DAVIDSON CAPITAL MANAGEMENT, INC.

Form ADV Part 2A Client Brochure SEC File Number 801-60519 5350 South Staples, Suite 434 Corpus Christi, Texas 78411 Phone: (361)906-0070 Email: jeff@davidsoncap.com Web: www.davidsoncap.com April 7, 2025 This brochure provides information about the qualifications and business practices of Davidson Capital Management, Inc. If you have any questions about the contents of this brochure, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906-0070. 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. Additional information about Davidson Capital Management, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov 1  Form ADV Part 2A April 7, 2025 Item 2 - Material Changes for Form ADV Part 2A & 2B Material Changes for Form ADV Part 2A No Changes Material Changes for Form ADV Part 2B Brochure Supplement Added Louis Pierce May as an Investment Advisor 2  Form ADV Part 2A April 7, 2025 Item 3 - Table of Contents Form ADV Part 2A Item 1 Cover Page ..............................................................................................................1 Item 2 Material Changes to Form ADV Part 2A & 2B ......................................................2 Item 3 Table of Contents ....................................................................................................3 Item 4 Advisory Business ..................................................................................................4 Item 5 Fees and Compensation ......................................................................................... 6 Item 6 Termination Procedures & Reporting Responsibilities After Termination ........... 8 Item 7 Fiduciary Status ..................................................................................................... 10 Item 8 Performance-Based Fees and Side-By-Side Management ......................................10 Item 9 Types of Clients ......................................................................................................10 Item 10 Methods of Analysis, Investment Strategies and Risk of Loss ...............................11 Item 11 Disciplinary Information .........................................................................................12 Item 12 Other Financial Industry Activities and Affiliations ...............................................12 Item 13 Code of Ethics, Participation, or Interest in Client Transactions And Personal Trading .............................................................................................12 Item 14 Brokerage Practices .................................................................................................13 Item 15 Review of Accounts ............................................................................................... 15 Item 16 Client Referrals and Other Compensation ..............................................................15 Item 17 Custody ...................................................................................................................15 Item 18 Investment Discretion .............................................................................................16 Item 19 Voting Client Securities .......................................................................................... 16 Item 20 Financial Information. .............................................................................................21 Item 21 Requirements for State Registered Advisers .......................................................... 21 Form ADV Part 2B William Jeffrey Davidson ...................................................................................................... 22 John Kyle Davidson ...............................................................................................................25 Joe Carroll Rust, Jr. ...............................................................................................................28 Chad Thomas Jones ...............................................................................................................31 Louis Pierce May ...................................................................................................................34 John Edward Davidson ..........................................................................................................36 3  Form ADV Part 2A April 7, 2025 Item 4 - Advisory Business Davidson Capital Management, Inc. (DCM) is a subchapter S Corporation organized under the laws of the state of Texas. DCM is a registered investment adviser with the United States Securities and Exchange Commission, the Texas State Securities Board, and has been registered since November 1989. DCM is owned by William Jeffrey Davidson, President, and John Kyle Davidson Senior Vice President. DCM is not publicly owned or traded. There are no indirect owners of DCM. DCM provides independent, fee-only investment management to its clients under three different investment management programs: Individually Managed Account, Asset Builder Account, and 401(k) Retirement Plan Advisory Services. Individually Managed Account/Asset Builder Account DCM’s investment advisor representatives (IAR), William Jeffrey Davidson, John Kyle Davidson, Joe Carroll Rust Jr., and Chad Thomas Jones develop asset allocation strategies using a mix of stocks, exchange traded funds, bonds, and no-load mutual funds. Through continuous monitoring of asset class segment returns and risk factors, DCM adjusts portfolio asset mixes to meet investment objectives. The specific percentages allocated to each asset class may vary due to the nature of asset performance and/or the strategy selected. It is DCM’s intent to maintain a risk exposure commensurate with each client’s objectives by using the various investment portfolio choices available under the asset allocation strategy selected by the client. DCM’s IAR’s consult with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify DCM if there are changes in their financial situation or if they wish to adjust their asset allocations. Clients may not impose unreasonable restrictions on the management of their accounts if DCM determines, in its sole discretion, the restrictions will materially impact the performance of an asset allocation strategy or prove overly burdensome to DCM’s management efforts. The investment management program for each client will be determined by the amount of client assets available to invest. The client’s asset allocation will be determined by the clients’ risk tolerance, investment objective, and income requirements. DCM generally limits the types of securities used for client investment to the following: common stocks, exchange traded funds, government bonds, investment grade corporate bonds, State of Texas municipal bonds, and no-load mutual funds. 401(k) Retirement Plan Advisory Services 401(k) Retirement Plan Advisory Services consists of helping employer plan sponsors establish, monitor, and review their company's 401(k) retirement plan. As the needs of the plan sponsor dictate, areas of advising could include investment selection and monitoring, plan structure, and participant education. DCM offers management of retirement plans both on a plan level and on the individual participant level. At the plan level DCM manages the investment line-up, making changes as 4  Form ADV Part 2A April 7, 2025 necessary as well as providing risk-based investment models for the participants. At the individual participant level, DCM manages risk-based models using the current investment lineup based on the risk tolerance of the individual plan participant. Plan Level DCM will establish the plan’s needs and objectives through an initial meeting to collect data, review plan information, assist in developing or updating the plan’s provisions and provide a comprehensive review of existing 401(k) plan investment options. DCM will also assist with converting from incumbent service providers to a new service provider if appropriate. Ongoing services will include selection and review of unaffiliated mutual funds that, in DCM’s judgment, are suitable for plan assets to be invested, and DCM will draft an Investment Policy Statement (IPS) providing ongoing monitoring of the mutual funds in the 401(k) plan to ensure compliance with the IPS and will provide custom designed asset allocation models that can be used by plan