DAVIDSON KAHN CAPITAL MANAGEMENT, LLC

Item 1: Cover Page Davidson Kahn Capital Management, LLC Firm Brochure - Form ADV Part 2A 14011 Ventura Blvd., Suite 302 Sherman Oaks, CA 91423 (310) 928-8192 jdavidson@davidsonkahn.com February 13, 2026 Registration does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Davidson Kahn Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at (310) 928- 8192 or by email at: jdavidson@davidsonkahn.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. Additional information about Davidson Kahn Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Davidson Kahn Capital Management, LLC’s CRD number is: 290062. 1  Item 2: Material Changes The following are material changes in this brochure from the last annual updating amendment filed 01/29/2025 for Davidson Kahn Capital Management, LLC. Material changes relate to the firm’s policies, practices or conflicts of interests. The firm has added a custodian. (Item 12). The firm has added language regarding Standing Letters of Authorization. (Item 15). The firm has amended the outside business activities for Mr. Davidson. (Item 10). Pursuant to applicable regulation, we will ensure that clients receive a summary of any material changes to this Brochure within 120 days of the close of our fiscal year-end. Additionally, as the firm experiences material changes in the future, we will send you a summary of our “Material Changes” under separate cover. 2  Item 3: Table of Contents 1 2 3 4 6 7 7 7 9 9 Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Services Item 5: Fees and Compensation Item 6: Performance Based Fees and Side by Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities and Affiliations; Conflicts of Interests Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12: Brokerage Practices Item 13: Review of Client Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities (Proxy Voting) Item 18: Financial Information 10 11 13 14 14 15 15 15 3  Item 4: Advisory Services A. Description of the Advisory Services Davidson Kahn Capital Management, LLC (hereinafter “DKCM”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in July 2017, and the principal owner is Jake R. Davidson. B. Types of Advisory Services Portfolio Management Services DKCM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. DKCM provides an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: Investment strategy ● ● Personal investment policy ● Asset allocation ● Asset selection ● Risk tolerance ● Regular portfolio monitoring DKCM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. DKCM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. DKCM seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of DKCM’s economic, investment or other financial interests. To meet its fiduciary obligations, DKCM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, DKCM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is DKCM’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. In addition to recommending investments in equity, fixed-income, exchanged traded funds (ETFs) and mutual funds, DKCM invests directly in equities that meet its requirements for value, growth potential, and financial stability. Allocation among these assets depends on the client’s individual situation. 4  Services Limited to Specific Types of Investments DKCM generally limits its investment advice to equities, mutual funds, ETFs and cash equivalent instruments. DKCM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposted Restrictions DKCM offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Financial Memorandum which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs DKCM does not participate in any wrap fee programs. A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. E. Assets Under Management DKCM has the following assets under management as of December 31, 2025. Discretionary Assets Non-discretionary Assets Total Assets $ 415,493,541.00 $0.0 $ 415,493,541.00 5  Item 5: Fees and Compensation A. Portfolio Management Fees Portfolio Management Fees will not be more than 1.00% of assets under management. Final fee for each client will be disclosed within the Advisory Agreement entered into between DKCM and the client. DKCM or its advisers, if applicable, may choose to charge a certain percentage of the fee to certain clients at their discretion. It should be expected that advisory fees may vary among portfolios based on a variety of factors. DKCM uses the liquidation value at the end of each month and collects fees monthly in arrears. This is completed after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. The final fee is attached as Exhibit I of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of DKCM's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. In such cases, fees will be charged on a pro-rated basis. B. Deduction of Advisory Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in arrears. Fees are assessed on all assets under management, including securities, cash and money market balances. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by DKCM. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees DKCM collects its fees in arrears, therefore it is our practice to not require prepayment of any fees in advance of services. E. Outside Compensation For the Sale of Securities to Clients Neither DKCM nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. 6  Item 6: Performance Based Fees and Side by Side Management DKCM does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. DKCM does not provide side by side management of funds. Side by side management is a financial strategy where one manager or firm simultaneously manages different investment funds, such as a mutual fund and a hedge fund, or separate funds with different investor types. Item 7: Types of Clients DKCM generally provides advisory services to the following types of clients: Individuals Corporations Foundations High-Net-Worth Individuals There is an account minimum of $500,000, which may be waived by DKCM at its discretion. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis DKCM’s methods of analysis include fundamental analysis and quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Quantitative analysis deals with measurable factors such as the value of assets, the cost of capital, historical projections of sales, and so on. DKCM will monitor the price of the securities we purchase. Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. 