and execution fee schedule in effect at the time of execution. Therefore, brokerage and investment advisory services offered by DCM may cost a client more or less than similar investment advisory services offered by another firm, or by purchasing similar services separately. DCM does not receive any research or other soft-dollar benefit from its relationship with Schwab. In some cases, DCM may aggregate client trades or execute "block" trading. The firm does not always aggregate client transactions as accounts are managed on an individual basis. However, blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts. If DCM determines that it is advantageous to customers to execute block transactions, clients participating in any aggregated transactions will receive an average share price and transaction costs (i.e., commissions and trading fees) will be determined on an account by account basis based on each client's account status at the custodian. For the benefit of no commissions or transaction fees, fully digital account opening, a large variety of security options and complete integration with software tools, DCM also recommends Altruist Financial LLC, an unaffiliated registered broker dealer and FINRA/SIPC member, as the introducing broker to Apex Clearing Corporation, an unaffiliated registered broker dealer and FINRA/SIPC member, as the clients' custodian. DCM does not receive any research or other soft-dollar benefit from its relationship with Altruist Financial LLC. DCM does not receive any referrals in exchange for using Altruist Financial LLC as a broker dealer. As part of its fiduciary duty to clients, DCM endeavors at all times to put clients' interests first. DCM may receive research materials from custodians or broker/dealers with whom client transactions are executed. This may be an economic benefit to DCM; however, the receipt of this research is not dependent upon DCM' execution of customer transactions or custody of client assets. Clients should be aware that the receipt of economic benefits by the firm in and of itself creates a potential conflict of interest. While DCM feels the quality of custodial services provided by broker/dealers recommended by DCM is beneficial to clients, the firm cannot guarantee that best execution will be obtained. DCM does not recommend broker/dealers in order to receive client referrals from such broker/dealers. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 13 Review of Accounts Various members of DCM's professional team perform all account reviews. On a daily basis, Mr. DeWitt and members of the DCM team monitor market conditions as well as significant developments related to any portfolio holdings in clients' accounts. On a quarterly basis, Mr. DeWitt and members of the DCM team conduct an in-depth review of each client's account and a quarterly performance report is generated for the client. Such report will include account valuation detailing the performance of the account including any unrealized or realized profits or losses. Clients will also receive normal and customary brokerage or custodial statements from the custodians at which their assets are held. These 15  brokerage or custodial statements are typically generated whenever there is activity in the account or at least quarterly. Clients should carefully compare the information provided in reports generated by DCM with the information provided by the account custodian. If any information conflicts between the reports provided by DCM vs. the custodial statements, the custodial statements should be relied upon for information. Item 14 Client Referrals and Other Compensation As discussed previously, the sole business of DCM is that of providing the investment advisory services described herein. DCM does not receive an economic benefit from anyone that is not a client for providing investment advice or other advisory services to its clients. DCM does not currently maintain any referral arrangements with individuals or entities that may be compensated, directly or indirectly. If DCM were to enter into an arrangement with a third-party, it would do so in accordance with Rule 206(4)-1 of the Advisers Act. Item 15 Custody A client's independent custodian will directly debit a client's account for the payment of our advisory fees. This ability to deduct DCM's advisory fees from client accounts causes our firm to exercise limited custody over client funds or securities solely because advisory fees are directly deducted from client accounts by the custodian on behalf of DCM. We do not have physical custody of any of client funds and/or securities. Client funds and securities are held with a bank, broker-dealer, or other qualified custodian. Clients will receive account statements from the qualified custodian(s) holding funds and securities at least quarterly. The account statements from the custodian will indicate the amount of DCM's advisory fees deducted from the account each billing period. DCM sends the qualified custodian written notice of the amount of the fee to be deducted from the client's account and DCM will send the client an itemized invoice including any formulae used to calculate the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. Clients should carefully review account statements for accuracy. Item 16 Investment Discretion DCM does accept discretionary authority to manage securities accounts on behalf of clients. Clients who elect discretionary management will grant DCM limited power of attorney over the managed account which gives DCM the power and authority to supervise and direct the account investments including the authority to buy, sell, exchange, convert or otherwise trade in any security, or any other investment product including individual stocks, bonds and mutual fund shares on behalf of the client. The primary factor in the selection of a financial product for a client is the suitability of the product for the client. For clients who enter into non-discretionary arrangements with our firm, we will obtain verbal or written approval prior to our execution of any transactions for your account(s) on a client's behalf, and such approval will be documented and maintained in DCM's books and records. Adviser access is granted to DCM by clients at the custodian to execute trades on a non-discretionary basis. Clients may also execute transactions on their own behalf. Clients have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. 16  Item 17 Voting Client Securities DCM does not accept authority to vote client securities on behalf of clients. Clients retain all rights to their brokerage accounts, including the right to vote proxies. Clients are responsible for directing each custodian of their assets to forward copies of all proxies and shareholder communications directly to the client. While DCM may provide information or consultation to assist a client in deciding how to vote a particular security, the ultimate decision and responsibility to vote a security lies with the client. Item 18 Financial Information DCM does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and, we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. We have not filed a bankruptcy petition at any time in the past ten years. Item 19 Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information PRIVACY POLICY DCM maintains a specific Privacy Policy that is distributed to each client at the time an account is opened and annually thereafter. DCM collects nonpublic information about clients from the following sources: information the firm receives from clients verbally, on applications or other forms and information about client transactions with others or the firm. DCM may have to share non-public client information with unaffiliated firms in order to service client accounts. Additionally, DCM may have to provide information about clients to regulatory agencies as required by law. Otherwise, DCM will not disclose any client information to an unaffiliated entity unless a client has given express permission for the firm to do so. DCM is committed to protecting client privacy. The firm restricts access to clients' personal and account information to those employees who need to know the information. DCM also maintains physical, electronic and procedural safeguards that the firm believes comply with Federal standards to protect against threats to the safety and integrity of client records and information. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. We may, upon request, assist you in your analysis of a class action lawsuit for which you may be eligible to participate. 17