participants. Participant Level DCM will use its proprietary method of selecting mutual funds to create a list of mutual funds available for investment in each 401(k) plan. Plan participants can design their own 401(k) portfolio the following ways: (1) Plan participants can select from various risk-based asset allocation models designed by DCM or asset allocation models designed by the third party recordkeeper which will contain pre-set allocations of mutual funds from the list of mutual funds selected by DCM. (2) Plan participants can design their own portfolio asset allocation from the list of mutual funds chosen by DCM. (3) If the Third Party Administrator permits, plan participants can create portfolios from a combination of both (1) & (2). The mutual funds available to 401(k) participants are continually reviewed by DCM. When any mutual fund(s) fails to meet the investment standards outlined in the IPS, DCM will replace those mutual fund(s). Conflicts of Interest – IRA Rollover Recommendations When recommending that a client rollover his or her account from a 401(k) plan managed by DCM to an IRA also managed by DCM, DCM and its investment adviser representatives have a conflict of interest. DCM and its representatives can earn investment advisory fees by recommending that a client rollover his or her account at the retirement plan to an IRA managed by DCM; however, DCM and its investment adviser representatives will not earn any investment advisory fee if client does not rollover the funds from the 401(k) plan. Thus, DCM and its investment adviser representatives have an economic incentive to recommend a rollover of the 401(k) plan account to an IRA account managed by DCM, which is a conflict of interest. DCM has taken steps to manage this conflict of interest arising from rolling over funds from an ERISA covered retirement plan to an IRA. DCM and its investment adviser representatives will (i) provide investment advice to ERISA covered retirement plan participant regarding a rollover of funds from the ERISA covered retirement plan in accordance with DCM’s fiduciary status, (ii) not recommend investments which result in the firm receiving unreasonable compensation related to the rollover of funds from the ERISA covered retirement plan to an IRA, and (iii) fully disclose compensation received by DCM and its supervised persons and any material conflicts of interest related to DCM recommending the rollover of funds 5  Form ADV Part 2A April 7, 2025 from the ERISA covered retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. As of December 31, 2024, DCM managed on a discretionary basis $567,908,265 in 871 accounts. DCM has no non-discretionary assets under management. DCM does not participate in any wrap account programs. Item 5 - Fees and Compensation Individually Managed Account & Asset Builder Account DCM charges investment management fees for investment management services. Investment management fees under the Individually Managed Account or Asset Builder Account programs are computed based upon the total market value of assets managed for each client at the close of each calendar quarter and are payable quarterly in advance. Investment management fees are deducted directly from each client's account. Individually Managed Account & Asset Builder Account Fee Schedule First $1 Million Next $1 Million Next $2 Million Next $2 Million Thereafter 1.00% of Assets Annually 0.90% 0.80% 0.70% 0.60% DCM may negotiate management fees in certain circumstances. Clients that invest in common stocks or exchange traded funds may be charged a commission by the custodian for the purchase or sale of these securities. Clients that invest in mutual funds should understand that each mutual fund company charges fees and expenses to manage the client's assets that are in addition to the investment management fees charged by DCM. In addition, the custodian of each client's account may charge a transaction fee for the purchase or sale of some, or all the mutual funds selected by DCM for investment in client account. These transaction fees are beyond the control of DCM. Clients may also incur other fees and expenses imposed by custodians, brokers, or other third parties such as custodial fees, deferred sales charges, account transfer fees, and wire transfer fees. The fees and expenses charged by each mutual fund company, custodian, broker, or other third party are beyond the control of DCM. DCM is not compensated for the selection of any security used for client investment. DCM does not receive any portion of the fees and expenses charged to any client by the mutual fund company, custodian, broker, or other third party. 6  Form ADV Part 2A April 7, 2025 401(k) Retirement Plan Advisory Services Investment management fees under the 401(k) Retirement Plan Advisory Services program are computed based upon the total market value of assets managed for each 401(k) client at the close of each calendar quarter and are payable quarterly in arrears or advance. Investment management fees for 401(k) Retirement Plan Advisory Services clients are deducted directly from 401(k) participant accounts or paid by the 401(k) plan sponsor. 401(k) Retirement Plan Advisory Services Fee Schedule First $3 Million Next $2 Million Next $5 Million Next $10 Million Thereafter 0.50% of Assets Annually 0.20% 0.15% 0.10% Negotiable Minimum Annual Management Fee $5,000. DCM may negotiate management fees in certain circumstances. In addition to DCM’s quarterly management fee, there are annual asset fees paid to the 401(k) plan’s third party administrator(s) as outlined in their 401(k) program agreement and the management fees and expenses charged by the individual mutual funds in the 401(k) plan. Both the fees and expenses charged by the third-party administrator and the mutual fund company are beyond the control of DCM. Portfolio Review Fees DCM performs portfolio reviews for prospective clients typically without charge, however, DCM reserves the right to charge portfolio review fees for the review of any portfolio(s) that in DCM’s opinion requires additional work beyond the scope of a typical portfolio review. If DCM determines that additional portfolio review fees are required to complete a prospective clients’ portfolio review, DCM may require the payment of portfolio review fees not to exceed the amount the prospective client would have paid for one calendar quarter of portfolio management fees (In accordance with the fee schedule in Item 5 of ADV Part 2A) had the prospective clients’ aggregate total portfolio value being reviewed been under the management of DCM. DCM will require the prospective client sign a portfolio review contract at the time the portfolio review commences, and the prospective client will pay one-half of the portfolio review fee at the time of contract signing with the remaining portfolio review fee due at the time the portfolio review meeting is held, or if a portfolio review meeting is not held when the portfolio review is delivered to the prospective client. If the prospective client decides to hire DCM as their investment adviser, the portfolio review fees will be applied as a credit to any portfolio management fees due as long as a Discretionary Account Agreement is signed within 30 days of the portfolio review meeting with the client, or if no portfolio review meeting is held, when the portfolio review is delivered to the prospective client. 