Davidson Investment Advisors, Inc.

Part 2A of Form ADV: Firm Brochure 4901 Libbie Mill E Blvd #210 Richmond, VA 23230 800-332-0529 www.davidsoninvestmentadvisors.com December 15, 2025 This firm brochure provides information about the qualifications and business practices of Caprin Asset Management, a division of Davidson Investment Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 800-332-0529 or DavidsonInvMarketing@dadco.com. 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. Registration as an investment adviser with the Securities and Exchange Commission does not imply any specific level of skill or training. Additional information about Davidson Investment Advisors, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 Material Changes This Firm Brochure (“Brochure”) for Caprin Asset Management, a division of Davidson Investment Advisors (“Caprin”), is our disclosure document prepared according to the SEC’s requirements and rules. This Brochure dated December 15, 2025, contains no material changes from the last annual update, the December 20, 2024 Brochure. 2  Item 3 Table of Contents Item 2 Material Changes .........................................................................................................................................2 Item 3 Table of Contents ........................................................................................................................................3 Item 4 Advisory Business ........................................................................................................................................4 TYPES OF ADVISORY SERVICES .............................................................................................................................4 ASSETS UNDER MANAGEMENT ............................................................................................................................5 SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE ..............................................................................5 Item 5 Fees and Compensation ..............................................................................................................................7 DESCRIPTION ........................................................................................................................................................7 HOW FEES ARE CHARGED .....................................................................................................................................7 Item 6 Performance-Based Fees and Side-By-Side Management ..........................................................................9 Item 7 Types of Clients ...........................................................................................................................................9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................9 METHODS OF ANALYSIS ........................................................................................................................................9 INVESTMENT STRATEGIES ................................................................................................................................. 11 RISK OF LOSS ...................................................................................................................................................... 11 Item 9 Disciplinary Information ........................................................................................................................... 13 Item 10 Other Financial Industry Activities and Affiliations ................................................................................ 13 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................... 14 CODE OF ETHICS ................................................................................................................................................ 14 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ................................................................................. 14 D.A. DAVIDSON PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ....................................................... 15 Item 12 Brokerage Practices ................................................................................................................................ 15 Item 13 Review of Accounts ................................................................................................................................ 16 Item 14 Client Referrals and Other Compensation ............................................................................................. 17 CLIENT REFERRALS ............................................................................................................................................. 17 OTHER COMPENSATION .................................................................................................................................... 17 Item 15 Custody ................................................................................................................................................... 17 Item 16 Investment Discretion ............................................................................................................................ 18 Item 17 Voting Client Securities .......................................................................................................................... 18 Item 18 Financial Information ............................................................................................................................. 19 3  Item 4 Advisory Business account. If the request for restrictions is deemed reasonable by Caprin, we will select replacement securities as appropriate. Note that restrictions placed on an account may positively or negatively affect account performance and may cause the account to perform differently (including worse) than a like account with no restrictions. Restrictions cannot be placed on securities issued by pooled investment vehicles held in a client’s account (e.g., mutual funds, exchange traded funds, etc.). This Brochure describes the investment advisory services offered by Caprin Asset Management (“Caprin” or “we”), a division of Davidson Investment Advisors, Inc. (“Davidson Investment Advisors,” “Davidson,” or “the Firm”). The purpose of this Brochure is to describe and disclose the services, fees, potential conflicts of interest, and other information clients should consider regarding the advisory services offered by Caprin. The information contained herein is current as of the date of this Brochure and is subject to change at Caprin’s discretion. Please retain this Brochure for your records. Davidson Investment Advisors has a separate Firm Brochure and Wrap Brochure that describe the investment advisory services offered by Davidson and is available upon request or visit the website at www.dadavidson.com/Disclosures. Client-Directed Tax Harvesting. For taxable accounts, Caprin will also accept instructions to harvest a specific amount of tax losses or gains, subject to such limitations and procedures as the Firm may establish from time to time. Instructions to harvest tax losses must be provided in writing in the manner prescribed by the Firm. Caprin will reasonably attempt to fulfill these instructions but may determine that a request is not feasible for a variety of reasons, including but not limited to, the size of the request. Any proceeds from such tax loss sales will be held in cash and will not be reinvested in substitute securities, unless otherwise instructed, which may affect the performance of the account. Caprin was acquired by Davidson effective March 1, 2023 and currently operates as a division of Davidson Investment Advisors. Davidson Investment Advisors is wholly-owned by D.A. Davidson Companies, a financial services holding company. Davidson Investment Advisors has been conducting business since 1975, with headquarters in Great Falls, Montana. TYPES OF ADVISORY SERVICES The advisory services offered by Caprin include portfolio management, investment advice, performance reporting, and related account services. Caprin retains all discretion regarding portfolio construction, changes to portfolios, timing and parameters for implementation, execution, monitoring and rebalancing. In addition to the portfolio management services described above, Caprin may also serve as sub- adviser to other duly registered investment adviser firms for the purpose of managing their clients’ fixed income portfolios using some or all of the strategies described above. In such circumstances, the agreement between Caprin and the firm(s) for whom Caprin serves as sub-adviser authorizes Caprin, without prior consultation, to buy or sell securities according to the investment guidelines agreed to between Caprin and the primary advisory firm subject to client parameters established between the primary advisory firm and the client. Caprin generally has the flexibility to accept or reject client specific parameters on a case-by-case basis. Caprin makes itself available to clients of financial advisors via dual contract arrangements, where clients sign both custodial agreements and Caprin’s investment advisory agreement, but Caprin prefers whenever possible to participate as a manager available in certain Wrap Fee programs. As a Wrap Reasonable Investment Restrictions. Subject to their agreement with Caprin, a client may request that we impose reasonable restrictions on the securities or types of securities held in an account, including directing Caprin to not purchase or liquidate certain securities in their account. Each request for a restriction by a client must be communicated in writing to Caprin and will be considered in accordance with Caprin’s policies and procedures and must be approved by Caprin in its sole discretion. This option, however, is not intended to permit a client to direct the purchase of certain securities or types of securities in their 4  Program Participant, the custodian charges clients only one fee, and a previously agreed to portion of that fee is then paid to Caprin as portfolio manager. When managing portfolios, Caprin treats its Wrap Fee clients exactly the same as it treats its direct clients and other clients referred by independent advisors. Generally, the investment parameters of a Wrap Fee client relationship are similar to those discussed in the previous paragraph on sub-advisory relationships. ASSETS UNDER MANAGEMENT As of September 30, 2025, Caprin managed approximately $1.1 billion in assets, all of which are discretionary. Additionally, Caprin serviced approximately $61 million in model-based assets, which are not included on Davidson’s ADV Part 1. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE “retirement accounts”) Caprin is a “fiduciary” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when providing investment advice or managing a client’s account. ERISA and the Code limit the types of products and services Caprin can offer and provide with respect to retirement accounts. When making recommendations that clients open, rollover or transfer retirement account assets to an advisory account or change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020-02, which allows Caprin to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires Caprin to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under PTE 2020-02, Caprin and its financial professionals must also: • Meet a professional standard of care (give prudent advice); • Not put the Firm’s financial interests ahead of client’s (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that the Firm and its financial professionals give advice that is in client’s best interest; • Charge no more than is reasonable for the Firm’s services; and • Give the client basic information about conflicts of interest. Advisers Act Fiduciary Duty. As a registered investment adviser, Davidson Investment Advisors and its Caprin division are subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means we are required to act in the client’s best interest when providing investment advice and managing client accounts. The duty of care requires, among other things, for Caprin to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information and other circumstances or mandate (collectively, client’s “Investment Profile”). The duty of loyalty requires Caprin to eliminate or mitigate material conflicts of interest with clients, and to provide full and fair disclosure of such conflicts of interest. The duty also requires Caprin to provide ongoing monitoring of clients’ accounts and its recommendations in advisory accounts. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendation (“Covered Recommendation”), as may be applicable: Special Rules for Retirement Accounts. For retirement and other qualified accounts, including employer-sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, Coverdell educational savings accounts, and other similar accounts (collectively, 5  other transactions or discretionary investment advice, except as otherwise agreed to in writing in any applicable agreements or disclosures; • Roll Out Recommendation. From time to time, the Firm in coordination with a centralized review team, will provide a written recommendation that client roll out assets from a plan to an IRA. • Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company; and • Recommendations that are not fiduciary The above acknowledgement does not apply to other suggestions, recommendations, and services the Firm and its financial professionals provide and that are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. Caprin refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an individualized/personalized suggestion for a client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as a Covered Recommendation under this disclosure, including, but not limited to: “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account). • General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; • General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm; • General Information and Education about rollovers from a 529 account to a Roth IRA; • Transfers of retirement account assets held at a financial service company other than the Firm (including directly with an investment product sponsor); • Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts); • Transactions clients enter into without a recommendation from Caprin or that are contrary to, or inconsistent with, their recommendation; The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020- 02 does not require that Caprin guarantee the performance of any investment or that a client’s investment objectives will be achieved. In addition, Caprin and its financial professionals may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to a client. There may be times Caprin is legally prohibited from making a recommendation that may be otherwise considered to be in a client’s best interest, such as due to insider trading. A client understands any recommendations Caprin, or its financial professionals make will reflect the information a client provides to the Firm about their investment objectives, risk level, investment time horizon, financial information and other circumstances and Caprin will not be responsible for any information client omits or fails to provide, including changes thereto. Caprin and its financial professionals’ recommendations and advice will also reflect any reasonable limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying Caprin and their financial • Ongoing recommendations of securities or 6  Though Caprin strives for consistency wherever possible, we recognize that not all client arrangements are identical and therefore reserves the right to negotiate fees. HOW FEES ARE CHARGED professionals if their investment objectives, risk tolerance or financial circumstances change. Caprin will not be responsible for clients’ decision to invest or transfer their retirement account assets in a manner that is different from, or inconsistent with, Caprins’ recommendations or other advice and guidance, and clients assume the risk of such decision, nor will Caprin or its financial professionals be responsible for clients’ delay in implementing a recommendation. The specific manner in which fees are charged by Caprin is established in each client’s written agreement with Caprin or within each respective agreement governing the managed account program provided by a third-party program sponsor, which may be Sub-Advisory, Wrap, or Dual Contract. Caprin maintains two distinct fee schedules for separately managed accounts that differ primarily based on the nature of the relationship between Caprin and its clients. When Caprin and its representatives bear primary responsibility, including assisting with the selection of the appropriate investment strategy and reporting, the relationship is direct (‘DIRECT’). When a third-party investment adviser or financial adviser makes the recommendation or decision to engage Caprin as an asset manager for the client using a managed account program available to the adviser through their broker/dealer, Caprin’s responsibilities are reduced to that of portfolio management only for the Caprin investment strategy as the adviser bears the primary responsibility for all aspects of the client’s investment program (‘DUAL CONTRACT’). Reasonable compensation under the DOL Fiduciary Duty has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features and benefits) provided. This standard does not require the Firm to offer its services at the lowest cost, or for the least compensation, in the marketplace, nor that it offer its services to clients at the same or lower cost or compensation levels than it offers to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their accounts than those that apply to client’s advisory account. By entering into an agreement with Caprin, client agrees that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If client decides not to use all or some of the services made available, client agrees the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If clients want to change the services the Firm makes available to them or has any concerns regarding the level of fees their retirement account pays or Caprin’s compensation, a client should contact us immediately. Item 5 Fees and Compensation DESCRIPTION Where Caprin and the client have a specific written agreement, fees will generally be billed on a quarterly basis in advance, and bills will be submitted directly to each client’s custodian of record. In these arrangements, management fees will be prorated for each capital contribution made during the applicable calendar quarter (with the exception of inconsequential contributions). Furthermore, accounts opened or closed during a calendar quarter will be charged a prorated fee reflecting the accounts’ actual time under management. A client’s investment management agreement will set forth the actual compensation the client will pay to Caprin. A client pays Caprin an ongoing fee based on the market value of the assets in the account on the last day of the preceding quarter. Caprin does not have one standard annual fee schedule that is applicable across all strategies but has a fee schedule per strategy and account type. If a Caprin account is governed by a Sub-Advisory or Wrap program agreement, Caprin’s fees, along with the fees of the program sponsor, and all corresponding rules are the sole responsibility of the program sponsor and are governed by the client agreement with the program sponsor. For this reason, the fee schedules provided below are 7  account assets up to $5 million; .15% on the next $10 million in account assets; Fees are subject to review on assets above $15 million. ETF Strategies: only for Caprin separately managed accounts that are DIRECT as described above or DUAL CONTRACT, where an adviser supervises investment strategies under a managed account program and the client has an agreement with Caprin and a separate agreement with the adviser’s firm. Below are typical strategy-specific fee schedules applicable to separately managed accounts for which Caprin has trading discretion. Note: There are exceptions to the below fee construct for a limited number of clients based on legacy relationships and/or supervisory approval. Intermediate Maturity Municipal and Taxable Fixed Income: Caprin’s fee schedule for Intermediate Maturity Municipal Bond and Taxable Bond accounts managed on a DIRECT basis is as follows: 0.50% on account assets up to $5 million; 0.40% on the next $10 million in account assets; fees are subject to review on assets above $15 million. Caprin created in late 2010 and began marketing strategies that utilize various Exchange Traded Funds (ETF’s) and maintains two distinct fee schedules for these strategies that are based on the nature of the relationship between Caprin and the client. Caprin makes its Managed ETF strategies available as separately managed accounts on a DIRECT and DUAL CONTRACT basis and as model selections available through platforms like Unified Managed Accounts Platforms (UMA) and TAMPs administered by overlay managers through Sponsor Firms. When Caprin’s Managed ETF strategies are utilized as separate accounts, Caprin’s fee is 0.25% on all assets. When Caprin’s Managed ETF strategies are selected as a Model through an overlay manager, Caprin’s fee is set by the Sponsor Firm and overlay manager, and this fee may vary between Sponsor Firms. All clients are encouraged to consult with their advisor for a full description and explanation of fees for each account and participating program. Services Covered by the Fees. The fee includes Caprin's investment management and other administrative services. Caprin’s fee schedule for Intermediate Maturity Municipal Bond and Taxable Bond accounts managed on a DUAL CONTRACT basis is as follows: 0.35% on account assets up to $5 million; and 0.25% on the next $10 million of account assets; Fees are subject to review on account assets above $15 million. Fees for Caprin managed Sub-Advisory or Wrap accounts are governed by the program sponsor’s agreement and may differ from sponsor to sponsor. Short Maturity Municipal and Low Duration Taxable Fixed Income: Caprin’s fee schedule for Short Maturity Municipal Bond and Low Duration Taxable Bond accounts, whether managed on a DIRECT basis or DUAL CONTRACT basis is as follows: 0.30% on account assets up to $5 million; 0.20% on the next $10 million in account assets; Fees are subject to review on assets above $15 million. Fees for Caprin managed Sub-Advisory or Wrap accounts are governed by the program sponsor’s agreement and may differ from sponsor to sponsor. Taxable Cash Management: Caprin’s fee schedule for Taxable Cash Management accounts is as follows: 0.20% on Services NOT Covered by the Fees. Caprin’s fees do not include brokerage commissions, transaction fees, and other related expenses that may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and other third parties like fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, commissions and other fees and taxes on brokerage accounts and securities transactions. Exchange-traded funds, which may be incorporated into a client account depending on the strategy selected, also charge internal management fees that are disclosed in a fund’s prospectus. Caprin encourages all clients and prospective clients to consult with their financial adviser or custodial relationship on the fees and services provided by the respective managed account program or custodial relationship through which Caprin has been accessed. 8  days prior written notice. The fee schedules set forth above are current fee schedules for various strategies. Each strategy has had different fee schedules in effect over time, which may have reflected fees that are higher or lower than those currently stated. Item 6 Performance-Based Fees and Side-By-Side Management Caprin does not charge performance-based fees. Additional Fees and Expenses. Caprin may invest client assets in one or more pooled investment vehicles, such as mutual funds and ETFs, if such investments are consistent with the investment objectives and policies of the client accounts involved. If Caprin makes such an investment on behalf of its clients, those clients will be responsible, indirectly as investors in the pooled investment vehicles, for a portion of the operating expenses of the pooled investment vehicles in which they are invested. In effect, those clients would be paying multiple advisory fees. Item 7 Types of Clients Caprin provides portfolio management services to individuals, high net worth individuals, corporations, ERISA and non-ERISA retirement plans, charitable institutions, foundations, endowments, municipalities, and other U.S. institutions. When investing in mutual funds, including money market funds, a 12b-1 fee may be assessed, depending on the fund selected. 12b-1 fees are sales charges that are incorporated into the expense ratio of the fund. As a matter of Caprin’s policy, any new purchases of mutual funds in a Program account must be in an advisory share class that does not impose a 12b-1 Fee, where such a share class is available. Termination of the Advisory Relationship. If either Caprin or client terminates the client’s investment management agreement, any prepaid, unearned fees will be refunded. In calculating a client’s reimbursement of fees, Caprin will calculate a pro- rated refund based on the number of days remaining in the billing period. Minimum Account Requirements. Caprin generally requires a minimum account size of $2 million for accounts of clients hiring Caprin directly for individual bond portfolios, but when other independent investment advisers or financial advisers introduce clients to Caprin, Caprin generally has agreed to lower its minimum account size to $150,000 for all strategies except the taxable cash management strategy, for which the minimum size generally remains $2 million. Caprin requires a minimum account size of $100,000 for accounts of clients hiring Caprin to manage an all ETF separately managed account. When clients select all ETF strategies through a UMA or TAMP, minimum investments may vary. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Caprin takes a conservative and measured approach to the incremental risks of investing in fixed income securities. Opportunities to enhance yield are carefully measured against potential risks as Caprin strives to minimize overall volatility through investment cycles. METHODS OF ANALYSIS Purchasing Like Services Outside of an Advisory Relationship. The products and services provided to a client in connection with a Caprin advisory account may be available to a client outside of the advisory account. Clients are cautioned that, depending on factors such as: the level of fees charged by the executing broker-dealer, the amount of trading activity in the client’s account, the value of the client’s account, the types of securities held in the client’s account, the client’s investment strategy, and the level of service sought by the client, the aggregate cost of the client’s advisory account may be higher than if the client had selected the services separately. In addition, fees charged by Caprin may be higher or lower than the fee charged by another firm that offers comparable advisory services. Caprin employs the following “top-down” investment process, as overseen by Caprin’s portfolio management team for each strategy Additional General Fee Information. Caprin may modify a client’s existing fees and/or add additional fees or charges by providing the client thirty (30) 9  offered: scrutinize Fed statements and targets in terms of longevity and potential impact on economic conditions. • Interest Rate Momentum – Caprin has developed quantitative analytics to evaluate interest rate trends, longer-term momentum, and interest rate volatility. These supplement the firm’s fundamental analyses. Sector Positioning. Caprin develops its outlooks for desirable and out-of-favor sectors from several vantage points in the investment process. These outlooks are incorporated into strategy via the Team’s collective decisions. The portfolio management team meets regularly to review each member’s assessment of the current investment landscape and the recommended investment parameters for achieving strategy goals. Following their review and discussion of recommendations, average duration ranges, asset class targets, and other metrics are incorporated into the firm's strategy rules that then guide portfolio management activity. Caprin’s portfolio managers work collectively to assess the current outlook, previous activity, and evaluate circumstances relative to current strategy parameters. Our quantitative analytics are effective tools for providing real-time insight on market conditions and relative value on an intraday basis. The team utilizes this proactive approach as needed to recommend strategy adjustments. Duration and Maturity Positioning. When interest rates are expected to be stable, Caprin will structure portfolios with yield curve allocations generally in line with the assigned benchmark (at a neutral duration). When interest rates are expected to fall, Caprin will structure portfolios with longer-than-benchmark yield curve allocations and target duration. When interest rates are expected to increase, Caprin will strive for portfolios with duration and yield curve allocations shorter than the assigned benchmark. The following key considerations are used to develop Caprin’s interest rate outlook: • Economic Analysis – Caprin evaluates Caprin integrates research from external sources and from proprietary internal analytics to develop its outlook on the sectors relevant to the particular strategy. The internal analytics are both fundamental credit scoring metrics which assess individual credits that translates to the identification of broader sector trends and fundamental relative strength models that measure the attractiveness of certain sectors relative to each other. External sources include issuer and obligor reviews and analytics on the performance of various market-based risk management tools. Caprin utilizes Bloomberg to evaluate the ETF segment across characteristics such as yield curve, duration, credit quality, sector, and asset class metrics based on the aggregate of the securities underlying the ETFs, and to validate that recommended allocations have desired characteristics and performance attributes. economic metrics and indicators to assess interest rate trends within the broader economic cycle, including measures such as inflation, employment, international and domestic growth, demographic trends, political events, inflation expectations, likely monetary and fiscal policy, and risk market price momentum. Caprin also considers current macro-driving events and their potential impact on interest rate trends. Security Selection and Execution. Caprin uses rules-based investment parameters in its portfolio management application (Perform) which are constructed for each strategy based on portfolio managers’ decisions. Bond purchases and sales needed to align portfolios with strategy parameters are identified using those rules. Caprin utilizes Perform FPC to monitor each portfolio across 50+ characteristics to assess yield curve, duration, credit quality, sector, and asset class metrics for each strategy, and to help highlight portfolio characteristics and outliers. • Fed Policy – Caprin analyzes current Federal Reserve targets, policies and language in determining an outlook for interest rates within a Fed-driven cycle. We Target transactions are recorded in Perform, and the designated market specialist initiates activities 10  portfolios to average maturities of generally four months to eighteen months. to buy or to sell securities to satisfy the requested transactions. Portfolio Managers evaluate each investment opportunity incorporating both third party research and internal analyses and work closely to capture opportunities that arise. Within the short maturity municipal bond and low duration taxable bond strategies, Caprin may use traditional ETFs in these portfolios to gain market exposure while building new accounts. Traditional ETFs are not a part of cash management portfolios. Caprin has developed research models that compare financial strength and risks across issuers. We seek to add value by identifying securities with a favorable relative value to issuer risk profile. When appropriate, Caprin executes block trades to secure the best price and to ensure implementation of our best ideas across the maximum number of accounts. Recognizing that the market is dynamic, portfolio managers are poised to respond to changing conditions. Ongoing communication ensures our team and our process is responsive and that client portfolios benefit from our current best thinking. INVESTMENT STRATEGIES In addition to the individual bond strategies described above, Caprin manages separate account strategies using only ETFs. Caprin may also serve as “model provider” for these ETF strategies where they are available through select turnkey asset management programs (TAMPs). Registered investment advisors and broker dealers utilize TAMPs as a way to make available many investment solutions to their clients. In the model format, Caprin’s all-ETF strategies are available via subscription, and all transactions are executed by an unaffiliated third party, typically the TAMP itself. In keeping with our philosophy of capital preservation and income, Caprin manages both intermediate and short maturity fixed income portfolios. Caprin’s intermediate municipal bond portfolios generally, but not always, will have an average maturity of six to nine years, while Caprin’s intermediate taxable bond portfolios generally, but not always, will have an average maturity of four to six years. These all-ETF strategies, one that focuses on the municipal bond market, another which seeks exposure to the taxable bond market, and one that combines municipal and taxable fixed income sectors, may have an equivalent average maturity ranging from roughly zero to 10 years based on the weighted average of the characteristics of the ETFs held in each portfolio. It is important to recognize that the maturity characteristics of these all-ETF strategies primarily are provided to help investors compare portfolio features as the majority of traditional fixed income ETFs do not mature like an individual bond. Given the separately managed nature of our portfolios, client-specific customizations may be accommodated per request, at Caprin’s discretion. RISK OF LOSS In our intermediate portfolios, Caprin may use traditional mutual funds and exchange traded funds (“ETFs”) whose goals are consistent with those of Caprin’s strategies. Mutual funds and exchange traded funds may be used to help gain exposure to the desired market more quickly when building new accounts or to more easily adjust a portfolio’s positioning along the maturity curve. Clients should understand that investing in any securities involves a risk of loss of both income and principal. In addition to the intermediate maturity portfolios described above, Caprin offers short maturity municipal bond and low duration taxable bond strategies. The short maturity municipal bond and low duration taxable bond portfolios generally, but not always, will have an average maturity of one to three years. Caprin also has a cash management short maturity taxable fixed income strategy that invests Risks for all forms of security analysis. Securities analysis methods rely on the assumption that the entities whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk 11  that our analysis becomes compromised by inaccurate or misleading information. Investing in any security involves risk of loss that clients should be prepared to bear. Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at a potentially lower rate of return (i.e., due to reductions in interest rates). This relates primarily to client account investments in fixed income securities. Business Risk. These risks are associated with a particular industry or company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of potential profitability than an electric company, which generates its income from a steady stream of customers who buy electricity of the prevailing economic environment. Mutual Fund ETF Analysis. A common risk of ETF analysis is that, as with other securities investments, past performance does not guarantee future results. A manager who has been successful in identifying profitable opportunities among funds may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in an ETF, managers of different funds held by the client may purchase the same security, creating concentrated exposure for the client to that security and increasing the risk to the client if that security were to fall in value. There is also a risk of a manager deviating from the stated investment mandate or strategy of the ETF, which could make the holding(s) less suitable for the client’s portfolio. Liquidity Risk. Liquidity is the ability to readily convert a security into cash. Securities in a client’s account are more liquid if many individuals are interested in buying or selling them. For example, Treasury bills are highly liquid, while real estate properties are relatively illiquid. Liquidity risk is therefore the risk that a client will not be able to promptly sell a security due to a limited market for that instrument. Interest Rate Risk. Fluctuations in interest rates cause investment prices to fluctuate. For example, bond market values have an inverse relationship to changes in interest rates. Rising interest rates cause bond market values to decline, and declining interest rates cause market values to rise. Generally, the longer a bond’s maturity, the greater the interest rate risk and the higher its yield. Similarly, equities may also suffer from rising interest rates. Financial Risk. Excessive borrowing to finance a business’ operations may create a degree of stress on the firm to the point of jeopardizing its profitability, and potentially triggering a default on one or more outstanding loans. Depending on the circumstances, such a development could lead to a declining value in the company’s securities, or even its bankruptcy. Market Risk. Market risk is the risk of investment losses in a client’s account due to a variety of reasons outside of our control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, epidemic, pandemic, or social events, independent of the intrinsic valuation of one or more securities in the client’s account. Inflation Risk. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Inflation risk is the risk of inflation exceeding or eroding the return of an investment in the client’s account. Global Economic Risk. National and regional economies and financial markets are becoming increasingly interconnected, which increases the possibility that conditions in one country, region or market might adversely impact issuers in a different country, region or market. Changes in legal, political, regulatory, tax and economic conditions may cause fluctuations in markets and securities prices around the world, which could negatively impact the value of an account’s investments. Major economic or political disruptions, particularly in large economies, may have negative global economic and market repercussions. Additionally, events such as war, terrorism, natural and environmental disasters and the spread of infectious illnesses or other public 12  automated nature of the services provided. Concentration Risk. This is the risk that a client’s portfolio is heavily allocated in one or few securities, industries, sectors, or geographic locations. This increases the impact of negative or positive performance compared to a portfolio which is diversified. health emergencies may adversely affect the global economy and the markets and issuers in which an account invests. These events could reduce consumer demand or economic output, result in market closure, travel restrictions or quarantines, and generally have a significant impact on the economy. Such events could materially increase risks, including market and liquidity risk, and significantly reduce account values. Specific Security Risks. In addition to the above risks, each security type used has certain characteristics and is subject to a risk of loss that clients should be prepared to bear. For more information about risks associated with stocks, fixed income securities, mutual funds, and ETFs should speak with a financial professional. For risks associated with mutual funds and ETFs in a client’s account, see the fund’s current prospectus Item 9 Disciplinary Information Davidson Investment Advisors and its Caprin division do not have any material legal, financial, or disciplinary events that require disclosure. We are required to disclose any legal or disciplinary events that would be material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Cybersecurity Risk. Client portfolios are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events that include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cyber security failures or breaches by a third party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially result in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Item 10 Other Financial Industry Activities and Affiliations Davidson Investment Advisors is a wholly-owned subsidiary of D.A. Davidson Companies, a financial services holding company with other subsidiaries: D.A. Davidson & Co. (“D.A. Davidson”), D.A. Davidson Trust Company (“Davidson Trust Company”), and D.A. Davidson Trust Services, Inc. (“DADTS”). D.A. Davidson. D.A. Davidson is a broker-dealer registered as such with FINRA (Financial Industry Regulatory Authority) and a SEC Registered Investment Adviser. D.A. Davidson Financial Professionals may refer clients to Davidson Investment Advisors, Inc. in its capacities as independent investment adviser and as an investment adviser participating in D.A. Davidson’s advisory programs. D.A. Davidson and its Financial Professionals have an incentive to recommend a Program or an investment manager that is affiliated with D.A. Davidson because the Technology Risk. Caprin’s investment offerings are dependent upon various computer and telecommunication technologies, many of which are provided by or are dependent on third parties. The successful operation of our firm could be severely compromised by system or component failure, telecommunication failure, power loss, a software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damage, human errors in using or accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunication systems or operations could have a material adverse effect on the firm. Such a material effect may have a heightened impact on the investment strategies, given the 13  under the Investment Company Act of 1940. For additional information, the Fund’s Prospectus and Statement of Additional Information are available at: www.davidsonmutualfunds.com. Prospective investors should review these documents carefully before making any investment in the mutual fund. entire client fee is retained by D.A. Davidson and its Affiliate. However, in providing investment advisory services to clients, D.A. Davidson and its Financial Professionals are required to act solely in the best interest of clients. The criteria used by them in deciding to select or recommend affiliated investment products are the same as those used for unaffiliated investment products. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CODE OF ETHICS The Firm, including its Caprin division, has adopted a Code of Ethics (“Code”) which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Davidson Trust Company. Davidson Trust Company is a federal savings bank. Davidson Trust may elect to hire Davidson Investment Advisors as the investment adviser for certain client accounts over which Davidson Trust has investment discretion. Davidson Trust shares a portion of its investment management fee with Davidson Investment Advisors for providing investment advisory services. Davidson Investment Advisors also manages four Davidson Trust Company common trust funds. D.A. Davidson Trust Services, Inc. DADTS is a non- depository trust company chartered in New Hampshire which acts as the custodian for D.A. Davidson client assets maintained in IRA and 403(b) accounts. D.A. Davidson provides DADTS with supporting administrative, recordkeeping and reporting services as the client’s broker-dealer. Davidson's Code establishes rules of conduct for all employees and is designed to govern personal securities trading activities in the accounts of employees, among other things. The Code is based upon the principle that Davidson and its employees owe a fiduciary duty to its clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: serving their own personal interests ahead of clients; taking inappropriate advantage of their position with the Firm; and any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by calling us at (804) 583-4075. Note Regarding D.A. Davidson Companies Conflicts of Interest. Fee sharing agreements amongst Davidson, D.A. Davidson, Davidson Trust Company, and DADTS create a conflict of interest because the fees for managing and trading client accounts are all retained by D.A. Davidson Companies. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS As a general practice, Davidson, including its Caprin division, does not engage in principal transactions. Davidson employees are allowed to invest in the same securities recommended to or owned by clients. However, to avoid conflicts of interest, all Davidson employees are required to receive prior approval to trade in personal security accounts. Davidson Investment Advisors may recommend clients use D.A. Davidson, D.A. Davidson Trust Company, and DADTS, related parties, for custody and safekeeping purposes. The client also retains the right to direct Davidson to use another broker. If a client elects to use D.A. Davidson, D.A. Davidson Trust Company, or DADTS, the client may terminate the arrangement at any time. See additional information regarding Directed Brokerage under Item 12 – Brokerage Practices. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory Mutual Fund. Davidson Investment Advisors is the investment adviser to the Davidson Multi-Cap Equity Fund (the “Fund”), a series of the Adviser Series Trust, an investment company registered 14  clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. D.A. DAVIDSON PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS securities are issued in limited size and trade over the counter in a negotiated manner. In cases where commissions are negotiated, executing brokers will be selected first on suitability of investment selection, quality and breadth of service, and then lowest commissions; Caprin also considers its past experience with such firms and the quality of service provided to us (and our clients by extension), the liquidity of the security being traded, the speed and attention we receive from the trading desk of the firm selected, market conditions at the time, and other factors. Based on these factors, Caprin may trade with executing brokers that may charge fees that are higher than the lowest available fees. As previously noted, Davidson Investment Advisors may recommend D.A. Davidson, a related party and broker-dealer, as the qualified custodian or DADTS as a qualified custodian for Davidson Investment Advisor clients. Subject to the requirements of applicable law, D.A. Davidson may act as principal, buying securities for itself from, or selling securities it owns to, an advisory client, but only on a case- by-case basis with advance written authorization from the client, and when it is in the best interest of a client to do so. Consistent with obtaining best execution for clients, Davidson and its Caprin division maintain trading arrangements with various broker-dealers whereby we have access to its research. We may direct trades to one of those broker-dealers and pay commissions that are competitive but that are higher than the lowest available rate that another broker might have charged, if Caprin determines in good faith that the commissions are reasonable in relation to the value of the brokerage and research services provided. D.A. Davidson’s policy generally prohibits agency cross transactions for advisory clients, but in rare cases exceptions may be granted. An agency cross transaction is a transaction in which D.A. Davidson acts as broker for the party or parties on both sides of the transaction. However, no cross transactions may be made in ERISA-covered or IRA advisory accounts. For additional information regarding D.A. Davidson’s principal trading and agency cross transaction policies, please refer to D.A. Davidson’s Wrap Fee Program Brochure. You may also request a copy by calling us at (804)-583-4075. For additional information regarding D.A. Davidson’s principal trading and agency cross transaction policies, please refer to D.A. Davidson’s Firm Brochure. Item 12 Brokerage Practices Additionally, in connection with accounts where the client has accessed Caprin via a managed account program sponsored by a broker/dealer or related firm and where the client pays a program fee to the program’s sponsor for the respective program, Caprin will in most instances not trade securities with that program sponsor when a conflict of interest or a commission payment for securities transactions to the program sponsor would arise. We may implement this restriction at our discretion, while some program sponsors may impose this restriction. This restriction could result in execution prices that are not always at the best possible levels. When providing our services, Caprin will execute transactions through securities broker-dealers. When selecting broker-dealers for trade execution, we will consider a variety of factors. In most cases, executing brokers will be selected based on availability of product and/or the best net price bid or offer to the client. Availability of investment supply generally requires Caprin to purchase and sell bonds away from a client’s designated custodian because of the nuances of trading fixed income securities. Unlike stocks and other exchange traded securities where markets of sufficient size are readily accessible, Fixed Income When Caprin determines based on its duty to seek best execution that the most appropriate method of execution is that of a Step Out transaction, client(s) may be subject to commissions and other charges in addition to the fee they are already paying to their custodian/program sponsor. For instance, as discussed earlier in Item 5, clients may incur in the case of ETF related transactions an 15  thereafter. additional commission of up to $0.01 per share, and such commission will be included in the net price of the transaction as reported to the client’s custodian and/or Wrap Program Sponsor. In the case of Fixed Income Security transactions stepped out, the executing broker dealer may in some cases impose on the transaction a markup or markdown, which will be reflected in the net price of the transaction to the client. These fees are in addition to any “program fee” the client may pay when utilizing a Caprin strategy through a managed account program. Directed Brokerage. Some clients, when undertaking an advisory relationship, may already have a pre-established relationship with a broker- dealer. Therefore, the client may instruct Caprin to execute all transactions through that broker- dealer. If the client directs Caprin to use a particular broker-dealer, the client recognizes that Caprin will likely have no authority to negotiate transaction costs, to obtain volume discounts and best execution may not be achieved. Under these circumstances, there may be a disparity in commissions charged among the Firm’s clients. Trade Errors. As a fiduciary, Caprin has the responsibility to effect orders correctly, promptly and in the best interests of its clients. If an error occurs in the handling of any client transactions or the Fund, due to the Firm’s action, or inaction, or actions of others, the Firm’s policy is to seek to identify and correct errors as promptly as possible without disadvantaging the client or Fund in any way. If the error is the responsibility of Caprin, the transaction will be corrected, and Caprin will be responsible for any client loss resulting from an inaccurate or erroneous order. Caprin prefers, when possible, to execute transactions in “blocks,” meaning orders for more than one client, often from more than one custodian/program sponsor, are grouped together to increase the size of the transaction. “Block trading” may enable Caprin to obtain more favorable execution, including better pricing and enhanced investment opportunities, than were Caprin to trade solely with each client’s designated custodian/program sponsor. Blocking transactions in this manner may also help Caprin avoid a potentially adverse effect on the price of a security that could result from simultaneously placing a number of separate, successive or competing client orders (particularly for clients at many different custodians). Item 13 Review of Accounts Client accounts are managed according to targets consistent with the client’s investment guidelines. Caprin performs operational reviews of client portfolios monthly, and compliance reviews semi- annually. Where differences from approved strategy ranges are noted, recommendations are developed and changes made as market conditions permit. Reviews may be conducted more frequently as dictated by strategy changes or market action. It is ultimately the client's responsibility to advise the Firm of any changes to the information previously provided that might impact their account. Neither the Firm nor any investment manager is responsible for independently verifying information or data provided by a client, or for any adverse consequence arising out of or in any way connected with the client’s failure to promptly communicate the updated or new information to Because Caprin trades predominantly in Fixed Income Securities, and because of Caprin’s duty to find, to the best of its abilities, securities most appropriate for each client account given portfolio strategy and the then prevailing market conditions, Caprin places nearly all fixed income transactions for clients with firms other than the client’s designated custodian/program sponsor (and even in some cases is prohibited from trading with a client’s designated custodian or broker dealer firm where the transaction may create a conflict of interest); further, it is increasingly rare that any given broker dealer maintains a sufficient inventory of suitable fixed income securities, a factor Caprin must contend with when seeking to build and manage client portfolios according to their designated strategy. Because of the nuances of trading Fixed Income Securities, Caprin encourages all current and prospective clients to evaluate the total costs of any investment program or strategy before making their selection and periodically 16  any of these persons. percentage of Caprin’s management fee charged to the client who was referred by the non-affiliated advisor. In no instance will this fee sharing arrangement increase the fee paid by the client relative to a direct relationship between Caprin and the client. Furthermore, in all such circumstances, the referred client is provided a letter of full disclosure describing the relationship between Caprin and the referring advisor and the form of compensation that exists between them. The client must acknowledge this relationship in writing with his signature for any sharing of management fees or any other form of direct or indirect payment to occur. In addition to reviewing all client accounts, Caprin may provide upon request reports to help clients better understand their investment account and Caprin’s management of it and also to supplement those prepared and distributed by each client’s independent, qualified custodian. Caprin reports generally include a detailed list of positions including market value. Caprin provides reports to direct clients upon request, and Caprin may provide reports for referred or third-party clients upon request of their primary financial advisor. These reports may be distributed in hard copy or electronic form. Caprin currently has no such marketing relationships. When preparing client reports, Caprin relies on third parties, such as third-party quotation services and other custodians when determining the value of account assets. Our Firm does not conduct an in- depth review of valuation information provided by third party quotation services or other custodians, and it does not verify or guarantee the accuracy of such information. The prices obtained by Caprin from the third-party quotation services may differ from prices that could be obtained from other sources. The prices shown on a client’s account statement provided by their custodian may be different from the prices shown on statements and reports provided by Caprin due to the use of different valuation sources by the custodian and Caprin. Davidson Investment Advisors will from time to time pay referral fees to independent third parties and firms (each, a “Promoter,” and collectively, “Promoters”), including Financial Professionals at D.A. Davidson, a related person and broker-dealer, for introducing clients to us. Whenever Davidson pays a referral fee, we require the Promoter to provide the prospective client with a copy of this Brochure and a separate disclosure statement that includes the following information: the Promoter's name and relationship with the Firm; the fact that the Promoter is being paid a referral fee; the amount of the referral fee; the conflict of interest created by the referral fee; and whether the advisory fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. In practice, the Advisory Fees paid to Davidson by clients referred by Promoters are not increased as a result of any referral. OTHER COMPENSATION You are encouraged to compare Caprin’s prepared reports with those provided by your independent, qualified custodian. Caprin reminds its clients that reports generated by their custodian of record are the official statistics from an accounting and tax perspective. Please refer to Item 15 below for additional information about Statements and Reports provided by your custodian. Item 14 Client Referrals and Other Compensation It is Caprin’s policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. CLIENT REFERRALS Item 15 Custody Caprin is authorized only to enter purchase and sale orders and to request the payment of management fees from Caprin managed accounts Caprin may offer referral fees to non-affiliated investment advisors who refer clients to Caprin for fixed income, portfolio management services. In exchange for such referrals, Caprin may compensate the referring advisor with a 17  with its procedures, the security must be removed from the account managed by Caprin. Item 17 Voting Client Securities held at qualified custodians, and for the latter reason, Caprin may be considered to have custody of client accounts; however, Caprin may not open accounts on clients’ behalf and will not serve as trustee of client accounts, nor will Caprin accept the authority to transfer money. Caprin accepts, though not in the traditional sense, authority to vote proxies on behalf of its clients but understands that some clients may prefer to retain such authority. Proxy votes are exceedingly rare with fixed income securities as they pertain primarily to equity investments, and for fixed income securities they are more likely to be in the form of covenant change requests, which Caprin considers analogous to proxy items and for which this procedure exists. As a related person to D.A. Davidson, D.A. Davidson Trust Company, and DADTS, Davidson Investment Advisors, including its Caprin division, are deemed to have indirect custody of some clients’ assets. However, all client assets are held with financial institutions known as qualified custodians who are responsible for maintaining the assets and records of those assets. Caprin shall vote covenant requests for clients except in cases where clients, including ERISA clients, explicitly reserve in writing their right to vote. Accordingly, Caprin has adopted and implemented voting policies and procedures for clients that we believe are reasonably designed to ensure votes are in the best interest of clients. Caprin votes solely with the goal of maximizing the value of clients’ investments. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Caprin encourages you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Caprin statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 Investment Discretion Davidson’s Proxy Manager and/or Chief Compliance Officer reviews all issues. Caprin acknowledges that it may have a conflict of interest in voting on behalf of clients, and, in such circumstances, the Chief Compliance Officer will be sensitive to such issues. Clients may obtain a copy of Caprin’s complete proxy voting policies and procedures upon request, and clients may also obtain information from Caprin about how Caprin voted any proxies on behalf of their account(s) by submitting written notice to the following: Proxy Administrator, Davidson Investment Advisors, 8 Third Street North, Great Falls, MT 59401. Class Actions. Caprin will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Caprin receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold; such authority is described in each Advisory Agreement executed by Caprin clients. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. An investment account will not be opened until Caprin has received a fully executed Investment Advisory agreement and, should an account be funded partially or entirely with currently owned securities, has completed an Initial Position Review to determine those securities that will be sold and those that may be acceptable relative to Caprin 's strategies and guidelines. Upon completion of an Initial Position Review, Caprin will notify the designated account contact (either the direct client or the referring financial advisor) to review the scope of required security sales. Should a security be identified as a required sale, and Caprin is not able to affect a sale in accordance 18  Item 18 Financial Information We are required to disclose any financial condition that is likely to impair our ability to meet our contractual obligations. Davidson Investment Advisors, Inc., including its Caprin Asset Management division, has no additional financial circumstances to report. Davidson Investment Advisors, Inc., including the Caprin Asset Management division, has not been the subject of a bankruptcy petition at any time during the past ten years. Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. 19 

Part 2A of Form ADV: Firm Brochure 8 Third Street North Great Falls, MT 59401 800-332-0529 www.davidsoninvestmentadvisors.com December 15, 2025 This firm brochure provides information about the qualifications and business practices of Davidson Investment Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 800-332-0529 or DavidsonInvMarketing@dadco.com. 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. Registration as an investment adviser with the Securities and Exchange Commission does not imply any specific level of skill or training. Additional information about Davidson Investment Advisors, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 Material Changes This Firm Brochure (“Brochure”) for Davidson Investment Advisors, is our disclosure document prepared according to the SEC’s requirements and rules. This Brochure dated December 15, 2025, contains no material changes from the last annual update, the December 20, 2024 Brochure. 2  Item 3 Table of Contents Item 2 Material Changes .........................................................................................................................................2 Item 3 Table of Contents ........................................................................................................................................3 Item 4 Advisory Business ........................................................................................................................................4 TYPES OF ADVISORY SERVICES .............................................................................................................................4 ASSETS UNDER MANAGEMENT ............................................................................................................................7 SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE ..............................................................................7 Item 5 Fees and Compensation ........................................................................................................................... 10 DESCRIPTION ..................................................................................................................................................... 10 ADDITIONAL FEE INFORMATION ....................................................................................................................... 11 Item 6 Performance-Based Fees and Side-By-Side Management ....................................................................... 13 Item 7 Types of Clients ........................................................................................................................................ 13 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................................. 13 METHODS OF ANALYSIS ..................................................................................................................................... 13 INVESTMENT STRATEGIES ................................................................................................................................. 14 RISK OF LOSS ...................................................................................................................................................... 15 Item 9 Disciplinary Information ........................................................................................................................... 18 Item 10 Other Financial Industry Activities and Affiliations ................................................................................ 18 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................... 19 CODE OF ETHICS ................................................................................................................................................ 19 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ................................................................................. 19 D.A. DAVIDSON PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ....................................................... 19 Item 12 Brokerage Practices ................................................................................................................................ 20 Item 13 Review of Accounts ................................................................................................................................ 21 Item 14 Client Referrals and Other Compensation ............................................................................................. 22 CLIENT REFERRALS ............................................................................................................................................. 22 OTHER COMPENSATION .................................................................................................................................... 22 Item 15 Custody ................................................................................................................................................... 23 Item 16 Investment Discretion ............................................................................................................................ 23 Item 17 Voting Client Securities .......................................................................................................................... 24 Item 18 Financial Information ............................................................................................................................. 25 3  Item 4 Advisory Business Davidson Investment Advisors, Inc. ("Davidson Investment Advisors", “Davidson”, or “the Firm”) is a Securities and Exchange Commission (“SEC”)-registered investment adviser. Davidson Investment Advisors is wholly owned by D.A. Davidson Companies, a financial services holding company. Davidson Investment Advisors has been conducting business since 1975 with its headquarters in Great Falls, Montana. The purpose of this Firm Brochure (“Brochure”) is to describe and disclose the services, fees, potential conflicts of interest, and other information clients should consider regarding the advisory services offered by the Firm. The information contained herein is current as of the date of this Brochure and is subject to change at Davidson’s discretion. Please retain this Brochure for your records. Caprin Asset Management (“Caprin”) operates as a division of Davidson Investment Advisors. Caprin offers fixed income portfolio management services for both institutional and individual clients. For information about Caprin’s services, please see Caprin’s Form ADV Part 2A Firm Brochure, which can be found at www.dadavidson.com/Disclosures. TYPES OF ADVISORY SERVICES The Firm offers professional portfolio management to individuals and institutions desiring investments in equity, fixed income, and multi-asset products. The advisory services offered by Davidson generally include portfolio management related account services. These advisory services are offered through the following types of programs: • A direct relationship with Davidson Investment Advisors, with full investment and trading discretion. • A subadvisor to other investment advisers or broker-dealers, with full investment and trading discretion. This includes participation in wrap fee programs sponsored and administrated by D.A. Davidson & Co. (a related person and broker-dealer subsidiary of D.A. Davidson Companies) and unaffiliated parties (the “Sponsors”). • A model provider to other investment advisers or broker-dealers for equity strategies. As a model portfolio provider, Davidson Investment Advisors monitors and updates the model portfolios; the investment advisers or broker-dealers are then responsible implementing the model portfolios for their clients and adjusting the model portfolio as recommended by the Firm. Davidson Investment Advisors does not have any trading authority over the third-party investment adviser’s clients’ assets invested in such model portfolios. • Investment adviser to the Davidson Multi-Cap Equity Fund (the “Fund”), which is a fund of the Adviser Series Trust ("Trust"). The Trust is registered under the Investment Company Act of 1940 as an open- end management investment company with multiple series. U.S. Bank Global Fund Services acts as the Fund's administrator and provides accounting and transfer agency services. In addition, Davidson Investment Advisors offers discretionary and non-discretionary advisory services to direct clients via our own sponsored Wrap Fee Program. In this Wrap Fee Program, the Firm acts as your investment adviser. Brokerage and custody services (such as trade execution and account custody) are provided by our affiliated broker-dealer, D.A. Davidson & Co. (also referred to as “D.A. Davidson”), which serves as both broker and custodian, or by D.A. Davidson Trust Services, Inc. (also referred to as “DADTS”) acting solely as custodian. 4  These services are covered by a single “wrap fee.” Conversely, in a non-wrap fee program, Davidson acts as your investment adviser and brokerage services (such as trade execution and custody services) are negotiated by you with the account custodian and paid separately. For a complete description of Davidson Investment Advisors Wrap Fee Program, clients should refer to the Firm’s Form ADV Part 2A Appendix 1: Wrap Fee Program Brochure. To receive a copy of this wrap brochure, contact us at 800-332-0529 or DavidsonInvMarketing@dadco.com, or visit our website at www.dadavidson.com/Disclosures. Davidson offers four primary investment strategies: Equity Income, Multi-Cap Equity, Intermediate Taxable Fixed Income, and Intermediate Municipal Fixed Income. The Firm provides advisory services for all programs, and portfolios with the same investment strategy are constructed and managed similarly. Portfolio Construction and Composition. Davidson Investment Advisors can use a variety of investments, including stocks, bonds, mutual funds, and ETFs, among others, to build a portfolio of diversified holdings; the Firm will use all or a subset of these investments to construct the client’s portfolio. The Firm can provide diversification through exposure to different asset classes (such as equities, fixed income, and alternative investments). More information on the methods of analysis for investment strategies undertaken in the Discretionary Program is provided in Item 8 below. Monitoring and Rebalancing. Davidson Investment Advisors reviews the portfolios periodically and considers whether, based on market fluctuations and other factors, rebalancing a client’s portfolio is appropriate. Depending on the type, accounts are generally reviewed on a quarterly basis or at least on an annual basis. Once changes are deemed appropriate, they are implemented in the client’s account at the Firm’s discretion without prior notice to the client (including regarding the timing of these changes). Reasonable Investment Restrictions. Subject to the agreement with Davidson Investment Advisors, the Firm may implement reasonable restrictions on the securities or types of securities held in the client’s account upon request, including directing Davidson Investment Advisors to not purchase or liquidate certain securities in their account. Each request for an account restriction must be communicated in writing to Davidson Investment Advisors and will be considered in accordance with the Firm’s policies and procedures and must be approved by Davidson Investment Advisors in its sole discretion. This option, however, is not intended to permit a client to direct the purchase of certain securities or types of securities in their account. If the request for restrictions is deemed reasonable by Davidson Investment Advisors, the Firm will select replacement securities as appropriate. Note that restrictions placed on an account may positively or negatively affect account performance and may cause the account to perform differently (including worse) than a like account with no restrictions. Restrictions cannot be placed on securities issued by pooled investment vehicles held in a client’s account (e.g., mutual funds, exchange traded funds, etc.). Tax Overlay Service. For taxable accounts that select Davidson Investment Advisors’ Tax Overlay service, the Firm will seek to harvest the tax losses in a client’s account to the extent consistent with the selected investment strategy. The Firm will strategically sell relevant securities in your account with unrealized losses. When Davidson Investment Advisors sells this security, it may enable the client to offset taxes on both capital gains and a limited amount of ordinary income. When implementing the Tax Overlay service, Davidson Investment Advisors will harvest tax losses with respect to securities it has recommended, and not necessarily based on other positions in the client’s account. The Firm will review the positions in the client’s account for 5  tax losses on a quarterly basis; the Firm may change this frequency from time to time without notice. Davidson Investment Advisors’ goal is not to maximize overall losses either in the client’s account or across all of a client’s accounts (managed by the Firm or elsewhere), as the Firm will not necessarily sell all securities with unrealized losses in a particular client account and will also not necessarily sell securities with the greatest aggregate losses in a particular client account. Davidson Investment Advisors will only sell those securities with unrealized losses that it determines are appropriate to be sold at the time. Proceeds from positions sold to harvest losses will be held in cash or an ETF until “wash sale” windows expire. Client-Directed Tax Harvesting. For taxable accounts, Davidson Investment Advisors will also accept instructions to harvest a specific amount of tax losses or gains, subject to such limitations and procedures as the Firm may establish from time to time. Instructions to harvest tax losses must be provided in writing in the manner prescribed by the Firm. Davidson Investment Advisors will reasonably attempt to fulfill these instructions but may determine that a request is not feasible for a variety of reasons, including but not limited to, the size of the request. Any proceeds from such tax loss sales will be held in cash and will not be reinvested in substitute securities, unless otherwise instructed, which may affect the performance of the account. Tax-Aware Transition Service. For new accounts coming under Davidson Investment Advisors’ management, the Firm offers a Tax-Aware Transition service, whereby Davidson Investment Advisors facilitates tax-optimal transitions of legacy security positions into target investment strategies. This service includes discretionary implementation of trades to maintain with reasonable precision the specified asset allocation of the selected investment strategy, while realizing capital gains associated with legacy positions over multiple (generally 2-3) tax years. Additional Information Regarding Tax-Related Services. If clients and/or their spouse have other taxable or non-taxable accounts, and the client holds in those accounts any of the securities held in your Davidson Investment Advisors managed account, clients should not buy any security sold at a loss for a period of at least 30 days before or after the Firm sells those same securities as part of a tax-related service offered by the Firm to avoid the possible application of the “wash sale” rules. Clients are responsible for monitoring their (and their spouse’s) accounts both under and outside of Davidson Investment Advisors’ management to ensure that transactions in the same security or a substantially similar security as the one traded in the client’s account managed by the Firm do not create a wash sale. A wash sale is the sale at a loss and purchase of the same security or substantially similar security within 30 days of each other. If a wash sale transaction occurs, the IRS may disallow or defer the claimed loss for tax reporting purposes. More specifically, the wash sale period for any sale at a loss consists of 61 calendar days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. The wash sale rule has the effect of disallowing or postponing losses on a sale if a replacement security is bought within these time periods. If a client has multiple household accounts under Davidson Investment Advisors’ management, the Firm will not monitor other household accounts, nor will it monitor any accounts for members of a client’s household maintained outside the Firm’s management, to ensure that transactions in the same security or a substantially similar security do not create a wash sale. For more information on the wash sale rule, please read IRS Publication 550. Whether Davidson Investment Advisors’ tax-related services are effective in reducing a client’s overall tax liability will depend on the client’s entire tax and investment profile, including purchases and dispositions in the 6  client’s (or their spouse’s) accounts outside of Davidson Investment Advisors’ management, the nature of the client’s investments (e.g., taxable or nontaxable) and their respective holding period (e.g., short-term or long- term). Davidson Investment Advisors will monitor only the account(s) opting into the tax-related service to determine if there are unrealized losses for purposes of determining whether to harvest losses. Transactions in any account other than a client’s account, any accounts outside of the Firm’s management, or even additional Davidson Investment Advisors-managed accounts may affect whether a loss is successfully harvested. Moreover, in determining whether and how to harvest tax losses, the Firm relies on various assumptions about the tax posture of a typical investor, which assumptions may or may not correspond with the client’s actual circumstances. Davidson Investment Advisors does not employ tax professionals and has not and will not provide tax advice to clients. No employee of Davidson Investment Advisors is qualified or permitted to provide tax advice. Clients should consult a tax professional for specific tax advice and specifically regarding the tax consequences of investing with Davidson Investment Advisors and engaging in tax-related services based on their particular circumstances. No feature of, interaction with, description of, or action taken in accordance with the Firm’s management, including tax-related services, represents a tax strategy in the context of a client’s individual tax situation and should not replace or supplement the advice of a personal tax advisor. Davidson Investment Advisors is not responsible for ensuring that clients accurately report the trading activity in their account to the IRS or any other relevant taxing authority. The Firm is not responsible to clients for the tax consequences of any transaction in a managed account. Davidson Investment Advisors makes no warranties or guarantees that the tax consequences described herein or in any materials provided to clients in respect to your managed account will be achieved. The Firm also makes no warranty or guarantee that the IRS or other relevant taxing authorities will not challenge the tax consequences of its trades, nor that any such challenge will not be successful. If the IRS is successful in its claim that one or more transactions executed pursuant to the Program were wash sale transactions, any loss recognized on such transactions may be deferred or disallowed, and clients may be subject to the imposition of interest and penalties on such transactions. ASSETS UNDER MANAGEMENT As of September 30, 2025, Davidson Investment Advisors, including its Caprin division, managed approximately $5.1 billion in assets on a discretionary basis and $38 million on a non-discretionary basis. Additionally, the Firm provides several investment strategies via a model-based solution to other investment advisers. As of September 30, 2025, Davidson Investment Advisors, including its Caprin division, serviced approximately $1.6 billion in model-based assets, which is not included on the Firm's ADV Part 1. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE Advisers Act Fiduciary Duty. As a registered investment adviser, Davidson Investment Advisors is subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means that the Firm is required to act in the client’s best interest when providing investment advice and managing client accounts. The duty of care requires, among other things, for Davidson to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information and other circumstances (collectively, client’s “Investment Profile”) or mandate. The duty of loyalty requires the Firm to eliminate or mitigate material conflicts of interest with 7  clients, and to provide full and fair disclosure of such conflicts of interest. The duty also requires Davidson Investment Advisors to provide ongoing monitoring of clients’ accounts and its recommendations in advisory accounts. Special Rules for Retirement Accounts. For retirement and other qualified accounts, including employer- sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, Coverdell educational savings accounts, and other similar accounts (collectively, “retirement accounts”) DIA is a “fiduciary” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when providing investment advice or managing a client’s account. ERISA and the Code limit the types of products and services Davidson Investment Advisors can offer and provide with respect to retirement accounts. When making recommendations that clients open, rollover or transfer retirement account assets to an advisory account or change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020-02, which allows Davidson Investment Advisors to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires Davidson Investment Advisors to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under PTE 2020-02, Davidson Investment Advisors and its financial professionals must also: • Meet a professional standard of care (give prudent advice); • Not put the Firm’s financial interests ahead of client’s (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that the Firm and its financial professionals give advice that is in client’s best interest; • Charge no more than is reasonable for the Firm’s services; and • Give the client basic information about conflicts of interest. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendation (“Covered Recommendation”), as may be applicable: • Roll Out Recommendation. From time to time, the Firm in coordination with a centralized review team, will provide a written recommendation that client roll out assets from a plan to an IRA. The above acknowledgement does not apply to other suggestions, recommendations, and services the Firm and its financial professionals provide and that are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. Davidson Investment Advisors refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an 8  individualized/personalized suggestion for a client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as a Covered Recommendation under this disclosure, including, but not limited to: • General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; • General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm; • General Information and Education about rollovers from a 529 account to a Roth IRA; • Transfers of retirement account assets held at a financial service company other than the Firm (including directly with an investment product sponsor); • Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts); • Transactions clients enter into without a recommendation from Davidson Investment Advisors or that are contrary to, or inconsistent with, their recommendation; • Ongoing recommendations of securities or other transactions or discretionary investment advice, except as otherwise agreed to in writing in any applicable agreements or disclosures; • Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company; and • Recommendations that are not fiduciary “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account). The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020-02 does not require that Davidson Investment Advisors guarantee the performance of any investment or that a client’s investment objectives will be achieved. In addition, Davidson Investment Advisors and its financial professionals may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to a client. There may be times when Davidson Investment Advisors is legally prohibited from making a recommendation that may be otherwise considered to be in a client’s best interest, such as due to insider trading. A client understands any recommendations Davidson Investment Advisors, or its financial professionals make will reflect the information client provides to the Firm about their investment objectives, risk level, investment time horizon, financial information and other circumstances and Davidson Investment Advisors will not be responsible for any information a client omits or fails to provide, including changes thereto. Davidson Investment Advisors and its financial professionals’ recommendations and advice will also reflect any reasonable limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying Davidson Investment Advisors and their financial professionals if their 9  investment objectives, risk tolerance or financial circumstances change. Davidson Investment Advisors will not be responsible for clients’ decision to invest or transfer their retirement account assets in a manner that is different from, or inconsistent with, Davidson Investment Advisors’ recommendations or other advice and guidance, and clients assume the risk of such decision, nor will Davidson Investment Advisors or its financial professionals be responsible for clients’ delay in implementing a recommendation. Reasonable compensation under the retirement laws has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features and benefits) provided. This standard does not require Davidson Investment Advisors to offer its services at the lowest cost, or for the least compensation, in the marketplace, nor that it offer its services to clients at the same or lower cost or compensation levels than it offers them to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their advisory services than others. By entering into an agreement with Davidson Investment Advisors, clients agree that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If clients decide not to use all or some of the services made available, clients agree the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If clients want to change the services the Firm makes available to them or has any concerns regarding the level of fees their retirement account pays or Davidson Investment Advisors’ compensation, a client should contact their financial professional immediately. Item 5 Fees and Compensation DESCRIPTION A client’s investment management agreement will set forth the actual compensation the client will pay to Davidson Investment Advisors. A client pays the Firm an asset-based fee, which is an ongoing fee based on the market value of the assets in the account (including cash and cash equivalents) on the last day of the preceding quarter. Davidson Investment Advisors does not have one standard annual fee schedule that is applicable across all strategies but has a fee schedule per strategy and account type. Advisory fees are negotiable. If an account is governed by a sub-advisory or wrap program agreement, the Firm’s fees, along with the fees of the program sponsor, and all corresponding rules are the sole responsibility of the program sponsor and are governed by the client agreement with the program sponsor. Below are typical strategy-specific fee schedules applicable to separately managed accounts for which Davidson has trading discretion: Equity Income Strategy: Value of assets 0 - $10m Above $10m Annual Fee 0.50% negotiable Multi-Cap Equity Strategy: Value of assets 0 - $10m Above $10m Annual Fee 0.65% negotiable 10  Intermediate Taxable Fixed Income Strategy: Value of assets 0 - $10m Above $10m Annual Fee 0.35% negotiable Intermediate Municipal Fixed Income Strategy: Value of assets 0 - $10m Above $10m Annual Fee 0.25% negotiable Note: There are exceptions to the above fee construct for a limited number of clients based on legacy relationships and/or supervisory approval. The typical fee schedule for model provider services to other investment advisers or broker-dealers is 0.30% of the market value of assets invested using Davidson Investment Advisors’ models. ADDITIONAL FEE INFORMATION How Fees are charged. Fees are generally charged quarterly, in advance, payable on the first day of each calendar quarter. This quarterly fee is calculated based on the market value of assets in the account (including cash and cash-equivalents) on the last business day of the prior quarter. The value of assets held in the client’s account will be determined in good faith by the Firm to reflect their fair market value. Depending on the terms of an investment management agreement governed by a sub-advisory or wrap program sponsor, some clients may be charged in arrears and/or monthly. The initial billing period begins when an investment management agreement is signed by the client and accepted by Davidson. If this occurs after the start of a monthly or quarterly billing period, the initial or partial quarter fee will be prorated based on the number of days remaining in the billing period. Clients may choose to have fees deducted directly from their account or be invoiced quarterly. Services Covered by the Advisory Fees. The fee includes Davidson's investment management and other administrative services. Service Fees and Expenses NOT Covered by the Advisory Fees. In addition to the advisory fees described above, a client may incur other fees and expenses related to the management and servicing of their account. These other fees and expenses include commissions for account transactions, exchange fees, electronic fund and wire transfer fees, margin interest, transfer taxes, redemption fees imposed by a mutual fund company in relation to trading deemed to be excessive, certain fees in connection with the establishment, administration, or termination of retirement or profit-sharing plans or trust accounting, or other costs or fees imposed under applicable laws or regulations. In addition, in connection with the purchase of certain types of securities (such as securities traded over the counter and fixed income securities), the client will bear the cost of any mark-ups, mark-downs and spreads charged by market-makers and dealers. Investment Fees and Expenses NOT Covered by the Advisory Fees. All advisory fees paid to the Firm for investment advisory services provided are in addition to the fees and expenses clients incur with respect to investments held in the accounts, including for assets invested in bank deposit accounts, money market funds, mutual funds, ETFs, and other pooled investments. These fees and expenses are described in each fund's (or 11  other vehicle’s) prospectus or offering document and will be borne directly or indirectly by their shareholders. These fees can include fund management fees, administrative fees, omnibus and sub-transfer agent fees, other fund expenses, and potentially a 12b-1 Fee or other marketing, shareholder servicing and distribution charges. By investing in these types of securities, a client is essentially paying multiple layers of fees and expenses on the assets invested. When investing in mutual funds, including money market funds, a 12b-1 fee may be assessed, depending on the fund selected. 12b-1 fees are sales charges that are incorporated into the expense ratio of the fund. As a matter of the Firm’s policy, any new purchases of mutual funds must be in an advisory share class that does not impose a 12b-1 Fee, where such a share class is available. Davidson Investment Advisors does not guarantee clients will always be invested in the most favorable share class offered by a mutual fund company or that more favorable share classes will be made available in advisory accounts. In no case does Davidson Investment Advisors receive compensation from mutual fund companies in which client assets are invested. For client accounts custodied at D.A. Davidson or DADTS, in the event the Firm receives a 12b-1 Fee in relation to an existing mutual fund position in an advisory account, the Firm will pass on and rebate the fee to the client. For accounts managed by the Firm that are held at custodians other than D.A. Davidson or DADTS, please refer to the custodian’s 12b-1 rebate practices, as Davidson Investment Advisors is unable to rebate any such 12b-1 fees. Termination of the Advisory Relationship. Either clients or the Firm may terminate an investment management agreement upon ten business day’s written notice to the other. Davidson Investment Advisors may also place restrictions on client’s account (i) automatically upon notification to the Firm of client’s death, or the death of all authorized persons on the account (including trustees), (ii) should a client’s balance fall below the minimum balance due to client-initiated withdrawals, or (iii) if a client fails to update or provide any required documentation. In the event Davidson Investment Advisors or a client terminates an account, any prepaid, unearned fees will be refunded. The number of days remaining in the billing period after the effective date of the termination will be considered in determining the amount of any fee reimbursement due to a client. Purchasing Like Services Outside of an Advisory Relationship. The products and services provided to a client in connection with an advisory account at Davidson Investment Advisors may be separately available to a client outside of the advisory account. Clients are cautioned that, depending on factors such as: the level of fees charged by the executing broker-dealer, the amount of trading activity in the client’s account, the value of the client’s account, the types of securities held in the client’s account, the client’s investment strategy, and the level of service sought by the client, the aggregate cost of the client’s advisory account may be higher than if the client had selected the services separately. In addition, fees charged by Davidson Investment Advisors may be higher or lower than the fee charged by another firm that offers comparable advisory services. A client could also invest in a mutual fund directly or through an unaffiliated broker-dealer without Davidson Investment Advisors’ services. In that case, the client would not receive the ongoing investment advisory services offered by the Firm through its programs, which are intended, among other things, to assist the client in determining which mutual funds or other securities are most appropriate in considering the client's financial condition and objectives. Moreover, the mutual fund purchased directly by the client may also impose an initial or deferred sales charge. Taking such information into consideration, each client should carefully review and evaluate their investment objectives and risk tolerance, the investment advisory services provided by Davidson 12  Investment Advisors and other firms, and the costs and expenses charged by such firms, before determining whether to open an advisory account and participate in a Program. Additional General Fee Information. Davidson Investment Advisors may modify a client’s existing fees and/or add additional fees or charges by providing the client thirty (30) days prior written notice. Different fee schedules have been in effect over time, which may have reflected fees that are higher or lower than those currently stated. Davidson, at its discretion, may group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members of associated persons of our Firm. Item 6 Performance-Based Fees and Side-By-Side Management Davidson Investment Advisors, Inc. does not charge performance-based fees (i.e. fees based on a share of capital gains or capital appreciation of the client’s assets) resulting from the Firm’s advisory services. Item 7 Types of Clients Davidson Investment Advisors offers its services to all types of current or prospective clients, including, but not limited to: individuals; banks or thrift institutions; ERISA and non-ERISA retirement plans; trusts; estates; charitable organizations; corporations or other business entities; and registered investment companies. Minimum Account Requirements. A minimum of $100,000 of assets under management is generally required to participate in the Firm’s equity strategies. A minimum of $250,000 of assets under management is generally required to participate in the Firm’s fixed income strategies. A minimum of $50,000 of assets is required to participate in the Discretionary Program’s multi-asset portfolio solutions. These account minimums may be higher or lower under certain circumstances and depending on the portfolio selected as well as program sponsor. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS The Investment Team process leverages one team, with shared responsibility for investment strategy construction, changes to investment strategies, timing, and parameters for implementation, and monitoring and rebalancing the strategies. They conduct due diligence building investment strategies based on an evaluation of the capital markets, current and projected macroeconomic and other conditions and performance of investments over time. Davidson Investment Advisors utilizes three primary methods of analysis for its investment strategies: Fundamental Analysis. Davidson Investment Advisors attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the issuer itself) to determine if the security is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. 13  Quantitative Analysis. Quantitative analysis uses complex mathematical models and statistics to analyze past events to make investment decisions about security performance (or larger market movements) in the future. Qualitative Analysis. Qualitative analysis involves the analysis of unquantifiable information, such as management decisions, to evaluate investment opportunities in the company’s securities. INVESTMENT STRATEGIES Davidson Investment Advisors offers the following core investment strategies: Equity Income Strategy. The Equity Income strategy invests in U.S.-traded equities and ETFs, and its primary investment objectives are capital appreciation and income generation. The strategy is actively managed and invests in high-quality companies with solid balance sheets, ample cash flow and a strong competitive position generating attractive return on capital. Key to the investment strategy is our focus on Dividend Power -- looking beyond current dividend yield to include a company's future capacity for dividends. Using a multivariate appraisal process, we assess value across three dimensions (Asset Value, Dividend Power, and Growth Value) to uncover quality companies underappreciated by the broader market. Multi-Cap Equity Strategy. The Multi-Cap Equity strategy invests in U.S.-traded equities and ETFs, and its primary investment objective is capital appreciation. The strategy is actively managed and unconstrained by market capitalization and style classifications. As fundamental investors, we are cognizant of cyclical and secular dynamics, and focus on profitable companies with attractive return on capital, cash flow and growth prospects. We take active industry positions, with relative position sizes commensurate with risk. Our holdings are diversified by economic sector and adjusted based on where we view the greatest market opportunities. Intermediate Taxable Fixed Income Strategy. The Intermediate Taxable Fixed Income strategy’s primary investment objectives are capital preservation and income generation. The strategy invests in a variety of securities, including U.S. Treasury bonds, corporate bonds, government agency bonds, mortgage-backed securities, and ETFs. The strategy is actively managed and focuses on the intermediate portion of the yield curve. We invest in investment grade or higher issues with maturities ranging from one to ten years. We perform fundamental credit analysis and monitor issuers and credit trends daily. We believe that fixed income assets are best managed actively with respect to duration and credit exposures, as we monitor, anticipate, and respond to changes in the broad economy and the interest rate environment. Intermediate Municipal Fixed Income Strategy. The Intermediate Municipal Fixed Income strategy’s primary investment objectives are capital preservation and tax-exempt income generation. The strategy invests in general obligation and revenue bonds of various municipalities across the U.S., as well as ETFs. The strategy is actively managed and focuses on the intermediate portion of the yield curve, purchasing investment-grade issues with maturities ranging from one to fifteen years. Emphasis is placed on purchasing issues with predictable income and principal stability, while managers also remain aware of resiliency to credit stress, changing interest rates, and market volatility. Given the tax-sensitive nature of the asset class, attention is also paid to the management of portfolio turnover and the opportunity to realize gains or losses as advantageous for clients, as well as Alternative Minimum Tax and state tax considerations. Davidson Investment Advisors also offers custom and multi-asset portfolio management, which includes, but is not limited to, asset allocation services. We tailor portfolios to client specifications regarding exposure to various asset classes (including, but not limited to, equities, fixed income securities, international securities, 14  alternative investments, and private equity), as well as desired portfolio characteristics (such as quality parameters or cash flow projections). Such specifications may be outlined in an institutional client’s Investment Policy Statement (IPS), a document that aligns the objectives of an organization with its financial goals to ensure financial assets support organizational objectives. For all investment strategies, securities selected for inclusion in client portfolios are monitored using Bloomberg and other available data. Davidson Investment Advisors focuses on long-term investing; ultimately, a portfolio position may be sold once the security has become fully priced by the market, a more favorable investment alternative becomes available, the fundamentals of the issuer deteriorate, or catalysts for growth identified in the due diligence process fail to develop. RISK OF LOSS Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. The following provides information on specific types of investment risks depending on the type of underlying investments. Risks for all forms of analysis. Securities analysis methods rely on the assumption that the entities whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis becomes compromised by inaccurate or misleading information. Investing in any security involves risk of loss that clients should be prepared to bear. Fundamental Analysis Risk. This method of analysis presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. Quantitative Analysis Risk. A risk in using quantitative analysis is that the models used are based on assumptions that may prove to be incorrect. Qualitative Analysis Risk. A risk of using qualitative analysis is that our subjective judgment proves to be incorrect. Technical Analysis. Technical analysis involves the use of statistical data, and trends in that data, to identify trading opportunities. Technical analysis does not consider the underlying financial condition of a company, or the intrinsic value of its securities. This type of analysis presents a risk in that a poorly managed or financially unsound company may underperform regardless of larger movements in the market. Cyclical Analysis. This form of technical analysis involves studying cycles in the economy and financial markets. In this type of technical analysis, the movements of a particular stock are measured relative to the overall market in an attempt to predict the price movement of the security. The risk most commonly associated with this analysis is that the overall measurement is incorrect. Asset Allocation. A risk of an incorrect asset allocation decision is that the client does not participate in a sharp increase in a particular security, industry, or market sector. Another risk is that the ratio of equities, fixed income, and cash holdings will change over time due to security value and market movements and, if not corrected (i.e., through rebalancing), will no longer be appropriate for the client’s goals. 15  Mutual Fund and/or ETF Analysis. A common risk of mutual funds and/or ETF analysis is that, as with other securities investments, past performance does not guarantee future results. A manager who has been successful in identifying profitable opportunities among mutual funds may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a mutual fund or ETF, managers of different funds held by the client may purchase the same security, creating concentrated exposure for the client to that security and increasing the risk to the client if that security were to fall in value. There is also a risk of a manager deviating from the stated investment mandate or strategy of the mutual fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Interest Rate Risk. Fluctuations in interest rates cause investment prices to fluctuate. For example, bond market values have an inverse relationship to changes in interest rates. Rising interest rates cause bond market values to decline and declining interest rates cause market values to rise. Generally, the longer a bond’s maturity, the greater the interest rate risk and the higher its yield. Similarly, equities may also suffer from rising interest rates. Market Risk. Market risk is the risk of investment losses in a client’s account due to a variety of reasons outside of Davidson Investment Advisors’ control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, epidemic, pandemic, or social events, independent of the intrinsic valuation of one or more securities in the client’s account. Inflation Risk. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Inflation risk is the risk of inflation exceeding or eroding the return of an investment in the client’s account. Currency Risk. Among other risks, investments in non-U.S. securities are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Currency risk could lead to a loss to a client, for example, when the proceeds from the sale of the non-U.S. security, which may be in a devaluing foreign currency, are converted to a relatively stronger U.S. dollar. Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at a potentially lower rate of return (i.e., due to reductions in interest rates). This relates primarily to client account investments in fixed income securities. Business Risk. These risks are associated with a particular industry or company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of potential profitability than an electric company, which generates its income from a steady stream of customers who buy electricity of the prevailing economic environment. Liquidity Risk. Liquidity is the ability to readily convert a security into cash. Securities in a client’s account are more liquid if many individuals are interested in buying or selling them. For example, Treasury bills are highly liquid, while real estate properties are relatively illiquid. Liquidity risk is therefore the risk that a client will not be able to promptly sell a security due to a limited market for that instrument. Financial Risk. Excessive borrowing to finance a business’ operations may create a degree of stress on the firm to the point of jeopardizing its profitability, and potentially triggering a default on one or more outstanding loans. Depending on the circumstances, such a development could lead to a declining value in the company’s 16  securities, or even its bankruptcy. Global Economic Risk. National and regional economies and financial markets are becoming increasingly interconnected, which increases the possibility that conditions in one country, region or market might adversely impact issuers in a different country, region, or market. Changes in legal, political, regulatory, tax and economic conditions may cause fluctuations in markets and securities prices around the world, which could negatively impact the value of an account’s investments. Major economic or political disruptions, particularly in large economies, may have negative global economic and market repercussions. Additionally, events such as war, terrorism, natural and environmental disasters and the spread of infectious illnesses or other public health emergencies may adversely affect the global economy and the markets and issuers in which an account invests. These events could reduce consumer demand or economic output, result in market closure, travel restrictions or quarantines, and have a significant impact on the economy. Such events could materially increase risks, including market and liquidity risk, and significantly reduce account values. Cybersecurity Risk. Client portfolios are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events that include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cyber security failures or breaches by a third-party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially result in in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Technology Risk. The Firm’s investment offerings are dependent upon various computer and telecommunication technologies, many of which are provided by or are dependent on third parties. The successful operation of our Firm could be severely compromised by system or component failure, telecommunication failure, power loss, a software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damage, human errors in using or accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunication systems or operations could have a material adverse effect on the Firm. Such a material effect may have a heightened impact on the investment strategies, given the automated nature of the services provided. Concentration Risk. This is the risk that a client’s portfolio is heavily allocated in one or few securities, industries, sectors, or geographic locations. This increases the impact of negative or positive performance compared to a portfolio which is diversified. Specific Security Risks. In addition to the above risks, each security type used has certain characteristics and is subject to a risk of loss that clients should be prepared to bear. For more information about risks associated with stocks, fixed income securities, mutual funds, and ETFs should speak with a financial professional. For risks associated with mutual funds and ETFs in a client’s account, see the fund’s current prospectus. 