7  B. Investment Strategies DKCM purchases for the long term and may engage in margin transactions. Long term investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. We intend to use margin rarely, if ever, and only for brief periods of time. C. Risks of Loss Described below are what DKCM believes are the material risks of its investment program, but this section does not attempt to identify every risk or to describe completely those risks it does identify. Clients should be prepared to bear all of the risks described below and others if they invest with DKCM. Clients should discuss with the adviser any questions regarding the investment strategies employed for their particular accounts and their applicable risks. An understanding of risk in different forms can help clients to understand the opportunities, trade-offs and costs involved with different investment approaches. The principal risk of any investment is that, despite any comprehensive analysis, the security will not perform as expected. This can be due to, among other things: Market Risk: The success of investment activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty, changes in laws, trade barriers, currency fluctuations and controls, and national and international political circumstances. These factors may affect the level of volatility of securities prices and the liquidity of investments in client portfolios. Such volatility or illiquidity could impair profitability or result in losses. Volatility of Securities Markets: The value of securities held in client accounts that are traded on exchanges, and the risks associated with holding these positions, vary in response to events that affect asset markets in general. Market disruptions could lead to dramatic price swings in securities held within client portfolios and could result in substantial losses. Price and Interest Rate Risk: When interest rates change, the price of a bond is likely to adjust up or down so that its yield, based on the new price, is in line with the new level of interest rates. Interest rate risk is probably the most significant risk facing clients in fixed income securities because it affects all bonds similarly. 8  Equity: Investing in equity generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus the client may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Margin: DKCM's use of margin transactions generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information DKCM has never had a criminal, civil, administrative or regulatory matter to disclose or report regarding the firm or its representatives. Item 10: Other Financial Industry Activities and Affiliations; Conflicts of Interests Neither DKCM nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Jake R. Davidson, CPA, is a Certified Public Accountant and from time to time, may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Mr. Davidson is the President of J.R. Davidson and Co, Inc., this company provides management services to Davidson Kahn Capital Management, LLC, that may include payroll, compliance, human resources, bill paying and other miscellaneous activities. In addition, J.R. Davidson and Co provides consulting services to individuals and businesses. At times, a client of J.R Davidson and Co may also be a client of Davidson Kahn Capital Management, and clients should be aware that these services may involve a 9  conflict of interest. This conflict is mitigated by engaging in separate contracts for each service and full disclosure. Mr. Davidson is a Member of SDHBC Investment Partners, LLC, which provides investment advice and tax filings for his family. Mr. Davidson is the owner of SC Partners Holdings, LLC, a medical facility management company. Davidson Kahn Capital Management always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of Davidson Kahn Capital Management in connection with such individual’s activities outside of Davidson Kahn Capital Management. Alex Michael Lanzkowsky is currently the CFO of Centennial Medical Group in Las Vegas. This business is not investment related and he will not offer any services to clients from his outside business activities. In the future, Alex may offer clients advice or products from outside business activities and clients should be aware that these services may involve a conflict of interest. Davidson Kahn Capital Management always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of Davidson Kahn Capital Management in connection with such individual’s activities outside of Davidson Kahn Capital Management. Drew Cohen is a part owner of Speedwell Research LLC. Speedwell Research LLC is a research business that focuses on analyzing select public companies and produces in depth research reports and financial models for paying subscribers. Subscribers may include investment funds or professional investors, but Speedwell Research does not offer any explicit investment recommendations. Drew Cohen may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Davidson Kahn Capital Management always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of Davidson Kahn Capital Management in connection with such individual’s activities outside of Davidson Kahn Capital Management. DKCM does not use third party investment advisers, all assets are managed by DKCM. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics DKCM has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, 10  Annual Review, and Sanctions. DKCM's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests DKCM does not recommend that clients buy or sell any security in which a related person to DKCM or DKCM has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of DKCM may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of DKCM to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. DKCM reviews any personal transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of DKCM may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of DKCM to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, DKCM will never engage in trading that operates to the client’s disadvantage if representatives of DKCM buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices When DKCM places orders for the execution of portfolio transactions for Client accounts, transactions are allocated to the Client’s broker-dealer for execution in various markets at prices and commission rates that, based upon good faith judgment, will be in the best interest of the Client. Clients should be aware that in most instances, the broker-dealer performing such transactions also serves as the client’s custodian. The following discussion summarizes the material aspects of the Firm’s practices for the selection of broker-dealers to execute Client transactions. A. Factors Used to Select Custodians and/or Broker-Dealers All separately managed account clients are required to establish custodial accounts with a qualified custodian of record. DKCM does not have discretion to choose the custodian but will recommend certain broker-dealers that we do business with. DKCM requires clients to use Charles Schwab and Co., Fidelity, Altruist and/or Principal. DKCM will consider many factors when determining a broker-dealer 11  relationship, these may include their respective financial strength, reputation, execution, pricing, research, and service. The commissions and/or transaction fees charged by particular brokers selected by DKCM can be higher or lower than those charged by other broker-dealers. DKCM periodically evaluates the commissions charged and the service provided by the broker- dealer and compares those with industry norms to evaluate whether overall best qualitative execution is being achieved. Other factors DKCM considers when evaluating its choice of broker dealer include: • Ability to trade mutual funds and other investments that DKCM determines suitable for a Client's portfolio; • Any custodial relationship between the Client and the broker-dealer; • Excellent customer service; • Interaction simplicity with the Adviser; • Discount transaction rates; and • Reliability and financial stability. Best Execution Custodians/broker-dealers are recommended based on DKCM’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and DKCM may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in DKCM's research efforts. DKCM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Research and Other Soft-Dollar Benefits DKCM is provided with access to institutional trading and custody services, which are typically not available to retail investors through their custodians. By receiving benefits and services from the custodians, we do not have to produce or pay for them directly. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them. The custodian’s services include brokerage, custody, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. DKCM has no formal soft dollars program in which soft dollars are used to pay for third party services. DKCM may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions. DKCM may receive soft dollar benefits that are within the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and DKCM does not seek to allocate benefits to client accounts proportional to any soft dollar credits generated by the accounts. DKCM benefits by not having to produce or pay for the research, products or services, and DKCM will have an incentive to recommend a broker-dealer based on receiving research or services. 12  Brokerage for Client Referrals DKCM receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use DKCM will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregation (Block) Trading for Multiple Client Accounts If DKCM buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such a case, DKCM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. DKCM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Client Accounts A. Frequency and Nature of Periodic Reviews All client accounts for DKCM's advisory services are reviewed on an ongoing basis with regard to clients’ respective investment policies and risk tolerance levels. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of DKCM's advisory services provided on an ongoing basis will receive, no less than quarterly, a report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come directly from the custodian. 13  Item 14: Client Referrals and Other Compensation DKCM does not receive any economic benefit, directly or indirectly from any third party for advice rendered to DKCM's clients. DKCM does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody DKCM does not take physical custody of client funds nor constructive custody of client assets other than to deduct fees for advisory services. Clients receive monthly account statements from their respective custodians. These statements will include the account balances, positions held and transactions that were made throughout the period and will reflect a deduction for the monthly fee. When advisory fees are deducted directly from client accounts at client's custodian, DKCM will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. However, DKCM is deemed to have custody in certain situations under guidance issued by the SEC. Specifically, pursuant to the Investment Advisers Act of 1940, the Firm is deemed to have “constructive custody” of Client funds because we have the authority and ability to debit our fees directly from the accounts of those Clients receiving our services. Additionally, certain Clients have, and could in the future, sign a Standing Letter of Authorization (“SLOA”) that gives us the authority to transfer funds to a third-party as directed by the Client in the SLOA. This is also deemed to give us custody. Custody is defined as any legal or actual ability by the firm to withdraw client funds or securities. Firms with deemed custody must take the following steps: 1. Ensure clients’ managed assets are maintained by a qualified custodian; 2. Have a reasonable belief, after due inquiry, that the qualified custodian will deliver an account statement directly to the client at least quarterly; 3. Confirm that account statements from the custodian contain all transactions that took place in the client’s account during the period covered and reflect the deduction of advisory fees; and 4. Obtain a surprise audit by an independent accountant on the clients’ accounts for which the advisory firm is deemed to have custody. However, the rules governing the direct debit of client fees and SLOAs exempts us from the surprise audit rules if certain conditions (in addition to steps 1 through 3 above) are met. Those conditions are as follows: 1. When debiting fees from client accounts, we must receive written authorization from clients permitting advisory fees to be deducted from the client’s account. 2. In the case of SLOAs, we must: (i) confirm that the name and address of the third party is included in the SLOA, (ii) document that the third-party receiving the transfer is not related to our firm, and (ii) ensure that certain requirements are being performed by the qualified custodian. 14  The qualified custodian that is selected by a client maintains actual physical custody of client assets. Client account statements from custodians will be sent directly to each client to the email or postal mailing address that is provided to the qualified custodian selected by the client. Clients are encouraged to compare information provided in reports or statements received by our firm with the account statements received from their custodian for accuracy. In addition, clients should understand that it is their responsibility, not the custodian’s, to ensure that the fee calculation is correct. If client funds or securities are inadvertently received by our firm, they will be returned to the sender immediately, or within three (3) business days. We encourage our clients to raise any questions with us about the custody, safety or security of their assets. The custodians we do business with will send Clients independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. Item 16: Investment Discretion DKCM provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, DKCM generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Clients will receive a quarterly statement directly from the custodian and can obtain daily and monthly statements directly from their account page on the custodian’s website. Clients should carefully review those statements for accuracy. Item 17: Voting Client Securities (Proxy Voting) DKCM will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information Neither DKCM, nor its management, have any adverse financial situations that would reasonably impair the ability of DKCM to meet all obligations to its clients. Neither DKCM, nor any of its advisory persons, has been subject to bankruptcy or financial compromise. DKCM is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. 15