7  Form ADV Part 2A April 7, 2025 Other Fiduciary Services DCM may perform other fiduciary services for clients. DCM’s compensation for those other fiduciary services will be negotiated on a case-by-case basis. Item 6 – Termination Procedures & Reporting Responsibilities After Termination Termination Procedures DCM Clients That Pay Quarterly in Advance To terminate DCM’s Discretionary Account Agreement, DCM must be notified either in writing, by regular mail or email, or verbally by an account holder, or the account holders’ duly authorized representative that they wish to terminate their Discretionary Account Agreement or notify DCM that the client intends to transfer their assets to a custodian not recognized by DCM. DCM, may in its sole discretion, accept the termination notification by one account holder, or the account holder’s duly authorized representative, to be valid termination of all accounts held at the same household or business address as the notifying party even if the notifying party is not the account holder. If the date termination notice is received is a weekend or holiday the termination date will be the end of the previous business day. All clients are required to give 30-day termination notices before management fees cease accruing. After the required 30-day notice period elapses, DCM will refund to the client’s account any unearned management fees from the ending date of the 30-day notice period to the end of the calendar quarter. If there are less than 30 days left in the calendar quarter when termination notice is received there will be no management fee refund. If a client does not notify DCM in writing, by regular mail or email, or verbally and transfers their assets to a custodian not recognized by DCM, DCM will immediately terminate the Discretionary Account Agreement on the date DCM is notified by the custodian that the client’s assets are being transferred. If the date notice of transfer is received is a weekend or holiday the termination date will be the end of the previous business day. All clients are required to give 30-day termination notices before management fees cease accruing. After the required 30-day notice period elapses, DCM will refund to the client’s account any unearned management fees from the ending date of the 30-day notice period to the end of the calendar quarter. If there are less than 30 days left in the calendar quarter when termination notice is received there will be no management fee refund. DCM Clients That Pay Quarterly in Arrears To terminate DCM’s Discretionary Account Agreement, DCM must be notified either in writing, by regular mail or email, or verbally by an account holder, or the account holders’ duly authorized representative that they wish to terminate their Discretionary Account Agreement or notify DCM that the client intends to transfer their assets to a custodian not recognized by DCM. DCM, may in its sole discretion, accept the termination notification by one account holder, or the account holder’s duly authorized representative, to be valid termination of all accounts held at the same household or 8  Form ADV Part 2A April 7, 2025 business address as the notifying party even if the notifying party is not the account holder. If the date termination notice is received is a weekend or holiday the termination date will be the end of the previous business day. All clients are required to give 30-day termination notices before management fees cease accruing. After the required 30-day notice period elapses, DCM will be entitled to management fees from the beginning of the quarter through 30 days after notice of termination is received. If there are less than 30 days left in the calendar quarter when termination notice is received DCM will be entitled to management fees for the entire quarter. If a client does not notify DCM in writing, by regular mail or email, or verbally and transfers their assets to a custodian not recognized by DCM, DCM will immediately terminate the Discretionary Account Agreement on the date DCM is notified by the custodian that the client’s assets are being transferred. If the date notice of transfer is received is a weekend or holiday the termination date will be the end of the previous business day. All clients are required to give 30-day termination notices before management fees cease accruing. After the required 30-day notice period elapses, DCM will be entitled to management fees from the beginning of the quarter through 30 days after notice of termination is received. If there are less than 30 days left in the calendar quarter when termination notice is received DCM will be entitled to management fees for the entire quarter. If DCM terminates a client’s Discretionary Account Agreement for any reason the client will be notified via email or verbally. For clients that pay quarterly in advance a management fee refund will be computed beginning the next calendar day following notice of termination to the end of the calendar quarter. For clients that pay quarterly in arrears management fees will be due from the beginning of the quarter through the business day DCM notifies the client of their termination. All management fee refunds will be paid directly to the account custodian for credit to the client’s account(s). No management fee refunds will be paid directly to the client. Management Fee refunds less than $10 will not be made to the client’s account. Reporting Responsibilities After Termination DCM will not deliver a quarterly report to clients for the quarter in which the client terminates. DCM’s responsibilities to deliver archived quarterly reports to clients after termination will be limited to the delivery of the prior two years of quarterly reports. A request for delivery of archived quarterly reports must be made in writing to DCM via regular mail or email within 90 days from the date of termination. DCM will deliver archived quarterly reports free of charge by electronic delivery only as long as the request to deliver archived quarterly reports is received within 90 days from the date of termination. Requests to deliver archived quarterly reports in paper form within 90 days from the date of termination will require the payment of a fee for materials and postage to be determined by DCM. Requests for archived quarterly reports beyond two years from the date of termination or requests for archived quarterly reports for any length of time after 90 days from the date of termination will be fulfilled after an appropriate fee is paid to DCM. DCM in its sole discretion will determine the appropriate fee to be paid based on the cost of employee time to produce and deliver the archived quarterly reports. All other documents such as trade confirmations, monthly statements, and tax reporting documents 9  Form ADV Part 2A April 7, 2025 can be obtained by the client from the custodian. Item 7 – Fiduciary Status As fiduciaries DCM is required to act in the best interest of all clients and to place the interests of all clients before their own. DCM is deemed to be a fiduciary to advisory clients that are employee benefit plans pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and regulations under the Internal Revenue Code of 1986 (the ”Code”), respectively. As such, DCM is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include, among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, DCM may only charge fees for investment advice. DCM does not receive any 12b- 1 fees from the mutual fund companies selected for inclusion in DCM’s 401(k) investment platform and does not receive any portion of the fees and expenses charged to any client by the third-party administrator. To the extent that DCM provides investment advice regarding retirement plan investments, DCM will comply with the requirements of the Department of Labor’s Best Interest Contract Exemption applicable to level fee fiduciaries. DCM acknowledges that it is a fiduciary under ERISA with respect to such investment advice. DCM will provide investment advice that is, at the time of the recommendation, in the best interest of the Client, without regard to the financial or other interests of DCM, any affiliate, related entity, or other party. Any recommended transaction will not cause DCM (or its affiliates or related entities) to receive, directly or indirectly, compensation for their services that is in excess of reasonable compensation within the meaning of ERISA Section 408(b)(2) and IRC Section 4975(d)(2). Neither DCM nor its advisers will make any statement to the Client about the recommended transaction, fees and compensation, material conflicts of interest, or any other matters relevant to the Client’s investment decisions that are materially misleading at the time they are made. Item 8 - Performance-Based Fees and Side-By-Side Management DCM does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 9 - Types of Clients DCM provides investment management services to individuals, charitable organizations, corporations, and defined contribution plans. Clients are required to initially invest and maintain an account balance of at least $1,000,000 to participate in the Individually Managed Account program. Clients are required to initially invest and maintain an account balance of at least $500,000 to participate in the Asset Builder Account program. DCM reserves the