17  Item 9 Disciplinary Information Davidson Investment Advisors does not have any events that are material to a client’s or prospective client’s evaluation of its advisory business the integrity of its management, including any legal, financial, or disciplinary events that require disclosure. Item 10 Other Financial Industry Activities and Affiliations Davidson is a wholly-owned subsidiary of D.A. Davidson Companies, a financial services holding company with other subsidiaries: D.A. Davidson & Co. (“D.A. Davidson”), D.A. Davidson Trust Company (“Davidson Trust Company” or “Davidson Trust”), and D.A. Davidson Trust Services, Inc. (“DADTS”). D.A. Davidson. D.A. Davidson is dually registered as a broker-dealer with FINRA (Financial Industry Regulatory Authority) and a registered investment adviser with the SEC and is also a qualified custodian. D.A. Davidson Financial Professionals may refer clients to Davidson Investment Advisors in its capacities as independent investment adviser participating in D.A. Davidson’s advisory programs as described in the D.A. Davidson 2A Wrap Fee Brochure. D.A. Davidson Financial Professionals have an incentive to recommend a Program or an investment manager that is affiliated with D.A. Davidson because the entire client fee is retained by D.A. Davidson Companies. Often the D.A. Davidson Financial Professional remains the client’s financial advisor for the Davidson Investment Advisors wrap fee account and is compensated for the referral on an ongoing basis. Many D.A. Davidson Financial Professionals are also registered representatives of D.A. Davidson in its capacity as a broker-dealer. When acting as a broker-dealer, these financial professionals provide brokerage and related services to clients, including in relation to the purchase and sale of individual stocks, bonds, mutual funds, private investment funds, life insurance policies and annuities, and other products. These broker-dealer recommendations and any subsequent implementation are separate and distinct from the Firm’s advisory services. See the D.A. Davidson Regulation Best Interest Disclosure at www.dadavidson.com/Disclosures for more information about D.A. Davidson’s Brokerage Services. Davidson Trust Company. Davidson Trust Company is a federal savings bank. Davidson Trust may elect to hire Davidson Investment Advisors as the investment adviser for certain client accounts over which Davidson Trust has investment discretion. Davidson Trust shares a portion of its investment management fee with Davidson Investment Advisors for providing investment advisory services. Davidson Investment Advisors also manages four Davidson Trust Company common trust funds. D.A. Davidson Trust Services, Inc. DADTS is a non-depository trust company chartered in New Hampshire which acts as the custodian for D.A. Davidson client assets maintained in IRA and 403(b) accounts. D.A. Davidson provides DADTS with supporting administrative, recordkeeping and reporting services as the client’s broker-dealer. Note Regarding D.A. Davidson Companies Conflicts of Interest. Fee sharing agreements amongst Davidson, D.A. Davidson, Davidson Trust Company, and DADTS create a conflict of interest because the fees for managing and trading client accounts are all retained by D.A. Davidson Companies. Davidson may recommend clients use D.A. Davidson, Davidson Trust Company, or DADTS, related parties, for custody and safekeeping purposes. The client also retains the right to direct Davidson to use another broker. If 18  a client elects to use D.A. Davidson, D.A. Davidson Trust Company or DADTS, the client may terminate the arrangement at any time. See additional information in regard to Directed Brokerage under Item 12 – Brokerage Practices. Davidson Funds. Davidson previously disclosed in "Advisory Business" (Item 4) of this Brochure that it is the investment adviser to the Davidson Multi-Cap Equity Fund, a fund of the Adviser Series Trust, an investment company registered under the Investment Company Act of 1940. Please refer to these items for a detailed explanation of this relationship and important conflict of interest disclosures. For additional information, the Fund’s Prospectus and Statement of Additional Information are available at www.davidsonmutualfunds.com. Prospective investors should review these documents carefully before making any investment in the mutual fund. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CODE OF ETHICS Davidson Investment Advisors has adopted a Code of Ethics (“Code”) which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. The Firm’s Code establishes rules of conduct for all employees and is designed to govern personal securities trading activities in the accounts of employees, among other things. The Code is based upon the principle that Davidson Investment Advisors and its employees owe a fiduciary duty to its 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. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by calling us at 800-332-0529. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS As a general practice, Davidson Investment Advisors does not engage in principal transactions. The Firm’s employees are allowed to invest in the same securities recommended to or owned by clients. However, in order to avoid conflicts of interest, all Davidson Investment Advisors employees are required to receive prior approval to trade in personal security accounts. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. D.A. DAVIDSON PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS As previously noted, Davidson Investment Advisors may recommend D.A. Davidson, a related party and broker- dealer, as the qualified custodian or DADTS as qualified custodian for many Davidson Investment Advisor clients. Subject to the requirements of applicable law, D.A. Davidson may act as principal, buying securities for itself from, or selling securities it owns to, an advisory client, but only on a case-by-case basis with advance 19  written authorization from the client, and when it is in the best interest of a client to do so. D.A. Davidson’s policy generally prohibits agency cross transactions for advisory clients, but in rare cases exceptions may be granted. An agency cross transaction is a transaction in which D.A. Davidson acts as broker for the party or parties on both sides of the transaction. However, no cross transactions may be made in ERISA- covered or IRA advisory accounts. For additional information regarding D.A. Davidson’s principal trading and agency cross transaction policies, please refer to D.A. Davidson’s Wrap Fee Program Brochure. You may also request a copy by calling us at 800-332-0529. Item 12 Brokerage Practices For clients, Davidson Investment Advisors will determine: (1) which securities are bought and sold; (2) the total amount of such purchases and sales and whether a client's transaction should be aggregated with those of other clients; (3) the broker through which transactions will be executed (with the exception of directed brokerage arrangements, as described later in this section); and (4) the commission rates paid to effect the transactions, as negotiated with the executing broker. Such determinations are made in the good faith judgment of the Firm so that such orders will be placed at prices and commissions that will be in the best interest of the account. Best Execution. Davidson Investment Advisors has the obligation to seek best execution when it places trades with broker-dealers. Best execution entails the efficient placement of orders, clearance, settlement and the overall quality of execution as well as the cost of the transaction. Selection of Broker-Dealers. Davidson Investment Advisors considers the full range and quality of the services in selecting or approving broker-dealers to meet best execution obligations which include but are not limited to: ability to provide anonymity; promptness of execution; access to inventory in case of fixed income, or access to multiple centers and alternative networks in case of equities; best available price; competitive bids/offers; adequate backup for the trader; financial stability/business reputation; overall responsiveness, and communication. Soft Dollars. Consistent with obtaining best execution for clients, the Firm maintains trading arrangements with various broker-dealers whereby it has access to its research. Davidson may direct trades to one of those broker-dealers and pay commissions that are competitive but that are higher than the lowest available rate that another broker might have charged, if Davidson determines in good faith that the commissions are reasonable in relation to the value of the brokerage and research services provided. The provision of such services in exchange for brokerage business is commonly referred to as a "soft dollar arrangement." Research services and products may include tangible research products (publications or writings as to the value of securities, analysis and reports concerning issuers, industries, economic factors and trends), as well as direct access to analysts and traders. This creates an incentive to select or recommend a broker- dealer based on the Firm’s interest in receiving research, rather than clients’ interest in receiving most favorable execution. However, Davidson Investment Advisors has a fiduciary duty to act in the best interest of clients and to obtain best execution for its advisory clients. The Firm does not enter into soft dollar arrangements that are not covered by the safe harbor of Section 28(e) of the Securities Exchange Act of 1934. Directed Brokerage. Some clients, when undertaking an advisory relationship, may already have a pre- established relationship with a broker-dealer. Therefore, the client may instruct Davidson to execute all 20  transactions through that broker-dealer. If the client directs Davidson Investment Advisors to use a particular broker-dealer, the client recognizes that Davidson will likely have no authority to negotiate commissions, to obtain volume discounts and best execution may not be achieved. Under these circumstances, there may be a disparity in commissions charged among the Firm’s clients. Order Aggregation. Davidson Investment Advisors will aggregate client trades where possible and when advantageous to clients. This aggregation of trades permits the trading of blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. All participating accounts receive an average share price for trade execution. Directed Brokerage in Wrap Programs. Client accounts managed by Davidson Investment Advisors which originate through a Wrap Program ordinarily are directed brokerage accounts. Sponsors of these programs typically charge the program participants a fee which covers the costs of executing transactions for the participants’ accounts when such transactions are placed by the program sponsor. Trades not placed by the program sponsor are referred to as “step-out” trades and will incur the client additional trading costs. A Wrap Program client should confer with the program’s sponsor and determine that the direction of brokerage provided for under the program is reasonable in view of the benefits received, and that the trade execution provided by the program’s sponsor is in the client’s best interest. Davidson Investment Advisors “steps-out” the majority of its trades, since it believes that “step-out” trades are more likely to provide clients, including Wrap Program clients, with best execution and offer a higher degree of liquidity. Since the Firm will frequently trade away from the program sponsor, Wrap Program clients will incur trading costs that are in addition to the fee they pay to the program sponsor. Trade Rotation. Davidson Investment Advisors employs a trade rotation policy for block trades, by which a rotating, pre-determined order is used to bring clients’ shares to the market. In the event that an aggregated trade takes multiple trading sessions to complete, the overall trade rotation for subsets is adhered to, and allocation of shares is conducted on a random basis using the trade order management system. Trade Errors. As a fiduciary, Davidson has the responsibility to effect orders correctly, promptly and in the best interests of its clients. If an error occurs in the handling of any client transactions or the Fund, due to the Firm’s action, or inaction, or actions of others, the Firm’s policy is to seek to identify and correct errors as promptly as possible without disadvantaging the client or Fund in any way. If the error is the responsibility of Davidson, the transaction will be corrected, and Davidson will be responsible for any client loss resulting from an inaccurate or erroneous order. Item 13 Review of Accounts Reviews. Davidson Investment Advisors monitors the underlying securities within each client’s account. Depending on the type, accounts are generally reviewed on a quarterly basis or at least on an annual basis. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, the market, political or economic environment. These accounts are reviewed by various members of the investment team, client service professionals and 21  portfolio administrators. It is ultimately the client's responsibility to advise the Firm of any changes to the information previously provided that might impact their account. Neither the Firm nor any investment manager is responsible for independently verifying information or data provided by a client, or for any adverse consequence arising out of or in any way connected with the client’s failure to promptly communicate the updated or new information to any of these persons. Reports. For accounts operating under a direct advisory agreement with Davidson Investment Advisors, the Firm provides written reports to clients on the performance of their account(s) on a quarterly basis. Client performance reports typically include a portfolio valuation, the asset allocation, and account performance. Performance returns include the deduction of advisory fees, transaction costs, and market appreciation or depreciation. When preparing a client’s account statements and performance reports, the Firm relies on third parties, such as third-party quotation services and other custodians when determining the value of account assets. Our Firm does not conduct an in-depth review of valuation information provided by third-party quotation services or other custodians, and it does not verify or guarantee the accuracy of such information. The prices obtained by Davidson Investment Advisors from the third-party quotation services it uses may differ from prices that could be obtained from other sources. If a client has assets held by a third-party custodian, the prices shown on a client’s account statement provided by that custodian may be different from the prices shown on statements and reports provided by the Firm due to the use of different valuation sources by the custodian and Davidson Investment Advisors. Item 14 Client Referrals and Other Compensation CLIENT REFERRALS Davidson Investment Advisors will from time to time pay referral fees to independent persons or firms, as well as Financial Professionals at D.A. Davidson a related person and broker-dealer, ("Promoters") for introducing clients to us. Whenever the Firm pays a referral fee, we require the Promoter to provide the prospective client with a copy of this Brochure and a separate disclosure statement that includes: the Promoter's name and relationship with the Firm; the fact that the Promoter is being paid a referral fee; the amount of the fee; and whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. As a matter of firm practice, the advisory fees charged to clients referred by Promoters or related parties are not increased as a result of any referral. OTHER COMPENSATION It is Davidson Investment Advisors’ policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Cash Management Program. As mentioned in Item 10 – Other Financial Industry Activities and Affiliations, the Firm may recommend that clients custody assets at D.A. Davidson or DADTS, related custodians. Your Davidson Investment Advisors account typically includes an allocation to cash. If D.A. Davidson or DADTS is selected as 22  the custodian for your account, a Cash Management Program will be utilized, commonly referred to as a “sweep” program, to automatically deposit uninvested cash balances into an interest-bearing account maintained at one or more participating third-party banks (or in limited circumstances to an unaffiliated money market fund) at the end of each business day. Uninvested cash may occur due to, among other things, the sale of securities, dividend payments, interest credited from bonds, and short-term allocations to cash in the account portfolio. Clients affirmatively consent to participation in D.A. Davidson’s Cash Management Program by expressly electing it in the account application and signing the account agreement but can revoke this consent at any time by contacting their Financial Professional. D.A. Davidson receives important and significant compensation and benefits from client use of the Cash Management Program. Because the advisory fees are generally charged on cash balances and cash balances generate compensation to D.A. Davidson through the cash management program, D.A. Davidson Companies earns two levels of compensation on such cash balances in Davidson Investment Advisors wrap accounts. Please review the Cash Management Program Disclosure Statement available on the D.A. Davidson website at dadavidson.com/Disclosures for more information about how the cash management program works, including limitations, restrictions, how changes are implemented and additional discussion of conflicts of interest. For current interest rates applicable to the cash management program see https://www.dadavidson.com/Individuals/Wealth-Management/Saving-Credit-Lending. Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that when client assets are custodied at our related person, D. A. Davidson or DADTS, as qualified custodians, advisory fees can be directly debited from client accounts. In some instances, a client appoints a separate custodian to maintain client assets in which advisory fees may also be directly debited with written authorization from the client on file. As a related person to D.A. Davidson, Davidson Trust Company, and DADTS, Davidson is deemed to have indirect custody of some clients’ assets. However, all client assets are held with financial institutions known as qualified custodians who are responsible for maintaining the assets and records of those assets. Clients will receive account statements directly from their qualified custodian. That statement is the official record of your account and the assets contained in it. As previously noted under Item 13, Davidson also delivers statements and reports to clients on the performance of their account. We urge you to compare the information contained in the Davidson quarterly account statements and other reports to the information contained in your official statements for the same period. In the event of a discrepancy between an official account statement and other reports or statements for the holdings and transactions shown, the client’s official account statement shall prevail. Item 16 Investment Discretion Davidson Investment Advisors receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold; such authority is described in each Advisory Agreement executed by the Firm’s clients. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. 23  Item 17 Voting Client Securities Davidson Investment Advisors votes proxies for discretionary client accounts. Client may retain the right to vote proxies for their own accounts, or to direct the Firm to vote a proxy in a particular manner, so long as the client timely notifies the Firm. Davidson Investment Advisors has engaged a third-party Proxy Service Vendor to provide proxy voting administrative duties and proxy voting recommendations from another third-party Proxy Advisory Form (“Proxy Advisor”). The Proxy Advisor recommendations are pre-populated into the Proxy Service Vendor’s electronic voting platform, and are automatically executed pursuant to the Proxy Advisor’s recommendations. However, the Firm reserves the right to exercise its own judgment on a case-by-case basis, to serve its clients’ best interests once it has determined that such a vote would not involve an identified firm-related conflict of interest. In these situations, Davidson Investment Advisors will generally vote in favor of proxy proposals that enhance the independence of board membership, against measures that promote anti-takeover defenses, and for incentive compensation that would align management interests with shareholder interests, including stock- based compensation and restricted stock award programs. Corporate governance issues, however, are diverse and continually evolving and these general policies may not be relevant in some circumstances. An Investment Adviser Proxy Voting Committee (the “Committee”), with members including senior personnel from Davidson Investment Advisors and other D.A. Davidson Companies’ subsidiaries, meets periodically. The Committee monitors the Firm’s overall adherence to and effectiveness of the Firm’s proxy voting policies and procedures. It reviews the rationale for some proxy votes that are not covered by the policies and procedures, or that present a potential conflict of interest. It also reviews the internal controls and independence of the third-party vendors on no less than an annual basis. The Committee periodically reviews policies and procedures and provides advice for revisions thereof. A summary of Davidson Investment Advisors’ proxy voting policies and procedures can be found on the Internet at www.dadavidson.com/Disclosures or a copy of the policies can be mailed, free of charge, at client's request to the following address: Davidson Investment Advisors, Compliance Department, 8 Third Street North, Great Falls, MT, 59401. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact Davidson Investment Advisors by telephone, email, or in writing. Conflicts of Interest. Davidson Investment Advisors and its supervised persons have various conflicts in relation to voting client proxies, which may include personal investments, outside activities, personal relationships, and management of investment accounts for or on behalf of publicly traded companies. Davidson Investment Advisors believes, however, that its retention of the Proxy Service Vendor, use of the Proxy Advisor Firm recommendations, it’s adherence to its proxy voting policies and procedures and oversight by the Proxy Voting Committee help to ensure proxies are voted in the best interest of the Firm’s clients. Class Action Notices. Davidson Investment Advisors will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies 24  of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 Financial Information We are also required to disclose any financial condition that is likely to impair our ability to meet our contractual obligations. Davidson Investment Advisors, Inc. has no additional financial circumstances to report. Davidson Investment Advisors, Inc. has not been the subject of a bankruptcy petition at any time during the past ten years. Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. 25 

Part 2A Appendix 1 of Form ADV: Wrap Fee Program Brochure 8 Third Street North Great Falls, MT 59401 800-332-0529 www.davidsoninvestmentadvisors.com December 15, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Davidson Investment Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 800-332-0529 or DavidsonInvMarketing@dadco.com. 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. Registration as an investment adviser with the Securities and Exchange Commission does not imply any specific level of skill or training. Additional information about Davidson Investment Advisors, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2 Material Changes This Davidson Investment Advisors ADV Part 2A 1 Wrap Fee Brochure (“Brochure”) is our disclosure document prepared according to the SEC’s requirements and rules. This Brochure dated December 15, 2025, contains no material changes from the last annual update, the December 20, 2024 Brochure. 2  Item 3 Table of Contents Item 2 Material Changes ........................................................................................................................................ 2 Item 3 Table of Contents ......................................................................................................................................... 3 Item 4 Services, Fees and Compensation ............................................................................................................... 4 DISCRETIONARY PROGRAM ................................................................................................................................. 5 NON-DISCRETIONARY PROGRAM ........................................................................................................................ 8 ADDITIONAL PROGRAM INFORMATION ............................................................................................................. 9 SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE ........................................................................... 13 CUSTODY ........................................................................................................................................................... 16 Item 5 Account Requirements and Types of Clients ............................................................................................ 16 MINIMUM ACCOUNT REQUIREMENTS ............................................................................................................. 16 TYPES OF CLIENTS .............................................................................................................................................. 16 Item 6 Portfolio Manager Selection and Evaluation ............................................................................................ 16 CALCULATION AND REVIEW OF PERFORMANCE............................................................................................... 16 PORTFOLIO MANAGEMENT BY RELATED PERSONS .......................................................................................... 17 PERFORMANCE-BASED FEES ............................................................................................................................. 17 METHODS OF ANALYSIS – DISCRETIONARY PROGRAM .................................................................................... 17 INVESTMENT STRATEGIES – DISCRETIONARY PROGRAM ................................................................................. 17 METHODS OF ANALYSIS – NON-DISCRETIONARY PROGRAM ........................................................................... 18 RISK OF LOSS ...................................................................................................................................................... 19 VOTING CLIENT SECURITIES ............................................................................................................................... 21 Item 7 Client Information Provided to Portfolio Managers ................................................................................. 23 Item 8 Client Contact with Portfolio Managers .................................................................................................... 23 Item 9 Additional Information .............................................................................................................................. 23 DISCIPLINARY INFORMATION ............................................................................................................................ 23 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................................................... 23 CODE OF ETHICS AND PERSONAL TRADING ...................................................................................................... 24 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS ................................................................................. 25 GENERAL BROKERAGE PRACTICES ..................................................................................................................... 25 BROKERAGE PRACTICES – DISCRETIONARY PROGRAM..................................................................................... 26 BROKERAGE PRACTICES – NON-DISCRETIONARY PROGRAM............................................................................ 26 REVIEW OF ACCOUNTS ...................................................................................................................................... 27 CLIENT REFERRALS ............................................................................................................................................. 27 OTHER COMPENSATION .................................................................................................................................... 28 FINANCIAL INFORMATION................................................................................................................................. 