right to combine multiple accounts to determine if minimum investment 10  Form ADV Part 2A April 7, 2025 requirements are met. DCM reserves the right to waive minimum investment requirements for any investment program at our discretion. Item 10 - Methods of Analysis, Investment Strategies and Risk of Loss DCM uses a long-term investment strategy with adjustments in client holdings being made when valuation changes occur, which cause holdings to become either overvalued or undervalued. In constructing equity portfolios, DCM uses a quality oriented, disciplined, long term approach to identify those companies whose fundamentals cause them to have greater growth potential than the marketplace. The same disciplined approach will be used to sell those holdings which have become overpriced. A database screen is used to identify those companies which merit further screening. From the eligible list, portfolios will be constructed using a proprietary grid ranking system which is sensitized to risk, economic, and cyclical considerations. Fixed income portfolios are constructed around a high-quality core holding of individual government bonds, government agency bonds, investment grade corporate bonds, Texas municipal bonds, or exchange traded funds that own government, government agency, investment grade corporate or Texas municipal bonds with maturity ranges of 1 to 7 years from the date of purchase depending on the type of investment account and the client's marginal tax bracket. The remainder of the portfolio is invested in either longer or shorter maturity individual government bonds, government agency bonds, investment grade corporate bonds, Texas municipal bonds, or exchange traded funds that own government, government agency, investment grade corporate or Texas municipal bonds based upon DCM's interest rate forecasts. Mutual fund portfolios are constructed using proprietary screens of the entire mutual fund universe. Mutual funds are screened based on criteria such as investment style, portfolio manager tenure, fees and expenses, and long-term performance. The principal sources of information to be used in equity, fixed income, and mutual fund research are online databases that contain fundamental investment variables for individual companies. DCM also obtains information from financial newspapers and magazines, and other sources offering information relevant to potential investments. Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal - the risk that the value of securities, when sold or otherwise disposed of, may be less than the original price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. 11  Form ADV Part 2A April 7, 2025 Item 11 - 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's management. DCM has no disciplinary events to disclose. Item 12 - Other Financial Industry Activities and Affiliations DCM has no other financial industry activities or affiliations. Item 13 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading DCM's Code of Ethics (The Code) establishes rules of conduct for all employees of DCM and is designed to, among other things, govern personal securities trading activities in the accounts of employees. The Code is based upon the principle that DCM and its employees owe a fiduciary duty to DCM's clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code is designed to ensure that the high ethical standards long maintained by DCM continue to be applied. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. The excellent name and reputation of our firm continues to be a direct reflection of the conduct of each employee. Pursuant to Section 206 of the Investment Advisers Act of 1940 (Advisers Act), both DCM and its employees are prohibited from engaging in fraudulent, deceptive, or manipulative conduct. Compliance with this section involves more than acting with honesty and good faith alone. It means that DCM has an affirmative duty of utmost good faith to act solely in the best interest of its clients. DCM and its employees are subject to the following specific fiduciary obligations when dealing with clients: (1) The duty to have a reasonable, independent basis for the investment advice provided; (2) The duty to obtain best execution for a client’s transactions where DCM is in a position to direct brokerage transactions for the client; (3) The duty to ensure that investment advice is suitable to meeting the client’s individual objectives, needs and circumstances; and (4) A duty to be loyal to clients. DCM employees may buy or sell securities that are also used for client investment. DCM maintains a formal policy manual which has been acknowledged in writing by every employee. DCM has a strict policy against entering into transactions that might pose a conflict of interest between employees and DCM's clients. DCM employees are forbidden from purchasing or selling securities, other than open-end mutual funds, immediately prior to the purchase or sale of the same securities 12  Form ADV Part 2A April 7, 2025 by a client. The Chief Compliance Officer reviews investment accounts of DCM employees monthly to ensure adherence to this policy. In meeting its fiduciary responsibilities to its clients, DCM expects every employee to demonstrate the highest standards of ethical conduct for continued employment with DCM. Strict compliance with the provisions of the Code shall be considered a basic condition of employment with DCM. A complete copy of DCM's Code of Ethics is available to existing or prospective clients on our website at https://davidsoncap.com/disclosures/ Item 14 - Brokerage Practices Individual & Joint Brokerage Accounts, Custodial Accounts, Corporate Accounts, Endowments, Partnerships, IRA's, Roth IRA's, Inherited IRA's, SEP IRA's, Simple IRA's DCM may recommend and/or require that clients establish brokerage accounts with the Schwab Institutional Division of Charles Schwab & Co., Inc. (Schwab) a FINRA registered broker- dealer, member SIPC, to maintain custody of clients' assets and to effect trades for their accounts. Although DCM may recommend and/or require that clients establish accounts at Schwab, it is the client's decision to custody assets with Schwab. DCM is independently owned and operated and not affiliated with Schwab. Schwab provides DCM with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are maintained in accounts at Schwab Institutional. These services are not contingent upon DCM committing to Schwab any specific amount of business (assets in custody or trading). Schwab's brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For DCM's client accounts maintained in Schwab's custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to DCM other products and services that benefit DCM but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of DCM's accounts, including accounts not maintained at Schwab. Schwab's products and services that assist DCM in managing and administering clients’ accounts includes software and other technology that (i) provide access to client account data (such as trade 13  Form ADV Part 2A April 7, 2025 confirmations and account statements); (ii) facilitate trade execution and allocation of aggregated trade orders for multiple client accounts; (iii) provide research, pricing information and other market data; (iv) facilitate payment of DCM's fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help DCM manage and further develop its business enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; (iii) access to employee benefits providers, human capital consultants and insurance providers. Schwab may make available, arrange and/or pay for these types of services rendered to DCM by independent third parties. Schwab Institutional may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to DCM. Schwab Institutional may also provide other benefits such as educational events or occasional business entertainment for DCM personnel. In evaluating whether to recommend or require that client’s custody their assets at Schwab, DCM may consider the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Our experience with Schwab has demonstrated their integrity in the marketplace, reputation, confidentiality, financial stability, reliability, accurate record keeping, and back-office services. DCM may from time-to-time aggregate client security orders. DCM, or persons associated with DCM, or entities controlled