29 3  Item 4 Services, Fees and Compensation Davidson Investment Advisors, Inc. ("Davidson Investment Advisors" or “the Firm”) is a Securities and Exchange Commission (“SEC”)-registered investment adviser. The Firm is wholly owned by D.A. Davidson Companies, a financial services holding company. Davidson Investment Advisors has been conducting business since 1975 with its headquarters in Great Falls, Montana. Caprin Asset Management (“Caprin”) operates as a division of Davidson Investment Advisors. Caprin offers fixed income portfolio management services for both institutional and individual clients. For information about Caprin’s services, please see Caprin’s Form ADV Part 2A Firm Brochure, which can be found at www.dadavidson.com/Disclosures. The purpose of this Wrap Fee Brochure (“Brochure”) is to describe and disclose the services, fees, potential conflicts of interest, and other information clients should consider regarding the wrap fee programs (“Program” or “Programs”) offered by Davidson Investment Advisors. The term “wrap fee” means Davidson Investment Advisors charges clients a single fee based on the market value of assets in the client’s account for advisory and trade execution services. The wrap fee covers investment advice or counsel provided by Financial Professionals, the execution of client transactions, custody services at D.A. Davidson & Company (“D.A. Davidson”, a related person and broker-dealer subsidiary of D.A. Davidson Companies) or D.A. Davidson Trust Services, Inc. (also referred to as “DADTS”) as custodian, account servicing, monitoring, rebalancing, and performance reporting, in addition to other standard services. Davidson Investment Advisors offers a Discretionary Program account, where a client appoints and authorizes Davidson Investment Advisors to make investment decisions with respect to the assets in a client’s account, including the authority to buy, sell or hold securities and the timing of these actions without notice to the client (the “Discretionary Program”). For clients, or other members of a client’s household, that have a Discretionary Program account, Davidson Investment Advisors offers a Non-Discretionary Program account, where a client appoints the Firm to provide investment advice and recommendations as to the assets in a client’s account, but the client retains full authority over the investment decisions, including the authority to buy, sell or hold securities and the timing of those actions (the “Non-Discretionary Program”). The Firm may offer the Non- Discretionary Program to a client not having a Discretionary Program account on an exception basis to legacy relationships and/or with supervisory approval. The information contained herein is current as of the date of this Brochure and is subject to change at the Firm’s discretion. Please retain this Brochure for your records. Not all Programs and investment strategies are appropriate for each client. Each Program is designed to meet differing investment needs of clients and have different levels of services, administration, structure, fees, and expenses. A Davidson Investment Advisors Financial Professional or D.A. Davidson Financial Professional (each a “Financial Professional”) will work with clients to recommend an investment strategy that is in the client’s best interest based on both the client’s Investment Profile (as defined below) and the client’s other needs and preferences. The Financial Professional will present the investment strategy to the client that identifies the specific investment strategy recommended to the client along with the proposed asset allocation and description of investments to be held in the account. If the client wishes to proceed, the client will enter into a written Advisory Agreement, which contains specific terms applicable to the client’s advisory relationship with Davidson Investment Advisors (including custody, brokerage, and administrative services). In addition, the client will receive a written confirmation (called a “Written Confirmation of Instruction”) upon the opening of 4  their investment advisory account(s), which outlines the selected Program, fee schedule and other account information. The ultimate decision regarding the investment strategy selected is that of the client. Discretionary management begins once the client is invested in the agreed upon investment strategy. If the client informs the Firm of any material changes to the information in their Investment Profile, the Financial Professional will evaluate the updated information and make changes or recommendations as appropriate to help ensure the investment strategy is in line with the client’s investment profile and their needs and preferences. The Financial Professional is also responsible for annually contacting the client to assess whether there are any updates to the client’s information that would impact their selected investment strategy. The client is responsible for promptly communicating any material changes to their Investment Profile to the Firm. Other Advisory Services. In addition to the Programs described in this Brochure, Davidson Investment Advisors also offers the following advisory services: • Subadvisor to other investment advisers or broker-dealers, with full investment and trading discretion. This includes participation in wrap fee programs sponsored and administrated by D.A. Davidson (a related person and broker-dealer subsidiary of D.A. Davidson Companies) and unaffiliated parties (the “Sponsors”). • Model provider to other investment advisers or broker-dealers for equity strategies. As a model portfolio provider, Davidson Investment Advisors monitors and updates the model portfolios; the investment advisers or broker-dealers are then responsible for implementing the model portfolios for their clients and for adjusting the model portfolio as recommended by Davidson Investment Advisors. The Firm does not have any trading authority over the third-party investment adviser’s clients’ assets invested in such model portfolios. • Investment adviser to the Davidson Multi-Cap Equity Fund (the “Fund”), which is a fund of the Advisors Series Trust ("Trust"). The Trust is registered under the Investment Company Act of 1940 as an open- end management investment company with multiple series. U.S. Bank Global Fund Services acts as the Fund's administrator and provides accounting and transfer agency services. For a complete description of these additional advisory services and fee arrangements offered by our Firm, clients should refer to our Form ADV Part 2A: Firm Brochure. To receive a copy of the firm brochure, contact us at 800-332-0529 or DavidsonInvMarketing@dadco.com, or visit our website at www.dadavidson.com/Disclosures. DISCRETIONARY PROGRAM The Discretionary Program offered by Davidson Investment Advisors includes portfolio management, investment advice, consulting services, performance reporting, and related account services. Davidson Investment Advisors retains all discretion regarding the portfolio construction, changes to the portfolios, timing and parameters for implementation, execution, monitoring and rebalancing. Davidson Investment Advisors offers four primary investment strategies: Equity Income, Multi-Cap Equity, Intermediate Taxable Fixed Income, and Intermediate Municipal Fixed Income. Portfolio Construction and Composition. Davidson Investment Advisors can use a variety of investments, including stocks, bonds, mutual funds, and ETFs, among others, to build a portfolio of diversified holdings 5  appropriate for clients enrolled in the Discretionary Program; the Firm will use all or a subset of these investments to construct the client’s portfolio. The Firm can provide diversification through exposure to different asset classes (such as equities, fixed income, and alternative investments). More information on the methods of analysis for investment strategies undertaken in the Discretionary Program is provided in Item 6 below under Portfolio Manager Selection and Evaluation. Monitoring and Rebalancing. Davidson Investment Advisors reviews the portfolios periodically and considers whether, based on market fluctuations and other factors, adjusting the asset allocations and investment selections is appropriate. Depending on the type, accounts are generally reviewed on a quarterly basis or at least on an annual basis. Once changes are deemed appropriate, they are implemented to the client’s Discretionary Program account at the Firm’s discretion without prior notice to the client (including regarding the timing of these changes). Reasonable Investment Restrictions. Subject to the agreement with Davidson Investment Advisors, the Firm may implement reasonable restrictions on the securities or types of securities held in the client’s Discretionary Program account upon request, including directing Davidson Investment Advisors to not purchase or liquidate certain securities in their account. Each request for an account restriction must be communicated in writing to Davidson Investment Advisors and will be considered in accordance with the Firm’s policies and procedures and must be approved by Davidson Investment Advisors in its sole discretion. This option, however, is not intended to permit a client to direct the purchase of certain securities or types of securities in their account. If the request for restrictions is deemed reasonable by Davidson Investment Advisors, the Firm will select replacement securities as appropriate. Note that restrictions placed on an account may positively or negatively affect account performance and may cause the account to perform differently (including worse) than a like account with no restrictions. Restrictions cannot be placed on securities issued by pooled investment vehicles held in a client’s account (e.g., mutual funds, exchange traded funds, etc.). Tax Overlay Service. For taxable accounts that select Davidson Investment Advisors’ Tax Overlay service, the Firm will seek to harvest the tax losses in a client’s Discretionary Program account to the extent consistent with the selected investment strategy. The Firm will strategically sell relevant securities in your account with unrealized losses. When Davidson Investment Advisors sells this security, it may enable the client to offset taxes on both capital gains and a limited amount of ordinary income. When implementing the Tax Overlay service, Davidson Investment Advisors will harvest tax losses with respect to securities it has recommended, and not necessarily based on other positions in the Discretionary Program account. The Firm will review the positions in the client’s account for tax losses on a quarterly basis; the Firm may change this frequency from time to time without notice. Davidson Investment Advisors’ goal is not to maximize overall losses either in the client’s account or across all of a client’s accounts (managed by the Firm or elsewhere), as the Firm will not necessarily sell all securities with unrealized losses in a particular client account and will also not necessarily sell securities with the greatest aggregate losses in a particular client account. Davidson Investment Advisors will only sell those securities with unrealized losses that it determines are appropriate to be sold at the time. Proceeds from positions sold to harvest losses will be held in cash or an ETF until “wash sale” windows expire. Client-Directed Tax Harvesting. For taxable accounts, Davidson Investment Advisors will also accept instructions to harvest a specific amount of tax losses or gains, subject to such limitations and procedures as the Firm may establish from time to time. Instructions to harvest tax losses must be provided in writing in the manner prescribed by the Firm. Davidson Investment Advisors will reasonably attempt to fulfill these 6  instructions but may determine that a request is not feasible for a variety of reasons, including but not limited to, the size of the request. Any proceeds from such tax loss sales will be held in cash and will not be reinvested in substitute securities, unless otherwise instructed, which may affect the performance of the account. Tax-Aware Transition Service. For new accounts coming under Davidson Investment Advisors’ management, the Firm offers a Tax-Aware Transition service, whereby Davidson Investment Advisors facilitates tax-optimal transitions of legacy security positions into target investment strategies. This service includes discretionary implementation of trades to maintain with reasonable precision the specified asset allocation of the selected investment strategy, while realizing capital gains associated with legacy positions over multiple (generally 2-3) tax years. Additional Information Regarding Tax-Related Services. If clients and/or their spouse have other taxable or non-taxable accounts, and the client holds in those accounts any of the securities held in your Davidson Investment Advisors managed account, clients should not buy any security sold at a loss for a period of at least 30 days before or after the Firm sells those same securities as part of a tax-related service offered by the Firm to avoid the possible application of the “wash sale” rules. Clients are responsible for monitoring their (and their spouse’s) accounts both under and outside of Davidson Investment Advisors’ management to ensure that transactions in the same security or a substantially similar security as the one traded in the client’s account managed by the Firm do not create a wash sale. A wash sale is the sale at a loss and purchase of the same security or substantially similar security within 30 days of each other. If a wash sale transaction occurs, the IRS may disallow or defer the claimed loss for tax reporting purposes. More specifically, the wash sale period for any sale at a loss consists of 61 calendar days: the day of the sale, the 30 days before the sale, and the 30 days after the sale. The wash sale rule has the effect of disallowing or postponing losses on a sale if a replacement security is bought within these time periods. If a client has multiple household accounts under Davidson Investment Advisors’ management, the Firm will not monitor other household accounts, nor will it monitor any accounts for members of a client’s household maintained outside the Firm’s management, to ensure that transactions in the same security or a substantially similar security do not create a wash sale. For more information on the wash sale rule, please read IRS Publication 550. Whether Davidson Investment Advisors’ tax-related services are effective in reducing a client’s overall tax liability will depend on the client’s entire tax and investment profile, including purchases and dispositions in the client’s (or their spouse’s) accounts outside of Davidson Investment Advisors’ management, the nature of the client’s investments (e.g., taxable or nontaxable) and their respective holding period (e.g., short-term or long-term). Davidson Investment Advisors will monitor only the account(s) opting into the tax-related service to determine if there are unrealized losses for purposes of determining whether to harvest losses. Transactions in any account other than a client’s account, any accounts outside of the Firm’s management, or even additional Davidson Investment Advisors-managed accounts may affect whether a loss is successfully harvested. Moreover, in determining whether and how to harvest tax losses, the Firm relies on various assumptions about the tax posture of a typical investor, which assumptions may or may not correspond with the client’s actual circumstances. Davidson Investment Advisors does not employ tax professionals and has not and will not provide tax advice to clients. No employee of Davidson Investment Advisors is qualified or permitted to provide tax advice. Clients should consult a tax professional for specific tax advice and specifically regarding the tax consequences of 7  investing with Davidson Investment Advisors and engaging in tax-related services based on their particular circumstances. No feature of, interaction with, description of, or action taken in accordance with the Firm’s management, including tax-related services, represents a tax strategy in the context of a client’s individual tax situation and should not replace or supplement the advice of a personal tax advisor. Davidson Investment Advisors is not responsible for ensuring that clients accurately report the trading activity in their account to the IRS or any other relevant taxing authority. The Firm is not responsible to clients for the tax consequences of any transaction in a managed account. Davidson Investment Advisors makes no warranties or guarantees that the tax consequences described herein or in any materials provided to clients in respect to your managed account will be achieved. The Firm also makes no warranty or guarantee that the IRS or other relevant taxing authorities will not challenge the tax consequences of its trades, nor that any such challenge will not be successful. If the IRS is successful in its claim that one or more transactions executed pursuant to the Program were wash sale transactions, any loss recognized on such transactions may be deferred or disallowed, and clients may be subject to the imposition of interest and penalties on such transactions. Fees and Compensation. The specific fee a client will pay is set forth in their Statement of Investment Selection, or as indicated in any amendment thereof. A client pays Davidson Investment Advisors an asset- based fee, which is an ongoing fee based on the market value of the assets in the account (including cash and cash equivalents) on the last day of the preceding quarter (the “Discretionary Fee”). The Discretionary Program Fee is negotiable and determined based upon a number of factors. Davidson Investment Advisors will take into consideration the value of the assets across accounts in one household participating in one or more Programs, subject to certain restrictions, the services expected to be provided to the clients, the types of assets being deposited into the account participating in the relevant Program, the composition of the account (i.e. whether the account holds or mostly holds equity securities or fixed income securities), and the nature of the client relationship In general, the greater the value of assets a client has invested through one or more Programs when the fee is established, the lower the fee will be. However, because the Discretionary Fee is individually negotiated, not all clients with the same amount of assets will be charged the same fee in the same program. Allowing Davidson Investment Advisors to determine the Discretionary Fee creates a conflict of interest because the Firm is incentivized to increase their compensation by setting a higher fee for client’s account. Following is a typical annual fee schedule for the Discretionary Program, based on total advisory household value. However, as indicated above, the Discretionary Program Fee is negotiable. Advisory Household Value Fee Rate Less than $2.5mm 1.00% $2.5mm - $10mm 0.90% $10mm - $20mm 0.75% $20mm+ negotiable Note: There are exceptions to the above fee construct for a limited number of clients based on legacy relationships and/or supervisory approval. NON-DISCRETIONARY PROGRAM Account Composition. For clients, or other members of a client’s household, that have a Discretionary Program account, Davidson Investment Advisors offers a non-discretionary advisory account in which clients can hold 8  certain assets such as the Fund or legacy holdings that clients wish to retain. Neither Davidson Investment Advisors nor its Financial Professionals has investment discretion and may not buy or sell securities in connection with the account without the client’s consent. The client enters into an agreement with the Firm for the provision of advisory, custody, brokerage and administrative services. Limited Monitoring. The client has sole discretion and makes the final decision whether to accept or reject any specific recommendation to purchase or sell securities. Davidson Investment Advisors is responsible for reviewing the account at least annually to assess whether the investments in the client’s account are suitable. Client-Directed Tax Harvesting. For taxable accounts Davidson Investment Advisors will also accept instructions to harvest specific tax losses or gains, subject to such limitations and procedures as the Firm may establish from time to time. Instructions to harvest tax losses must be provided in writing in the manner prescribed by the Firm. Davidson Investment Advisors will reasonably attempt to fulfill these instructions for Discretionary Program accounts but may determine that a request is not feasible for a variety of reasons, including but not limited to, the size of the request. Any proceeds from such tax loss sales will be held in cash and will not be reinvested in substitute securities, unless otherwise instructed, which may affect the performance of the account. Davidson Investment Advisors does not employ tax professionals and has not and will not provide tax advice to clients. No employee of Davidson Investment Advisors is qualified or permitted to provide tax advice. Clients should consult a tax professional for specific tax advice and specifically regarding the tax consequences of investing with Davidson Investment Advisors and engaging in Tax Harvesting based on their particular circumstances. No feature of, interaction with, description of, or action taken in accordance with the Firm’s management, including the Tax Overlay service, represents a tax strategy in the context of a client’s individual tax situation and should not replace or supplement the advice of a personal tax advisor. Davidson Investment Advisors is not responsible for ensuring that clients accurately report the trading activity in their account to the IRS or any other relevant taxing authority. The Firm is not responsible to clients for the tax consequences of any transaction in a managed account. Davidson Investment Advisors makes no warranties or guarantees that the tax consequences described herein or in any materials provided to clients in respect to your managed account will be achieved. The Firm also makes no warranty or guarantee that the IRS or other relevant taxing authorities will not challenge the tax consequences of its trades, nor that any such challenge will not be successful. If the IRS is successful in its claim that one or more transactions executed pursuant to the Program were wash sale transactions, any loss recognized on such transactions may be deferred or disallowed, and clients may be subject to the imposition of interest and penalties on such transactions. Fees and Compensation. A Non-Discretionary Program client’s Statement of Investment Selection will set forth the actual compensation the client will pay to Davidson Investment Advisors (the “Non-Discretionary Fee”). Clients with assets in the Firm’s ’s Non-Discretionary Program pay an annual advisory fee of 0.20% of assets under management, with a maximum fee of $250 annually. This ongoing fee is based on the market value of the assets in the account on the last day of the preceding year. If applicable, the value of Davidson Multi-Cap Equity Fund shares, which the Firm advises, is excluded from fee calculations. ADDITIONAL PROGRAM INFORMATION How Advisory Fees are Charged. Unless Davidson Investment Advisors has agreed otherwise (in writing), the Discretionary Fee is calculated and charged quarterly, in advance, payable on the first day of each calendar 9  quarter. This quarterly fee is calculated based on the market value of the assets in the account (including cash and cash-equivalents) on the last business day of the prior quarter, the portion of the applicable Discretionary Fee rate based on the 90 days in the quarter, and a 360-day year. The value of assets held in the Discretionary Program account will be determined in good faith by the Firm to reflect their fair market value. The initial billing period begins when an Advisory Agreement is signed by the client and accepted and executed by Davidson Investment Advisors. If this occurs after the start of a quarterly billing period, the initial or partial quarter fee will be prorated based on the number of days remaining in the current calendar quarter. Discretionary Fees are automatically debited from the client’s account and billed in accordance with the terms set forth in the client’s Advisory Agreement. Clients may alternatively choose to be invoiced. Discretionary Fees may be paid with other billing arrangements if agreed upon separately. Unless Davidson Investment Advisors has agreed otherwise (in writing), the Non-Discretionary Fee, is calculated and charged annually, in advance, payable on the first day of each calendar year. This annual fee is calculated based on the market value of assets in the account (including cash and cash-equivalents) on the last business day of the prior calendar year. The value of assets held in the Non-Discretionary Program account will be determined in good faith by the Firm to reflect their fair market value. The initial billing period begins when an Advisory Agreement is signed by the client and accepted and executed by Davidson Investment Advisors. If this occurs after the start of a year, the annual fee will be prorated based on the number of days remaining in the calendar year. Non-Discretionary Fees are automatically debited from the client’s account and billed in accordance with the terms set forth in the client’s Advisory Agreement. Clients may alternatively choose to be invoiced. Non-Discretionary Fees may be paid with other billing arrangements if agreed upon separately. The Non-Discretionary Fee is waived for clients: (i) that also have assets in the Discretionary Program or (ii) are only invested in the Fund. Services Covered by the Advisory Fees. The Advisory fees cover investment advice provided by Financial Professionals, portfolio management services, the execution of client transactions, custody services by D.A. Davidson or DADTS, account servicing, reporting, monitoring, rebalancing and other services. Service Fees and Expenses NOT Covered by the Advisory Fees. In addition to the advisory fees described above, a client may incur other fees and expenses related to the management and servicing of their account. These other fees and expenses include exchange fees, electronic fund and wire transfer fees, margin interest, transfer taxes, redemption fees imposed by a mutual fund company in relation to trading deemed to be excessive, certain fees in connection with the establishment, administration, or termination of retirement or profit-sharing plans or trust accounting, or other costs or fees imposed under applicable laws or regulations. In addition, in connection with the purchase of certain types of securities (such as securities traded over the counter and fixed income securities), the client will bear the cost of any mark-ups, mark-downs and spreads charged by market-makers and dealers. For accounts with a margin debit, Davidson Investment Advisors charges a fee on the gross value of securities in the account and the client also pays the margin interest on the debit balance in the account. Investment Fees and Expenses NOT Covered by the Advisory Fees All advisory fees paid to the Firm for investment advisory services provided are in addition to the fees and expenses clients incur with respect to investments held in the accounts, including for assets invested in bank deposit accounts, money market funds, mutual funds, ETFs, and other pooled investments. These fees and expenses are described in each fund's (or other vehicle’s) prospectus or offering document and will be borne 10  directly or indirectly by their shareholders. These fees can include fund management fees, administrative fees, omnibus and sub-transfer agent fees, other fund expenses, and potentially a 12b-1 Fee or other marketing, shareholder servicing and distribution charges. By investing in these types of securities, a client is essentially paying multiple layers of fees and expenses on the assets invested. When investing in mutual funds, including money market funds, a 12b-1 fee may be assessed, depending on the fund selected. 12b-1 fees are sales charges that are incorporated into the expense ratio of the fund. As a matter of the Firm’s policy, any new purchases of mutual funds must be in an advisory share class that does not impose a 12b-1 Fee, where such a share class is available. Davidson Investment Advisors does not guarantee clients will always be invested in the most favorable share class offered by a mutual fund company or that more favorable share classes will be made available in advisory accounts. In no case does Davidson Investment Advisors receive compensation from mutual fund companies in which client assets are invested. For client accounts custodied at D.A. Davidson or DADTS, in the event the Firm receives a 12b-1 Fee in relation to an existing mutual fund position in an advisory account, the Firm will pass on and rebate the fee to the client. Termination of the Advisory Relationship. Either clients or the Firm may terminate participation in a Program upon ten business day’s written notice to the other. Davidson Investment Advisors may also place restrictions on client’s account (i) automatically upon notification to the Firm of client’s death, or the death of all authorized persons on the account (including trustees), (ii) should a client’s balance fall below the minimum balance due to client-initiated withdrawals, or (iii) if a client fails to update or provide any required documentation. In the event Davidson Investment Advisors or a client terminates an account, any prepaid, unearned fees will be refunded. The number of days remaining in the billing period after the effective date of the termination will be considered in determining the amount of any fee reimbursement due to a client. Upon termination, the account assets will no longer be managed and the account will be automatically converted to a custody-only brokerage account at D.A. Davidson or DADTS until the client transfers the assets to another provider or makes other arrangements with the Firm. Purchasing Like Services Outside of an Advisory Relationship. The products and services provided to a client in connection with an advisory account at Davidson Investment Advisors may be separately available to a client outside of the advisory account. Clients are cautioned that, depending on factors such as: the level of fees charged by the executing broker-dealer, the amount of trading activity in the client’s account, the value of the client’s account, the types of securities held in the client’s account, the client’s investment strategy, and the level of service sought by the client, the aggregate cost of the client’s advisory account may be higher than if the client had selected the services separately. In addition, fees charged by Davidson Investment Advisors may be higher or lower than the fee charged by another firm that offers comparable advisory services. A client could also invest in a mutual fund directly or through an unaffiliated broker-dealer without Davidson Investment Advisors’ services. In that case, the client would not receive the ongoing investment advisory services offered by the Firm through its programs, which are intended, among other things, to assist the client in determining which mutual funds or other securities are most appropriate in considering the client's financial condition and objectives. Moreover, the mutual fund purchased directly by the client may also impose an initial or deferred sales charge. Taking such information into consideration, each client should carefully review and evaluate their investment objectives and risk tolerance, the investment advisory services provided by Davidson Investment Advisors and other firms, and the costs and expenses charged by such firms, before determining 11  whether to open an advisory account and participate in a Program. Consolidating Statements and Mailings. Clients should notify their Financial Professional if they wish to consolidate custodial statements for multiple account at the same mailing address. Program accounts held directly by client, or for the benefit of a spouse, parent, child, or anyone else residing at the same address as the client, qualify for statement consolidation. Clients may also request a single combined quarterly performance report per mailing address. By consolidating statements and quarterly performance reports, clients allow the Firm to share client’s Program account performance information with others at the client’s mailing address. Consolidating statements and quarterly performance reports does not authorize others at the client’s mailing address to conduct transactions in a client’s account. Additional General Fee Information. Davidson Investment Advisors may modify a client’s existing fee and/or add additional fees or charges by providing the client thirty (30) days prior written notice. Different fee schedules have been in effect over time, which may have reflected fees that are higher or lower than those currently stated. Davidson Investment Advisors, at its discretion, may group certain related client accounts for the purposes of achieving the minimum account size requirements (described under Item 5 below) and determining the annual fee rate. Discounts not available to our advisory clients, may be offered to family members and friends of associated persons of our Firm. Rollovers and Transfers. Davidson Investment Advisors makes more money when a client increases their assets managed by the Firm, including through rollovers from workplace retirement plans or IRAs at other financial services companies into IRAs with the Firm (“rollovers or transfers”). When a client engages in a rollover or transfer to an advisory IRA (or other account), Davidson Investment Advisors will receive compensation in connection with the investments held in the IRA. These payments create an incentive for the Firm and its Financial Professionals to recommend rollovers and transfers. Financial Professionals do not make recommendations to roll assets out of a plan or transfer assets from an IRA, but rather provide investors who are eligible to withdraw their benefits from workplace retirement plans or IRAs at other financial services companies with educational materials to help them determine whether or not to complete a roll out or transfer and confirm that such determination was made independently without the Financial Professional’s recommendation. Client Referrals. Davidson Investment Advisors pays referral fees to independent third parties and firms (each, a “Promoter,” and collectively, "Promoters") for introducing clients to the Firm. Whenever Davidson Investment Advisors pays a referral fee, the Firm requires that the Promoter provide the prospective client with a copy of this Brochure and a separate disclosure statement at the time of solicitation that includes the following information: the Promoter's name and relationship with Davidson Investment Advisors; the fact that the Promoter is being paid a referral fee; the amount of the referral fee; the conflict of interest created by the referral fee; and whether the advisory fees paid to Davidson Investment Advisors by the client will be increased above the Firm’s previously agreed fees in order to compensate the Promoter. In practice, the advisory fees paid to the Firm by clients referred by Promoters are not increased as a result of any referral. D.A. Davidson Financial Professionals who recommend a client participate in Davidson Investment Advisors’ wrap fee program will receive compensation as a result of that recommendation. The amount of compensation 12  received is made in Davidson Investment Advisors’ sole discretion and is based upon the client’s Fee and the level of client service provided by the D.A. Davidson Financial Professional. Securities-Based Lending. Davidson Investment Advisors can refer qualifying clients to borrow money from a third-party lender (the “Lender”) under D.A. Davidson’s Lending Program (the “Loan”). The Loan can be used for any personal or business purpose other than to purchase, carry or trade securities. The Loan is secured by the assets in a client’s non-qualified advisory and/or brokerage account(s). Any referral by Davidson Investment Advisors made to a Lender or for a Loan is an ancillary service and not part of our Programs or advisory services. Davidson Investment Advisors can educate clients about the Loan and eligibility criteria, act as an intermediary between the client and the Lender, but does not recommend the Loan, a draw down on the Loan or otherwise act in a fiduciary capacity with regard to the Loan. Davidson Investment Advisors also will not provide advice, monitor or oversee any such lending arrangement. Clients considering a loan should refer to the disclosure titled Important Considerations for Liquidity Needs available at dadavidson.com/Disclosures for more educational information about liquidity options, including considerations for taking the Loan and associated conflicts of interest. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE Advisers Act Fiduciary Duty. As a registered investment adviser, Davidson Investment Advisors is subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means that the Firm is required to act in the client’s best interest when providing investment advice and managing client accounts. The duty of care requires, among other things, for Davidson Investment Advisors to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information, and other circumstances (collectively, client’s “Investment Profile”) or mandate. The duty of loyalty requires the Firm to eliminate or mitigate material conflicts of interest with clients, and to provide full and fair disclosure of such conflicts of interest. The duties also require Davidson Investment Advisors to provide ongoing monitoring of Programs’ accounts and its recommendations of Programs’ accounts. Special Rules for Retirement Accounts. For retirement and other qualified accounts, including employer- sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, Coverdell educational savings accounts, and other similar accounts (collectively, “retirement accounts”) DIA is a “fiduciary” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when providing investment advice or managing a client’s account. ERISA and the Code limit the types of products and services Davidson Investment Advisors can offer and provide with respect to retirement accounts. When making recommendations that clients open, rollover or transfer retirement account assets to an advisory account or change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020- 02, which allows Davidson Investment Advisors to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires Davidson Investment Advisors to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under PTE 2020-02, Davidson Investment Advisors and its financial professionals must also: 13  • Meet a professional standard of care (give prudent advice); • Not put the Firm’s financial interests ahead of client’s (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that the Firm and its financial professionals give advice that is in client’s best interest; • Charge no more than is reasonable for the Firm’s services; and • Give the client basic information about conflicts of interest. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendation (“Covered Recommendation”), as may be applicable: • Roll Out Recommendation. From time to time, the Firm in coordination with a centralized review team, will provide a written recommendation that client roll out assets from a plan to an IRA. The above acknowledgement does not apply to other suggestions, recommendations, and services the Firm and its financial professionals provide and that are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. Davidson Investment Advisors refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an individualized/personalized suggestion for a client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as a Covered Recommendation under this disclosure, including, but not limited to: • General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; • General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm; • General Information and Education about rollovers from a 529 account to a Roth IRA; • Transfers of retirement account assets held at a financial service company other than the Firm (including directly with an investment product sponsor); • Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts); • Transactions clients enter into without a recommendation from Davidson Investment Advisors or that are contrary to, or inconsistent with, their recommendation; • Ongoing recommendations of securities or other transactions or discretionary investment advice, except as otherwise agreed to in writing in any applicable agreements or disclosures; 14  • Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company; and • Recommendations that are not fiduciary “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account). The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020-02 does not require that Davidson Investment Advisors guarantee the performance of any investment or that a client’s investment objectives will be achieved. In addition, Davidson Investment Advisors and its financial professionals may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to a client. There may be times when Davidson Investment Advisors is legally prohibited from making a recommendation that may be otherwise considered to be in a client’s best interest, such as due to insider trading. A client understands any recommendations Davidson Investment Advisors, or its financial professionals make will reflect the information client provides to the Firm about their investment objectives, risk level, investment time horizon, financial information and other circumstances and Davidson Investment Advisors will not be responsible for any information a client omits or fails to provide, including changes thereto. Davidson Investment Advisors and its financial professionals’ recommendations and advice will also reflect any reasonable limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying Davidson Investment Advisors and their financial professionals if their investment objectives, risk tolerance or financial circumstances change. Davidson Investment Advisors will not be responsible for clients’ decision to invest or transfer their retirement account assets in a manner that is different from, or inconsistent with, Davidson Investment Advisors’ recommendations or other advice and guidance, and clients assume the risk of such decision, nor will Davidson Investment Advisors or its financial professionals be responsible for clients’ delay in implementing a recommendation. Reasonable compensation under the retirement laws has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features and benefits) provided. This standard does not require Davidson Investment Advisors to offer its services at the lowest cost, or for the least compensation, in the marketplace, nor that it offer its services to clients at the same or lower cost or compensation levels than it offers them to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their advisory services than others. By entering into an agreement with Davidson Investment Advisors, clients agree that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If clients decide not to use all or some of the services made available, clients agree the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If clients want to change the services the Firm makes available to them or has any concerns regarding the level of fees their retirement account pays or Davidson Investment Advisors’ compensation, a client should contact their financial professional immediately. 15  CUSTODY Client assets are held in custody at D. A. Davidson or DADTS, related persons and qualified custodians. Clients will receive account statements directly from D. A. Davidson. That statement is the official record of your account and the assets contained in it. As noted under Item 9 and the Review of Accounts-section below, Davidson Investment Advisors also delivers statements and reports to clients on the performance of their account. We urge you to compare the information contained in the Davidson Investment Advisors quarterly account statements and other reports to the information contained in your official statements for the same period. In the event of a discrepancy between official account statements and other reports or statements for the holdings and transactions shown, the client’s official account statement shall prevail. Item 5 Account Requirements and Types of Clients MINIMUM ACCOUNT REQUIREMENTS Davidson Investment Advisors accounts are subject to certain minimum account size requirements. Minimum account sizes vary by Program and may vary depending on the type of portfolio selected for the client’s account. A minimum of $100,000 of assets is required to participate in the Discretionary Program’s equity strategies. A minimum of $250,000 of assets is required to participate in the Discretionary Program’s fixed income strategies. A minimum of $50,000 of assets is required to participate in the Discretionary Program’s multi-asset portfolio solutions. A minimum of $250 of assets is required to participate in the Non-Discretionary Program. These account minimums may be higher or lower under certain circumstances and depending on the portfolio selected. Please refer to the Investment Strategies section below for a detailed description of the investment strategies. If client’s account falls below the minimum for the Program or portfolio, the Financial Professional may recommend a different portfolio or that the advisory account be closed. TYPES OF CLIENTS Davidson Investment Advisors offers its services, including the wrap fee services, to all types of current or prospective clients, including, but not limited to: individuals; banks or thrift institutions; ERISA and non-ERISA retirement plans; trusts; estates; charitable organizations; corporations or other business entities; and registered investment companies. Item 6 Portfolio Manager Selection and Evaluation Davidson Investment Advisors serves as Wrap Program sponsor and portfolio manager. All investment strategies discussed below are managed internally by the Firm’s Investment Team. The investment strategy is recommended by the Financial Professional for a particular client as described in Item 4 above. CALCULATION AND REVIEW OF PERFORMANCE Davidson Investment Advisors prepares and presents composite performance in conformance with the Global Investment Performance Standards (GIPS®). Davidson Investment Advisors is independently verified on annual basis; verification assesses whether (1) the Firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the Firm's policies and procedures are designed to calculate and present composite performance in compliance with the GIPS standards. The Firm’s annual verification is performed by TSG (formerly The Spaulding Group, Inc.). 16  GIPS performance is based on time-weighted-return methodology. Time-weighted performance is often used as an industry standard to compare investment managers as it measures the compounded rate of growth, while removing the distorting effects caused by the inflow or outflow of funds in a portfolio. A client’s actual individual account performance is available to clients in a quarterly performance report. PORTFOLIO MANAGEMENT BY RELATED PERSONS As previously noted, all portfolios are managed internally by the Firm’s Investment Team. PERFORMANCE-BASED FEES Davidson Investment Advisors, Inc. does not charge performance-based fees (i.e., fees based on a share of capital gains or capital appreciation of the client's assets) in its Wrap Program. METHODS OF ANALYSIS – DISCRETIONARY PROGRAM The Investment Team process leverages one team, with shared responsibility for investment strategy construction, changes to investment strategies, timing, and parameters for implementation, and monitoring and rebalancing the strategies. They conduct due diligence building investment strategies based on an evaluation of the capital markets, current and projected macroeconomic and other conditions and performance of investments over time. Davidson Investment Advisors utilizes three primary methods of analysis for its investment strategies: Fundamental Analysis. Davidson Investment Advisors attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the issuer itself) to determine if the security is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. Quantitative Analysis. Quantitative analysis uses complex mathematical models and statistics to analyze past events to make investment decisions about security performance (or larger market movements) in the future. Qualitative Analysis. Qualitative Analysis involves the analysis of unquantifiable information, such as management decisions, to evaluate investment opportunities in the company’s securities. INVESTMENT STRATEGIES – DISCRETIONARY PROGRAM Davidson Investment Advisors offers the following core investment strategies in the Discretionary Program: Equity Income Strategy. The Equity Income strategy invests in U.S.-traded equities and ETFs, and its primary investment objectives are capital appreciation and income generation. The strategy is actively managed and invests in high-quality companies with solid balance sheets, ample cash flow and a strong competitive position generating attractive return on capital. Key to the investment strategy is our focus on Dividend Power -- looking beyond current dividend yield to include a company's future capacity for dividends. Using a multivariate appraisal process, we assess value across three dimensions (Asset Value, Dividend Power, and Growth Value) to uncover quality companies underappreciated by the broader market. Multi-Cap Equity Strategy. The Multi-Cap Equity strategy invests in U.S.-traded equities and ETFs, and its primary investment objective is capital appreciation. The strategy is actively managed and unconstrained by market capitalization and style classifications. As fundamental investors, we are cognizant of cyclical and 17  secular dynamics, and focus on profitable companies with attractive return on capital, cash flow and growth prospects. We take active industry positions, with relative position sizes commensurate with risk. Our holdings are diversified by economic sector and adjusted based on where we view the greatest market opportunities. Intermediate Taxable Fixed Income Strategy. The Intermediate Taxable Fixed Income strategy’s primary investment objectives are capital preservation and income generation. The strategy invests in a variety of securities, including U.S. Treasury bonds, corporate bonds, government agency bonds, mortgage-backed securities, and ETFs. The strategy is actively managed and focuses on the intermediate portion of the yield curve. We invest in investment grade or higher issues with maturities ranging from one to ten years. We perform fundamental credit analysis and monitor issuers and credit trends daily. We believe that fixed income assets are best managed actively with respect to duration and credit exposures, as we monitor, anticipate, and respond to changes in the broad economy and the interest rate environment. Intermediate Municipal Fixed Income Strategy. The Intermediate Municipal strategy’s primary investment objectives are capital preservation and tax-exempt income generation. The strategy invests in general obligation and revenue bonds of various municipalities across the U.S., as well as ETFs. The strategy is actively managed and focuses on the intermediate portion of the yield curve, purchasing investment-grade issues with maturities ranging from one to fifteen years. Emphasis is placed on purchasing issues with predictable income and principal stability, while managers also remain aware of resiliency to credit stress, changing interest rates, and market volatility. Given the tax-sensitive nature of the asset class, attention is also paid to the management of portfolio turnover and the opportunity to realize gains or losses as advantageous for clients, as well as Alternative Minimum Tax and state tax considerations. Davidson Investment Advisors also offers custom and multi-asset portfolio management in the Discretionary Program, which includes, but is not limited to, asset allocation services. We tailor portfolios to client specifications regarding exposure to various asset classes (including, but not limited to, equities, fixed income securities, international securities, alternative investments, and private equity), as well as desired portfolio characteristics (such as quality parameters or cash flow projections). Such specifications may be outlined in an institutional client’s Investment Policy Statement (IPS), a document that aligns the objectives of an organization with its financial goals to ensure financial assets support organizational objectives. For all investment strategies, securities selected for inclusion in client portfolios are monitored using Bloomberg and other available data. Davidson Investment Advisors focuses on long-term investing; ultimately, a portfolio position may be sold once the security has become fully priced by the market, a more favorable investment alternative becomes available, the fundamentals of the issuer deteriorate, or catalysts for growth identified in the due diligence process fail to develop. METHODS OF ANALYSIS – NON-DISCRETIONARY PROGRAM As described under Item 4 above, for clients, or other members of a client’s household, that have a Discretionary Program account, Davidson Investment Advisors can offer a non-discretionary advisory program account in which clients can hold certain assets such as the Fund or legacy holdings that clients wish to retain. In the Non-Discretionary Program, a Financial Professional advises the client on these holdings and monitors the account. Davidson Investment Advisors uses a customized approach to recommendations and methods analysis depending upon the client’s investment circumstances. In the Non-Discretionary Program, the client is ultimately responsible for the actual implementation of their assets. The use of leverage, including margin, may be used if directed by the client. 18  The client should ask Davidson Investment Advisors for information about their investment strategies, philosophies, and methods of analysis and investing techniques that may be used in formulating recommendations to the client in the Non-Discretionary account, bearing in mind, the client has sole discretion, and makes the final decision whether to accept or reject any specific recommendation made by Davidson Investment Advisors. RISK OF LOSS Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. The following provides information on specific types of investment risks depending on the type of underlying investments. Risks for all forms of analysis. Securities analysis methods rely on the assumption that the entities whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis becomes compromised by inaccurate or misleading information. Investing in any security involves risk of loss that clients should be prepared to bear. Fundamental Analysis Risk. This method of analysis presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the security. Quantitative Analysis Risk. A risk in using quantitative analysis is that the models used are based on assumptions that may prove to be incorrect. Qualitative Analysis Risk. A risk of using qualitative analysis is that our subjective judgment proves to be incorrect. Technical Analysis. Technical analysis involves the use of statistical data, and trends in that data, to identify trading opportunities. Technical analysis does not consider the underlying financial condition of a company, or the intrinsic value of its securities. This type of analysis presents a risk in that a poorly managed or financially unsound company may underperform regardless of larger movements in the market. Cyclical Analysis. This form of technical analysis involves studying cycles in the economy and financial markets. In this type of technical analysis, the movements of a particular stock are measured relative to the overall market in an attempt to predict the price movement of the security. The risk most commonly associated with this analysis is that the overall measurement is incorrect. Asset Allocation. A risk of an incorrect asset allocation decision is that the client does not participate in a sharp increase in a particular security, industry, or market sector. Another risk is that the ratio of equities, fixed income, and cash holdings will change over time due to security value and market movements and, if not corrected (i.e., through rebalancing), will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. A common risk of mutual funds and/or ETF analysis is that, as with other securities investments, past performance does not guarantee future results. A manager who has been successful in identifying profitable opportunities among mutual funds may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a mutual fund or ETF, managers of different funds held by the client may purchase the same security, creating concentrated exposure for the 19  client to that security and increasing the risk to the client if that security were to fall in value. There is also a risk of a manager deviating from the stated investment mandate or strategy of the mutual fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Interest Rate Risk. Fluctuations in interest rates cause investment prices to fluctuate. For example, bond market values have an inverse relationship to changes in interest rates. Rising interest rates cause bond market values to decline and declining interest rates cause market values to rise. Generally, the longer a bond’s maturity, the greater the interest rate risk and the higher its yield. Similarly, equities may also suffer from rising interest rates. Market Risk. Market risk is the risk of investment losses in a client’s account due to a variety of reasons outside of Davidson Investment Advisors’ control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, epidemic, pandemic, or social events, independent of the intrinsic valuation of one or more securities in the client’s account. Inflation Risk. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Inflation risk is the risk of inflation exceeding or eroding the return of an investment in the client’s account. Currency Risk. Among other risks, investments in non-U.S. securities are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Currency risk could lead to a loss to a client, for example, when the proceeds from the sale of the non-U.S. security, which may be in a devaluing foreign currency, are converted to a relatively stronger U.S. dollar. Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at a potentially lower rate of return (i.e., due to reductions in interest rates). This relates primarily to client account investments in fixed income securities. Business Risk. These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of potential profitability than an electric company, which generates its income from a steady stream of customers who buy electricity of the prevailing macroeconomic environment. Liquidity Risk. Liquidity is the ability to readily convert a security into cash. Securities in a client’s account are more liquid if many individuals are interested in buying or selling them. For example, Treasury bills are highly liquid, while real estate properties are relatively illiquid. Liquidity risk is therefore the risk that a client will not be able to promptly sell a security due to a limited market for that instrument. Financial Risk. Excessive borrowing to finance a business’ operations may create a degree of stress on the firm to the point of jeopardizing its profitability, and potentially triggering a default on one or more outstanding loans. Depending on the circumstances, such a development could lead to a declining value in the company’s securities, or even its bankruptcy. Global Economic Risk. National and regional economies and financial markets are becoming increasingly interconnected, which increases the possibility that conditions in one country, region or market might adversely impact issuers in a different country, region, or market. Changes in legal, political, regulatory, tax and 20  economic conditions may cause fluctuations in markets and securities prices around the world, which could negatively impact the value of an account’s investments. Major economic or political disruptions, particularly in large economies, may have negative global economic and market repercussions. Additionally, events such as war, terrorism, natural and environmental disasters and the spread of infectious illnesses or other public health emergencies may adversely affect the global economy and the markets and issuers in which an account invests. These events could reduce consumer demand or economic output, result in market closure, travel restrictions or quarantines, and have a significant impact on the economy. Such events could materially increase risks, including market and liquidity risk, and significantly reduce account values. Cybersecurity Risk. Client portfolios are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events that include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cyber security failures or breaches by a third-party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially result in in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Technology Risk. The Firm’s investment offerings are dependent upon various computer and telecommunication technologies, many of which are provided by or are dependent on third parties. The successful operation of our Firm could be severely compromised by system or component failure, telecommunication failure, power loss, a software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damage, human errors in using or accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunication systems or operations could have a material adverse effect on the Firm. Such a material effect may have a heightened impact on the investment strategies, given the automated nature of the services provided. Concentration Risk. This is the risk that a client’s portfolio is heavily allocated in one or few securities, industries, sectors, or geographic locations. This increases the impact of negative or positive performance compared to a portfolio which is diversified. Specific Security Risks. In addition to the above risks, each security type used has certain characteristics and is subject to a risk of loss that clients should be prepared to bear. For more information about risks associated with stocks, fixed income securities, mutual funds, and ETFs should speak with a financial professional. For risks associated with mutual funds and ETFs in a client’s account, see the fund’s current prospectus. VOTING CLIENT SECURITIES Davidson Investment Advisors does not vote proxies on behalf of clients in the Non-Discretionary Program. Clients retain the responsibility to vote proxies relating to securities in their accounts. 21  Davidson Investment Advisors votes proxies for client accounts in the Discretionary Program. Client may retain the right to vote proxies for their own accounts, or direct the Firm to vote a proxy in a particular manner, so long as the client timely notifies the Financial Professional. Davidson Investment Advisors has engaged a third-party Proxy Service Vendor to provide proxy voting administrative duties and proxy voting recommendations from another third-party Proxy Advisory Firm (“Proxy Advisor”). The Proxy Advisor recommendations are pre-populated into the Proxy Service Vendor’s electronic voting platform and are automatically executed pursuant to the Proxy Advisor’s recommendations. However, the Firm reserves the right to exercise its own judgment on a case-by-case basis, to serve its clients’ best interests once it has determined that such a vote would not involve an identified firm-related conflict of interest. In these situations, Davidson Investment Advisors will vote in favor of proxy proposals that enhance the independence of board membership, against measures that promote anti-takeover defenses, and for incentive compensation that would align management interests with shareholder interests, including stock- based compensation and restricted stock award programs. Corporate governance issues, however, are diverse and continually evolving and these general policies may not be relevant in some circumstances. An Investment Adviser Proxy Voting Committee (the “Committee”), with members including senior personnel from Davidson Investment Advisors and other D.A. Davidson Companies’ subsidiaries, meets periodically. The Committee monitors the Firm’s overall adherence to and effectiveness of the Firm’s proxy voting policies and procedures. It reviews the rationale for some proxy votes that are not covered by the policies and procedures, or that present a potential conflict of interest. It also reviews the internal controls and independence of the third-party vendors on no less than an annual basis. The Committee periodically reviews policies and procedures and provides advice for revisions thereof. A summary of Davidson Investment Advisors’ proxy voting policies and procedures can be found on the Internet at dadavidson.com/Disclosures or a copy of the policies can be mailed, free of charge, at client's request to the following address: Davidson Investment Advisors, Compliance Department, 8 Third Street North, Great Falls, MT, 59401. With respect to ERISA accounts, we will vote proxies unless the plan documents specifically reserve the plan sponsor's right to vote proxies. To direct us to vote a proxy in a particular manner, clients should contact Davidson Investment Advisors by telephone, email, or in writing. Conflicts of Interest. Davidson Investment Advisors and its supervised persons have various conflicts in relation to voting client proxies, which may include personal investments, outside activities, personal relationships, and management of investment accounts for or on behalf of publicly traded companies. Davidson Investment Advisors believes, however, that its retention of the Proxy Service Vendor, use of the Proxy Advisor Firm recommendations, it’s adherence to its proxy voting policies and procedures and oversight by the Proxy Voting Committee help to ensure proxies are voted in the best interest of the Firm’s clients. Class Action Notices. Davidson Investment Advisors will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s), including, but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, clients may direct us to transmit copies of class action notices to the client or a third party. Upon such direction, we will make commercially reasonable efforts to forward such notices in a timely manner. 22  Item 7 Client Information Provided to Portfolio Managers As described in Item 4 above, Financial Professionals are responsible for gathering client’s Investment Profile (i.e., investment objectives, risk tolerance, time horizon, financial information, and other circumstances) as well as their liquidity needs and any reasonable restrictions the client wishes to impose upon the management of the account. Davidson Investment Advisors, including its portfolio managers, has access to clients’ information, including personal and account information when managing clients’ assets. It is ultimately the client's responsibility to advise the Firm of any changes to the information previously provided that might impact their account. Neither the Firm nor any investment manager is responsible for independently verifying information or data provided by a client, or for any adverse consequence arising out of or in any way connected with the client’s failure to promptly communicate the updated or new information to any of these persons. Item 8 Client Contact with Portfolio Managers Davidson Investment Advisors does not place any restrictions on clients who wish to contact or consult with portfolio managers managing their accounts. The Firm also encourages clients to discuss their accounts with their Financial Professional, if applicable, as the Financial Professional serves as the communication conduit between the client and the portfolio manager. Item 9 Additional Information DISCIPLINARY INFORMATION Davidson Investment Advisors does not have any events that are material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management, including any legal, financial, or disciplinary events that require disclosure. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Davidson Investment Advisors is a wholly-owned subsidiary of D.A. Davidson Companies, a financial services holding company with other subsidiaries: D.A. Davidson & Co. (“D.A. Davidson”), D.A. Davidson Trust Company (“Davidson Trust Company” or “Davidson Trust”), and D.A. Davidson Trust Services, Inc. (“DADTS”). D.A. Davidson. D.A. Davidson is dually registered as a broker-dealer with FINRA (Financial Industry Regulatory Authority) and a registered investment adviser with the SEC and is also a qualified custodian. Client assets are held in custody at D. A. Davidson or DADTS and all transactions for wrap fee accounts managed in Davidson Investment Advisors’ Programs are executed through D.A. Davidson. Additionally, D.A. Davidson Financial Professionals may refer clients to Davidson Investment Advisors in its capacities as independent investment adviser for the wrap programs described in this Brochure and as an investment adviser participating in D.A. Davidson’s advisory programs as described in the D.A. Davidson 2A Wrap Fee Brochure. D.A. Davidson Financial Professionals have an incentive to recommend a Program or an investment manager that is affiliated with D.A. Davidson because the entire client fee is retained by D.A. Davidson Companies. Often the D.A. Davidson Financial Professional remains the client’s financial advisor for the Davidson Investment Advisors wrap fee account and is compensated for the referral on an ongoing basis. 23  Many D.A. Davidson Financial Professionals are also registered representatives of D.A. Davidson in its capacity as a broker-dealer. When acting as a broker-dealer, these financial professionals provide brokerage and related services to clients, including in relation to the purchase and sale of individual stocks, bonds, mutual funds, private investment funds, life insurance policies and annuities, and other products. These broker-dealer recommendations and any subsequent implementation are separate and distinct from the Firm’s advisory services. See the D.A. Davidson Regulation Best Interest Disclosure at dadavidson.com/Disclosures for more information about D.A. Davidson’s Brokerage Services. Davidson Trust Company. Davidson Trust Company is a federal savings bank. Davidson Trust may elect to hire Davidson Investment Advisors as the investment adviser for certain client accounts over which Davidson Trust has investment discretion. Davidson Trust shares a portion of its investment management fee with Davidson Investment Advisors for providing investment advisory services. Davidson Investment Advisors also manages four Davidson Trust Company common trust funds. D.A. Davidson Trust Services, Inc. DADTS is a non-depository trust company chartered in New Hampshire which acts as the custodian for D.A. Davidson client assets maintained in IRA and 403(b) accounts. D.A. Davidson provides DADTS with supporting administrative, recordkeeping and reporting services as the client’s broker- dealer. Note Regarding D.A. Davidson Companies Conflicts of Interest. Fee sharing agreements amongst Davidson, D.A. Davidson, Davidson Trust Company, and DADTS create a conflict of interest because the fees for managing and trading client accounts are all retained by D.A. Davidson Companies. Davidson Funds. As previously disclosed in "Advisory Business" (Item 6) and "Fees and Compensation" (Item 4) of this Brochure, the Firm is the investment adviser to the Davidson Multi-Cap Equity Fund, a fund of the Adviser Series Trust, an investment company registered under the Investment Company Act of 1940. Non- Discretionary Program accounts are permitted to hold shares of the Fund; however, Discretionary Program accounts are typically not permitted to do so. Holding the Fund in a Davidson Investment Advisors account presents a conflict of interest by having the potential to retain more compensation in D.A. Davidson Companies. However, the value of client assets invested in the Fund, whether held in a Discretionary or Non-Discretionary account, are excluded from Advisory Fee calculations. As a result, Davidson Investment Advisors only earns the underlying Fund management fees and not an Advisory Fee for assets invested in the Fund. For additional information, the Fund’s Prospectus and Statement of Additional Information are available at: www.davidsonmutualfunds.com. Prospective investors should review these documents carefully before making any investment in the mutual fund. CODE OF ETHICS AND PERSONAL TRADING Davidson Investment Advisors has adopted a Code of Ethics (“Code”) which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. The Firm’s 's Code establishes rules of conduct for all employees and is designed to govern personal securities trading activities in the accounts of employees, among other things. The Code is based upon the principle that Davidson Investment Advisors and its employees owe a fiduciary duty to its clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: (i) serving their own personal 24  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. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by calling us at 800-332-0529. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS As a general practice, Davidson Investment Advisors does not engage in principal transactions. The Firm’s employees are allowed to invest in the same securities recommended to or owned by clients. However, in order to avoid conflicts of interest, all Davidson Investment Advisors employees are required to receive prior approval to trade in personal security accounts. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. D.A. Davidson Participation in Client Transactions. As previously noted, Davidson Investment Advisors may recommend D.A. Davidson, a related party and broker-dealer, as the qualified custodian or DADTS as qualified custodian for many Davidson Investment Advisor clients. Subject to the requirements of applicable law, D.A. Davidson may act as principal, buying securities for itself from, or selling securities it owns to, an advisory client, but only on a case-by-case basis with advance written authorization from the client, and when it is in the best interest of a client to do so. D.A. Davidson’s policy prohibits agency cross transactions for advisory clients, but in rare cases exceptions may be granted. An agency cross transaction is a transaction in which D.A. Davidson acts as broker for the party or parties on both sides of the transaction. However, no cross transactions may be made in ERISA-covered or IRA advisory accounts. For additional information regarding D.A. Davidson’s principal trading and agency cross transaction policies, please refer to D.A. Davidson’s Wrap Fee Program Brochure. You may also request a copy by calling us at 800-332-0529 or visit the website at www.dadavidson.com/Disclosures. GENERAL BROKERAGE PRACTICES For clients, Davidson Investment Advisors will determine: (1) which securities are bought and sold; (2) the total amount of such purchases and sales and whether a client's transaction should be aggregated with those of other clients; and (3) the broker through which transactions will be executed (with the exception of directed brokerage arrangements, as described later in this section). Best Execution. Davidson Investment Advisors has the obligation to seek best execution when it places trades with broker-dealers. Best execution entails the efficient placement of orders, clearance, settlement, and the overall quality of execution as well as the cost of the transaction. Directed Brokerage. Client accounts managed by Davidson Investment Advisors which originate through both the Discretionary and Non-Discretionary Programs are directed brokerage accounts to D.A. Davidson, an affiliated broker-dealer. This creates a conflict of interest by keeping all potential compensation in D.A. Davidson Companies. Not all advisers require their clients to direct brokerage. By directing brokerage clients may be unable to achieve most favorable execution of client transactions, which may cost clients more money. However, when Davidson Investment Advisors executes transactions in exchange-traded securities and mutual funds via D.A. Davidson, there are no additional per-share transaction costs to the client for the execution of 25  these trades. Additionally, Davidson Investment Advisors “steps-out” the majority of its fixed income trades, since it believes that “step-out” trades are more likely to provide clients with best execution and offer a higher degree of liquidity. Wrap Program clients will not incur trading costs that are in addition to the fee they pay to the program sponsor for fixed income transactions. Soft Dollars. Consistent with obtaining best execution for clients, Davidson Investment Advisors maintains trading arrangements with various broker-dealers whereby it has access to its research. The provision of such services in exchange for brokerage business is commonly referred to as a "soft dollar arrangement." Research services and products may include tangible research products, (publications or writings as to the value of securities, analysis and reports concerning issuers, industries, economic factors, and trends) as well as direct access to analysts and traders. This creates an incentive to select or recommend a broker-dealer based on Davidson Investment Advisors’ interest in receiving research, rather than client’ interest in receiving most favorable execution. However, Davidson Investment Advisors has a fiduciary duty to act in the best interest of clients and to obtain best execution for its advisory clients. The Firm does not enter into soft dollar arrangements that are not covered by the safe harbor of Section 28(e) of the Securities Exchange Act of 1934. Trade Errors. As a fiduciary, Davidson has the responsibility to effect orders correctly, promptly and in the best interests of its clients. If an error occurs in the handling of any client transactions or the Fund, due to the Firm’s action, or inaction, or actions of others, the Firm’s policy is to seek to identify and correct errors as promptly as possible without disadvantaging the client or Fund in any way. If the error is the responsibility of Davidson, the transaction will be corrected, and Davidson will be responsible for any client loss resulting from an inaccurate or erroneous order. BROKERAGE PRACTICES – DISCRETIONARY PROGRAM Order Aggregation. Davidson Investment Advisors will aggregate client trades where possible and when advantageous to clients. This aggregation of trades permits the trading of blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. All participating accounts receive an average share price for trade execution. Trade Rotation. Davidson Investment Advisors employs a trade rotation policy for block trades, by which a rotating, pre-determined order is used to bring clients’ shares to the market. In the event that an aggregated trade takes multiple trading sessions to complete, the overall trade rotation for subsets is adhered to, and allocation of shares is conducted on a random basis using the trade order management system. BROKERAGE PRACTICES – NON-DISCRETIONARY PROGRAM For Non-Discretionary accounts, Davidson Investment Advisors places orders for the account promptly after receiving client authorization to do so, and therefore, does not wait to aggregate trades for the client with trades for other clients. Because similar orders for the client and other clients will be placed and filled at different times, clients may buy or sell securities at prices that are different from the prices obtained by other clients who received the same or similar advice from Davidson Investment Advisors. All trades in Non- 26  Discretionary accounts will be placed through D.A. Davidson. REVIEW OF ACCOUNTS Reviews. Davidson Investment Advisors monitors the underlying securities within each client’s accounts. Depending on the type, accounts are reviewed on a quarterly basis or at least on an annual basis. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, the market, political or economic environment. These accounts are reviewed by various members of the Investment Team, client service professionals and portfolio administrators. While Davidson Investment Advisors provides the client with periodic reminders, it is ultimately the client's responsibility to advise the Firm of any changes to the information previously provided that might impact the investment strategy or objectives in which they are invested. Davidson Investment Advisors is not responsible for independently verifying information or data provided in a client’s initial or subsequent updates to a Client’s Investment Profile, nor is the Firm responsible for any adverse consequences arising out of a client’s failure to promptly provide notification. A client understands the integrity and quality of the respective investment management services to be rendered by Davidson Investment Advisors is dependent upon the accuracy of the data and information supplied by a client in a Client’s Investment Profile. Davidson Investment Advisors, or the Financial Professional if applicable, will directly contact each client at least annually to verify that there has been no change in the client's financial circumstances or investment objectives, and determine whether the client wishes to impose or change any reasonable restrictions on the management of the account. The Firm will promptly act on any reported changes. Reports. Davidson Investment Advisors provides written reports to clients on the performance of their account(s) on a quarterly basis. Client performance reports include a portfolio valuation, the asset allocation, and account performance. Performance returns include the deduction of advisory fees, transaction costs, market appreciation or depreciation and the reinvestment of capital gains, dividends, interest, and other income. When preparing a client’s account statements and performance reports, the Firm relies on third parties, such as third-party quotation services and other custodians when determining the value of account assets. Our Firm does not conduct an in-depth review of valuation information provided by third party quotation services or other custodians, and it does not verify or guarantee the accuracy of such information. The prices obtained by Davidson Investment Advisors from the third-party quotation services it uses may differ from prices that could be obtained from other sources. If a client has assets held by a third-party custodian, the prices shown on a client’s account statement provided by that custodian may be different from the prices shown on statements and reports provided by the Firm due to the use of different valuation sources by the custodian and Davidson Investment Advisors. CLIENT REFERRALS Davidson Investment Advisors will from time to time pays referral fees to independent persons or firms, as well as D.A. Davidson financial professionals at D.A. Davidson, a related person and broker-dealer, ("Promoters") for introducing clients to us. Whenever the Firm pays a referral fee, we require the Promoter to provide the prospective client with a copy of this Brochure and a separate disclosure statement that includes: the Promoter's name and relationship with our Firm; the fact that the Promoter is being paid a referral fee; the 27  amount of the fee; and whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. As a matter of Firm practice, the advisory fees charged to clients referred by Promoters or related parties are not increased as a result of any referral. OTHER COMPENSATION It is Davidson Investment Advisors’ policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Cash Management Program. Your Davidson Investment Advisors account typically includes an allocation to cash. D.A. Davidson or DADTS, the custodian for your account, utilizes a Cash Management Program, commonly referred to as a “sweep” program, to automatically deposit uninvested cash balances into an interest-bearing account maintained at one or more participating third-party banks (or in limited circumstances to an unaffiliated money market fund) at the end of each business day. Uninvested cash may occur due to, among other things, the sale of securities, dividend payments, interest credited from bonds, and short-term allocations to cash in the account portfolio. Clients affirmatively consent to participation in D.A. Davidson’s Cash Management Program by expressly electing it in the account application and signing the account agreement but can revoke this consent at any time by contacting their Financial Professional. D.A. Davidson receives important and significant compensation and benefits from client use of the Cash Management Program. Because the advisory fees are generally charged on cash balances and cash balances generate compensation to D.A. Davidson through the cash management program, D.A. Davidson Companies earns two levels of compensation on such cash balances in Davidson Investment Advisors wrap accounts. Please review the Cash Management Program Disclosure Statement available on the D.A. Davidson website at dadavidson.com/Disclosures for more information about how the cash management program works, including limitations, restrictions, how changes are implemented and additional discussion of conflicts of interest. For current interest rates applicable to the cash management program see https://www.dadavidson.com/Individuals/Wealth-Management/Saving-Credit-Lending. To obtain a copy of the disclosure document please contact your Financial Professional. Compensation of D.A. Davidson Financial Professionals. For information about the compensation of D.A. Davidson Financial Professionals, who may be the Financial Professionals assigned to your account, see the D.A. Davidson 2A Wrap Fee Program Brochure. As described above, Davidson Investment Advisors compensates D.A. Davidson Financial Professionals for referrals made to the Firm. Portfolio Manager Compensation. Portfolio managers at Davidson Investment Advisors are salaried employees and do not receive a portion of the fees assessed to client accounts. Financial Professionals Compensation. Davidson Investment Advisors’ Financial Professionals are salaried employees and do not receive a portion of the fees assessed to client accounts. The Firm’s Financial Professionals are eligible to receive a subjective bonus based upon several factors, including the Firm’s revenue, profit, and assets under administration growth. 28  FINANCIAL INFORMATION We are also required to disclose any financial condition that is likely to impair our ability to meet our contractual obligations. Davidson Investment Advisors, Inc. has no additional financial circumstances to report. Davidson Investment Advisors, Inc. has not been the subject of a bankruptcy petition at any time during the past ten years. Under no circumstances do we require or solicit payment of fees in excess of $1,200 more than six months in advance of services rendered. 29