by DCM will not be favored by DCM over any other client and each client who participates in an aggregated security order will receive the same average security price. By aggregating all our trades through Schwab Institutional, DCM can negotiate reduced commission costs for all clients. Schwab Institutional's back-office support works in conjunction with DCM's portfolio management system to deliver reduced overhead costs enabling DCM to reduce overall management fees charged to our clients. If the client does not specify otherwise, DCM will direct all the client's security transactions through Schwab Institutional. Clients should understand that if they wish to direct or they are required to direct their security transactions through a broker-dealer other than Schwab Institutional, DCM may or may not charge additional management fees or expenses to compensate for increased overhead expenses that may be required to direct trades through the client's selected broker-dealer. Brokerage firms are considered based upon the value of research provided, execution capability, commission rate, financial responsibility, responsiveness to DCM and its clients, and other factors which DCM deems appropriate. The determinative factor is not necessarily the lowest possible commission, but whether each security transaction represents the best qualitative execution for the client's account. DCM does not share in any commission or fee charged by any custodian to any client account. 401(k) Retirement Plan Advisory Services DCM may make recommendations to use certain third-party administrators (TPA), to function as administrators to 401(k) plans. DCM and the TPA will provide plan design, plan implementation, 14  Form ADV Part 2A April 7, 2025 and ERISA consultation. The TPA's will offer administration and communication to the plan's participants. The TPA's offer a menu of employee education and communication materials, quarterly statements, online participant support at the TPA's websites, interactive voice response (IVR) telephone systems, including Spanish versions, and customized enrollment materials. The TPA’s will provide compliance documents and reporting to the Department of Labor. DCM receives no compensation from any TPA if a 401(k) plan decides to use the recommended TPA’s services and does not share in any commission or fee charged to any 401(k) participant’s account by a TPA. Item 15 - Review of Accounts Portfolio Reviews DCM continuously monitors all client portfolios for adherence to each portfolio's investment objectives. Portfolio changes are made when DCM determines that; (i) market conditions change causing investment objectives to be adjusted or (ii) client investment objectives change due to client specific factors. Portfolio Reporting Written reports which give a summary of account holdings, transactions, and performance will be furnished to clients on a quarterly basis though our online portal. In addition, daily updated reports which give a summary of account holdings, realized gains & losses, and performance will be furnished to clients through our online portal. DCM offers face-to-face portfolio review meetings upon client request. For our 401(k) clients, the third-party administrator will provide quarterly statements to the employer and employees. DCM will provide semi-annual or annual group meetings with the employer and employees. Item 16 - Client Referrals and Other Compensation DCM does not compensate any individual or organization for referring prospective clients to DCM. Item 17 - Custody DCM does not have custody of clients' cash or securities. Independent qualified custodians hold all clients’ cash and securities. 15  Form ADV Part 2A April 7, 2025 Item 18 - Investment Discretion DCM's Discretionary Account Agreement provides for full discretionary investment control over client assets. The powers of DCM shall include, without limitation, the power to buy, sell, exchange, convert and otherwise trade in any stocks, bonds, mutual funds, and/or exchange traded funds, and to place orders for the execution for such security transactions with or through such brokers, dealers, or issuers for such service and compensation as DCM may deem appropriate. Item 19 - Voting Client Securities Policy DCM as a matter of policy and as a fiduciary to our clients, has responsibility for voting proxies for portfolio securities consistent with the best economic interests of the clients. Our firm maintains written policies and procedures as to the handling, research, voting and reporting of proxy voting and makes appropriate disclosures about our firm’s proxy policies and practices. Our policies and practices include the responsibility to monitor corporate actions, receive and vote client proxies and disclose any potential conflicts of interest as well as making information available to clients about the voting of proxies for their portfolio securities and maintaining relevant and required records. Background Proxy voting is an important right of shareholders and reasonable care, and diligence must be undertaken to ensure that such rights are properly and timely exercised. Investment advisers registered with the SEC, and which exercise voting authority with respect to client securities, are required by Rule 206(4)-6 of the Advisers Act to (a) adopt and implement written policies and procedures that are reasonably designed to ensure that client securities are voted in the best interests of clients, which must include how an adviser addresses material conflicts that may arise between an adviser's interests and those of its clients; (b) to disclose to clients how they may obtain information from the adviser with respect to the voting of proxies for their securities; (c) to describe to clients a summary of its proxy voting policies and procedures and, upon request, furnish a copy to its clients; and (d) maintain certain records relating to the adviser's proxy voting activities when the adviser does have proxy voting authority. Responsibility W. Jeffrey Davidson has the responsibility for the implementation and monitoring of our proxy voting policy, practices, disclosures, and record keeping, including outlining our voting guidelines in our procedures. Procedure DCM has adopted procedures to implement the firm’s policy and reviews to monitor and ensure the 16  Form ADV Part 2A April 7, 2025 firm’s policy is observed, implemented properly, and amended or updated, as appropriate, which include the following: Voting Procedures • All employees will forward any proxy materials received on behalf of clients to W. Jeffrey Davidson. • W. Jeffrey Davidson will determine which client accounts hold the security to which the proxy relates. • Absent material conflicts, W. Jeffrey Davidson will determine how DCM should vote the proxy in accordance with applicable voting guidelines, complete the proxy and vote the proxy in a timely and appropriate manner. Disclosure • DCM will provide conspicuously displayed information in its Disclosure Document summarizing this proxy voting policy and procedures, including a statement that clients may request information regarding how DCM voted a client’s proxies, and that clients may request a copy of these policies and procedures. • W. Jeffrey Davidson will also send a copy of this summary to all existing clients who have previously received DCM's Disclosure Document; or W. Jeffrey Davidson may send each client the amended Disclosure Document. Either mailing shall highlight the inclusion of information regarding proxy voting. Client Requests for Information • All client requests for information regarding proxy votes, or policies and procedures, • received by any employee should be forwarded to W. Jeffrey Davidson. In response to any request W. Jeffrey Davidson will prepare a written response to the client with the information requested, and as applicable will include the name of the issuer, the proposal voted upon, and how DCM voted the client’s proxy with respect to each proposal about which client inquired. Policy Statement DCM is adopting these proxy voting policies and procedures (the "Policies and Procedures") to comply with Rule 206(4)-6 under the Investment Advisers Act of 1940, as amended and its associated record-keeping requirements. The Policies and Procedures apply to those client accounts (i) that contain voting securities; and (ii) for which DCM has authority to vote client proxies. The Policies and Procedures will be reviewed and, as necessary, updated periodically to address new or revised proxy voting issues. Other, similar rights such as consent rights shall be evaluated on a case-by-case basis. Pursuant to the Policies and Procedures and its fiduciary duties DCM will vote client proxies as part 17  Form ADV Part 2A April 7, 2025 of its authority to manage, acquire and dispose of account assets. When voting proxies for client accounts, the DCM's primary objective is to make voting decisions solely in the best interests of clients and beneficiaries and participants of benefits plans for which we manage assets. In fulfilling its obligations to clients, the DCM will act in a manner deemed to be prudent and diligent and which is intended to enhance the economic value of the underlying securities held in client accounts. In certain situations, a client or its fiduciary may provide DCM with a statement of proxy voting policy. In these situations, DCM seeks to comply with such policy to the extent it would not be inconsistent with applicable regulation or the fiduciary responsibility of DCM. General Proxy Voting Guidelines It is the policy of DCM in voting proxies to consider and vote each proposal with the objective of maximizing long-term investment returns for its clients. To ensure consistency in voting proxies on behalf of its clients, DCM utilizes the proxy voting guidelines (the "Proxy Voting Guidelines") set forth below. These guidelines address a broad range of issues, including board size and composition, executive compensation, anti-takeover proposals, capital structure proposals and social responsibility issues. Management Proposals A. The following management sponsored proposals are usually voted in support of management: 1. Approval of auditors and financial statements 2. Election of Directors 3. Requirement that at least 51% of its Board's members be comprised of independent and unaffiliated Directors 4. Requirement that the majority of members of the company's compensation committee, and 100% of members of the company’s nominating and audit committees, be comprised of independent or unaffiliated Directors 5. Recommendations to set retirement ages or require specific levels of stock ownership by Directors 6. General updating/corrective amendments to the charter 7. Elimination of cumulative voting 8. Elimination of preemptive rights 9. Provisions for confidential voting and independent tabulation of voting results 10. Proposals related to the conduct of the annual meeting except those proposals which relate to the "transaction of such other business which may come before the meeting" 11. Capitalization changes which eliminate other classes of stock and voting rights 12. Proposals to increase the authorization of existing classes of stock if: (i) a clear and legitimate business purpose is stated and (ii) the number of shares requested is reasonable in relation to the purpose for which authorization is requested 13. Proposals for share repurchase plans, unless it appears that a repurchase plan lacks a bona fide business purpose 14. Proposals to affect stock splits unless such a split would be contrary to shareholders' interest 15. Proposals to effect reverse stock splits if management proportionately reduces the authorized share amount set forth in the corporate charter. Reverse stock splits that do not 18  Form ADV Part 2A April 7, 2025 adjust proportionately to the authorized share amount will generally be approved if the resulting increase in authorized shares coincides with the proxy guidelines set forth above for common stock increases 16. Director fees unless the amounts are excessive relative to other companies in the country or industry 17. Employee stock purchase plans that permit discounts up to 15%, but only for grants that are part of a broad-based employee plan, including all non-executive employees 18. Establishment of Employee Stock Option Plans and other employee ownership plans 19. Proposals to expense stock options 20. Executive/Director stock option plans. Generally, the stock option plans should meet the following criteria: (i) the stock option plan should be incentive based; (ii) should be no more than 2% per annum of the issued capital at the time of approval 21. Modify or rescind existing supermajority vote requirements to amend the charters or bylaws 22. Adoption of anti-greenmail provisions provided that the proposal (a) defines greenmail, (b) prohibits buyback offers to large block holders not made to all shareholders or not approved by disinterested shareholders, and (c) contains no antitakeover measures or other provisions restricting the rights of shareholders 23. Proposals requiring shareholder ratification of poison pill B. The following proposals are usually voted against, notwithstanding management support: 1. Capitalization changes which add classes of stock which may significantly dilute the voting interests of existing shareholders 2. Proposals to increase the authorized number of shares of existing classes of stock which carry preemptive rights or super voting rights 3. Creation of blank check preferred stock 4. Changes in capitalization by 2% or more where management does not offer an appropriate rationale or where it is contrary to the best interests of existing shareholders 5. Compensation proposals that allow for discounted stock options which have not been offered to employees in general 6. Executive compensation plans that are excessive relative to other companies in the industry 7. Anti-takeover and related provision that serve to prevent the majority of shareholders from exercising their rights or effectively deter the appropriate tender offers and other offers 8. Shareholders rights plans which allow appropriate offers to shareholders to be blocked by the board or trigger provisions which prevent legitimate offers from proceeding 9. Amendments to bylaws that would require a supermajority shareholder vote to pass or repeal certain provisions 10. Proposals to indemnify auditors 11. Proposals to adopt poison pills C. The following types of proposals are usually voted on a case-by-case basis: 1. Change-in-control provisions in non-salary compensation plans, employment contracts, and severance agreements that benefit management and would be costly to shareholders if triggered are not supported by the Advisers, however the Adviser does not want to vote against a good management team, and so will usually abstain 2. Mergers, acquisitions, and other special corporate transactions (i.e., takeovers, spin-offs, 19  Form ADV Part 2A April 7, 2025 sales of assets, reorganizations, restructurings, and recapitalizations) 3. Proposals to create a new class of preferred stock or for issuances of preferred stock up to 5% of issued capital unless the terms of the preferred stock would adversely affect the rights of existing shareholders, in which case we are opposed 4. Proposals to reduce the number of authorized shares of common or preferred stock, or to eliminate classes of preferred stock, provided such proposals have a legitimate business purpose 5. Proposals to change covenants or other terms in connection with financings or debt issuances 6. Proposals to amend terms of shareholder rights agreements or similar documents which will affect the rights of a client 7. Limiting Directors' liability and broadening indemnification of Directors shareholder proposals Shareholder Proposals A. The following shareholder proposals are usually voted in support: 1. Requirement that a majority of members of the company's compensation, nominating and audit committees be comprised of independent or unaffiliated Directors 2. Prohibit payment of greenmail 3. Proposals which request or require disclosure of executive compensation in addition to the disclosure required by the Securities and Exchange Commission ("SEC") regulations 4. Elimination of certain anti-takeover related provisions 5. Reduction or elimination of supermajority vote requirements 6. Proposals to expenses stock options 7. Confidential voting B. The following shareholder proposals are usually voted against: 1. Requirements that the issuer prepare reports which are costly to provide, or which would require duplicative efforts or expenditures which are of a non-business nature or would provide no pertinent information from the perspective of institutional shareholders 2. Restrictions related to social, political, or special interest issuers that impact the ability of the company to do business or be competitive and which have a significant financial or best interest impact to the shareholders 3. Proposals that require inappropriate endorsements or corporate actions 4. Proposals requiring Directors to own large amounts of stock to be eligible for election 5. Proposals which limit tenure of Directors 6. Requiring shareholder approval of golden parachutes C. The following shareholder proposals are usually determined on a case-by-case basis: 1. Proposals to limit golden parachutes 2. Restoring cumulative voting in the election of Directors 3. Requirement that a certain percentage of its Board's members be compromised of independent and unaffiliated Directors 4. Proposals which limit retirement benefits or executive compensation 20  Form ADV Part 2A April 7, 2025 5. Requiring shareholder approval for Bylaw or charter amendments 6. Requiring shareholder approval for shareholder rights plan or poison pill Conflicts of Interest • • DCM will identify any conflicts that exist between the interests of the adviser and the client by reviewing the relationship of DCM with the issuer of each security to determine if DCM or any of its employees has any financial, business, or personal relationship with the issuer. If a material conflict of interest exists, W. Jeffrey Davidson will determine whether it is appropriate to disclose the conflict to the affected clients, to give the clients an opportunity to vote the proxies themselves, or to address the voting issue through other objective means such as voting in a manner consistent with a predetermined voting policy or receiving an independent third party voting recommendation. • DCM will maintain a record of the voting resolution of any conflict of interest. Recordkeeping W. Jeffrey Davidson shall retain the following proxy records in accordance with the SEC’s five- year retention requirement. • These policies and procedures and any amendments. • Each proxy statement that DCM receives. • A record of each vote that DCM casts. • Any document DCM created that was material to deciding how to vote proxies, or that memorializes that decision including periodic reports to W. Jeffrey Davidson or proxy committee, if applicable. • A copy of each written request from a client for information on how DCM voted such client’s proxies, and a copy of any written response. Item 20 - Financial Information DCM does not receive investment management fees more than six months in advance. Item 21 - Requirements for State-Registered Advisers DCM is a federally registered investment adviser. 21  Form ADV Part 2B Brochure Supplement William Jeffrey Davidson CRD File Number 4406705 5350 South Staples, Suite 434 Corpus Christi, Texas 78411 Phone: (361)906-0070 April 7, 2025 This brochure supplement provides information about William Jeffrey Davidson that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about William Jeffrey Davidson is also available on the SEC’s website at www.adviserinfo.sec.gov 22  Form ADV Part 2B April 7, 2025 Educational Background and Business Experience William Jeffrey Davidson Year of Birth – 1966 BBA North Texas State University 1988 MBA Texas A&M University - Corpus Christi 1994 2017-Present Davidson Capital Management, Inc. President/Owner 1992-2017 Davidson Capital Management, Inc. Vice President/Owner 1988-1992 Norwest Financial Texas, Inc. Branch Manager Disciplinary Information William Jeffrey Davidson is required as an investment adviser representative of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of William Jeffrey Davidson. William Jeffrey Davidson has no disciplinary events to disclose. Other Business Activities William Jeffrey Davidson participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. for these activities. 23  Form ADV Part 2B April 7, 2025 Additional Compensation William Jeffrey Davidson does not receive any additional compensation for his work at DCM beyond his standard compensation. Supervision William Jeffrey Davidson's investment management and compliance activities are supervised thru daily office interactions with John Kyle Davidson, Senior Vice President. Requirements for State-Registered Advisers There are no events required to be disclosed by William Jeffrey Davidson. 24  Form ADV Part 2B Brochure Supplement John Kyle Davidson CRD File Number 3087294 9601 US Hwy 281N, Suite 1230 San Antonio, Texas 78216 Phone: (210)418-1989 April 7, 2025 This brochure supplement provides information about John Kyle Davidson that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about John Kyle Davidson is also available on the SEC’s website at www.adviserinfo.sec.gov 25  ADV Part 2B April 7, 2025 Educational Background and Business Experience John Kyle Davidson Year of Birth – 1975 BBA Southwest Texas State University 1998 2017-Present Davidson Capital Management, Inc. Senior Vice President/Owner 2005-2017 Davidson Capital Management, Inc. Vice President/Owner 2002-2005 ADP Retirement Services Regional Channel Manager 1999-2002 Alliance Capital Management Associate Wholesaler Disciplinary Information John Kyle Davidson is required as an investment adviser representative of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of John Kyle Davidson. John Kyle Davidson has no disciplinary events to disclose. Other Business Activities John Kyle Davidson participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. for these activities. 26  ADV Part 2B April 7, 2025 Additional Compensation John Kyle Davidson does not receive any additional compensation for his work at DCM beyond his standard compensation. Supervision John Kyle Davidson's investment management and compliance activities are supervised thru daily office interactions with William Jeffrey Davidson, President & Chief Compliance Officer. Requirements for State-Registered Advisers There are no events required to be disclosed by John Kyle Davidson. 27  Form ADV Part 2B Brochure Supplement Joe Carroll Rust, Jr. AIF® CRD File Number 2674322 9601 US Hwy 281N, Suite 1230 San Antonio, Texas 78216 Phone: (210)418-1989 April 7, 2025 This brochure supplement provides information about Joe Carroll Rust, Jr. that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Joe Carroll Rust, Jr. is also available on the SEC’s website at www.adviserinfo.sec.gov 28  ADV Part 2B April 7, 2025 Educational Background and Business Experience Joe Carroll Rust, Jr. Year of Birth – 1970 BA Texas A&M University – College 1993 2017–Present Davidson Capital Management, Inc. Vice President, Director of Retirement Plans 2007-2017 IBTX Wealth Management Wealth Manager 2002-2007 Planco Financial Services Regional Marketing Director 2000-2002 Alliance Capital Management Associate Wholesaler 1999-2000 Merrill Lynch, Pierce, Fenner & Smith, Inc. Financial Consultant 1997-1999 Citicorp Investment Services Financial Consultant Disciplinary Information Joe Carroll Rust, Jr. is required as an investment adviser representative of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Joe Carroll Rust, Jr. Joe Carroll Rust, Jr. has no disciplinary events to disclose. Other Business Activities Joe Carroll Rust, Jr. participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. 29  ADV Part 2B April 7, 2025 for these activities. Joe Carroll Rust Jr. is Vice President and 49% owner of Alamo City Angels, LLC, a bartending, and promotions business. Mr. Rust spends 3 to 4 hours a week after regular business hours on this activity. Additional Compensation Joe Carroll Rust, Jr. does not receive any additional compensation for his work at DCM beyond his standard compensation. Professional Designations Joe Carroll Rust Jr. has earned the Accredited Investment Fiduciary® (AIF®) designation. AIF® is a professional certification that demonstrates an advisor has met certain requirements to earn and maintain the credential. The purpose of the AIF® designation is to assure that those responsible for managing or advising on investor assets have a fundamental understanding of the principles of fiduciary duty, the standards of conduct for acting as a fiduciary, and a process for fulfilling fiduciary responsibility. The AIF® designation is recognized by FINRA and require advisers to pass rigorous exams demonstrating their knowledge of fiduciary duties. In addition, advisers are required to complete continuing education requirements to maintain their professional designations. Joe Carroll Rust, Jr.'s investment management and compliance activities are supervised thru daily office interactions with either William Jeffrey Davidson, President & Chief Compliance Officer or John Kyle Davidson, Senior Vice President. Requirements for State-Registered Advisers There are no events required to be disclosed by Joe Carroll Rust, Jr. 30  Form ADV Part 2B Brochure Supplement Chad Thomas Jones CWS®, CRPC®, AAMS® CRD File Number 3228632 9601 US Hwy 281N, Suite 1230 San Antonio, Texas 78216 Phone: (210)418-1989 April 7, 2025 This brochure supplement provides information about Chad Thomas Jones that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Chad Thomas Jones is also available on the SEC’s website at www.adviserinfo.sec.gov 31  ADV Part 2B April 7, 2025 Educational Background and Business Experience Chad Thomas Jones Year of Birth – 1973 BBA University of Incarnate Word 2003 2025–Present Davidson Capital Management, Inc. Vice President, Investment Advisor 2017-2025 Frost Investment Services Wealth Advisor 2016-2017 BBVA Securities Incorporated Associate Financial Advisor 2015-2016 Wells Fargo Bank Advisors Financial Advisor 2013-2015 Merrill Lynch, Pierce, Fenner & Smith, Inc. Financial Advisor Disciplinary Information Chad Thomas Jones is required as an investment adviser representative of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Chad Thomas Jones. Chad Thomas Jones has no disciplinary events to disclose. Other Business Activities Chad Thomas Jones participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. for these activities. 32  ADV Part 2B April 7, 2025 Additional Compensation Chad Thomas Jones does not receive any additional compensation for his work at DCM beyond his standard compensation. Professional Designations Chad Thomas Jones has earned several professional designations. Advisers with the Certified Wealth Strategist® (CWS®) designation thrive in serving affluent, high-net-worth, and ultra-high-net-worth clients. CWS® fosters a higher standard of professionalism, nurtures the confidence needed for meaningful client conversations, and provides the essential skills to navigate complex financial situations. The Chartered Retirement Planning CounselorSM , or CRPC® program, is a designation program that enables experienced advisors, who are focused on retirement planning for individuals, define a “road map to retirement” for their clients. There is a focus on clients’ pre- and post- retirement needs, as well as issues related to asset management and estate planning. The Accredited Asset Management SpecialistSM, or AAMS® professional designation program is designed to equip advisors with the information they need to help clients plan for and accomplish their personal financial goals. An AAMS® specialist helps clients plan college savings, taxes, retirement savings, asset management, and investments. The CWS®, CRPC®, and AAMS® designations are recognized by FINRA and require advisers to pass rigorous exams demonstrating their knowledge of investment, insurance, tax, retirement, and estate planning topics. In addition, advisers are required to complete continuing education requirements to maintain each professional designation. Supervision Chad Thomas Jones investment management and compliance activities are supervised thru daily office interactions with either William Jeffrey Davidson, President & Chief Compliance Officer or John Kyle Davidson, Senior Vice President. Requirements for State-Registered Advisers There are no events required to be disclosed by Chad Thomas Jones. 33  Form ADV Part 2B Brochure Supplement Louis Pierce May CRD File Number 8056484 5350 South Staples, Suite 434 Corpus Christi, Texas 78414 Phone: (361)906-0070 April 7, 2025 This brochure supplement provides information about Louis Pierce May that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Louis Pierce May is also available on the SEC’s website at www.adviserinfo.sec.gov 34  ADV Part 2B April 7, 2025 Educational Background and Experience Louis Pierce May Year of Birth – 2001 BA Texas A&M University - College Station 2024 2025-Present Davidson Capital Management, Inc. Vice President, Investment Advisor Disciplinary Information Louis Pierce May is required as an investment adviser representative of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Louis Pierce May. Louis Pierce May has no disciplinary events to disclose. Other Business Activities Louis Pierce May participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. for these activities. Additional Compensation Louis Pierce May does not receive any additional compensation for his work at DCM beyond his standard compensation. Supervision Louis Pierce May's investment management and compliance activities are supervised thru daily office interactions with William Jeffrey Davidson, President & Chief Compliance Officer. Requirements for State-Registered Advisers There are no events required to be disclosed by Louis Pierce May. 35  Form ADV Part 2B Brochure Supplement John Edward Davidson CRD File Number 2789891 5350 South Staples, Suite 434 Corpus Christi, Texas 78411 Phone: (361)906-0070 April 7, 2025 This brochure supplement provides information about John Edward Davidson that supplements the Davidson Capital Management, Inc. (DCM) brochure. You should have received a copy of that brochure. If you did not receive DCM’s brochure or have any questions about the contents of this brochure supplement, please contact W. Jeffrey Davidson at jeff@davidsoncap.com or (361)906- 0070. The information in this brochure supplement has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about John Edward Davidson is also available on the SEC’s website at www.adviserinfo.sec.gov. 36  ADV Part 2B April 7, 2025 Educational Background and Business Experience John Edward Davidson Year of Birth – 1945 BBA University of Texas 1967 MBA Corpus Christi State University 1977 2017-Present Davidson Capital Management, Inc. Consultant 1989-2017 Davidson Capital Management, Inc. President 1987-1989 Lomas Capital Management Vice President/Portfolio Manager 1984-1987 First City Bank of Dallas Senior Vice President/Senior Trust Investment Officer Disciplinary Information John Edward Davidson is required as an investment adviser representative and consultant of DCM to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of John Edward Davidson. John Edward Davidson has no disciplinary events to disclose. Other Business Activities John Edward Davidson participates in a radio show called "Money Wise with Davidson Capital Management" on KKTX 1360 AM in Corpus Christi, Texas, every Saturday from 12pm-2pm CST and on WOAI 1200 AM in San Antonio, Texas from 12pm-1pm CST. KKTX 1360 AM & WOAI 1200 AM are owned by IHeartMedia, Inc. The shows provide information on various investment and financial planning topics. The investment and financial planning information discussed during the shows do not purport to meet the needs of each individual listener. The shows are designed to provide listeners with general investment and financial planning information. Listeners can participate in the shows by sending an email to DCM with questions specific to their personal situation or by suggesting topics to be discussed during the shows. DCM maintains archive recordings of the radio shows on its website at https://davidsoncap.com/radio-money-wise/ and archives all email communications related to the radio shows. DCM compensates IHeartMedia, Inc. for these activities. 37  ADV Part 2B April 7, 2025 Additional Compensation John Edward Davidson does not receive any additional compensation for his work as a consultant to DCM or as a periodic guest contributor to the Moneywise radio program. Supervision John Edward Davidson acts solely as a consultant to William Jeffrey Davidson, John Kyle Davidson, Joe Carroll Rust Jr., and Chad Thomas Jones on matters relating to investment strategy and participates periodically as a guest contributor to the Moneywise radio show. He does not perform any trading functions, has no interactions with clients of DCM, and is not an owner or employee of DCM, therefore his activities require no supervision. Requirements for State-Registered Advisers There are no events required to be disclosed by John Edward Davidson 38