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Item 1 – Cover Page
200 1st Street, Suite 204
Neptune Beach, FL 32266
(904) 222-0280 Phone
(904) 212-0058 Fax
200 Mansell Court East, Suite 305
Roswell, GA 30076
(678) 222-3469 Phone
(678) 222-3401 Fax
10 Glenlake Parkway, Suite 130
Atlanta, GA 30328
www.demgt.com
February 11, 2026
This Brochure provides information about the qualifications and business practices of
Disciplined Equity Management, Inc (“DEM”). If you have any questions about the contents
of this Brochure, please contact us at (904) 222-0280 or ddavey@demgt.com. It is intended
to provide clients and prospective clients with an understanding of the investment advisory
services offered by DEM and to provide full and fair disclosure of any conflicts or potential
conflicts of interest associated with those services. At the request of a client, DEM may
provide investment advice or other services not discussed in this Brochure. In such cases,
any additional disclosures will be provided to the client as necessary. Clients can also refer
to their portfolio management agreement for information specific to the management of
their account.
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. Disciplined Equity
Management, Inc. is a registered investment adviser. Registration of an Investment Adviser
does not imply any level of skill or training. The oral and written communications of an
Adviser provide you with information about which you determine to hire or retain an
Adviser.
Additional information about Disciplined Equity Management, Inc. also is available on the
SEC’s website at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Investment Advisers are required to prepare a disclosure document (“Brochure”) that
describes the firm and its business practices. Pursuant to SEC rules, we are required to
update our Brochure at least annually and provide you with a summary of any material
changes since the previous annual amendment.
We have prepared this Brochure, dated February 11, 2026, in accordance with the annual
amendment requirement. There have been no material change since our last annual
Brochure dated February 14, 2025.
With this summary, we hereby offer to deliver a complete copy of our Investment Adviser
Brochure upon your request at any time during the year. You may request our Brochure at
any time by contacting Don Davey, at 904-222-0280 or ddavey@demgt.com.
Additional information about Disciplined Equity Management, Inc. is available at
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons
affiliated with Disciplined Equity Management, Inc. who are registered as investment adviser
representatives of Disciplined Equity Management, Inc.
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Item 3 – Table of Contents
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Item 1 – Cover Page
...................................................................................................................... 3
Item 2 – Material Changes
.................................................................................................................... 4
Item 3 – Table of Contents
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Item 4 – Advisory Business
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Item 5 – Fees and Compensation
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Item 6 – Performance-Based Fees and Side-By-Side Management
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Item 7 – Types of Clients
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9 – Disciplinary Information
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Item 10 – Other Financial Industry Activities and Affiliations
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Item 11 – Code of Ethics
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Item 12 – Brokerage Practices
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Item 13 – Review of Accounts
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Item 14 – Client Referrals and Other Compensation
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Item 15 – Custody
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Item 16 – Investment Discretion
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Item 17 – Voting Client Securities
Item 18 – Financial Information
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Item 4 – Advisory Business
Donald V. Davey formed Disciplined Equity Management, Inc. in 2002. DEM provides
discretionary investment supervisory services to individuals, trusts, estates, small business
owners, pension plans and charitable entities.
Each client account is managed according to the specific goals and objectives of the client, as
stated in the Investment Policy Statement signed by the client. Therefore, even when using
the same investment strategy for more than one client, not all client accounts will necessarily
hold identical positions. Any restrictions imposed on the management of the account must
be included in the Investment Policy Statement.
DEM offers the following investment strategies:
Individual Stock Strategies:
The US Large-Cap Growth Strategy selects US large-capitalization stocks with
above-average long-term and short-term earnings and price trends. The goal
of the strategy is to provide long-term capital growth.
The US Large-Cap Value Strategy selects US large-capitalization stocks with
above-average dividend yields and financial strength. The goal of the strategy
is to provide a rising dividend stream in addition to participation in the long-
term growth of equities.
The Blue Chip Core Portfolio is an equal blend of the Large-Cap Growth and
Large-Cap Value Strategies.
Mutual Fund and ETF Strategies:
DEM may either replace or complement the individual stock strategies with
no-load equity and fixed-income mutual funds and/or exchange-traded funds
(ETFs). DEM primarily utilizes the Dimensional Fund Advisors family of funds
to implement the mutual fund strategies.
Separately Managed Accounts (SMA):
DEM may elect to engage a sub-adviser/co-adviser to manage a particular
strategy within a client’s portfolio through the custodian’s SMA platform. An
SMA would primarily be used for taxable accounts of sufficient size that could
benefit from greater diversification and tax management. DEM selects
strategies offered by Dimensional Fund Advisors which employ the same low-
cost, low turnover, high diversification philosophy they follow in their mutual
funds and ETFs.
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DEM provides financial planning services to asset management clients. These services are
included in the investment advisory services offered and are not subject to additional fees or
execution of a separate contract.
As of December 31, 2025, DEM has discretionary assets under management of approximately
$520,953,831. DEM does not manage any non-discretionary assets.
Investment Advice Specific to Retirement Account Rollovers
When we provide investment advice regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest
and not put our interest ahead of yours. Under this special rule’s provisions, we must:
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Meet a professional standard of care (give prudent advice)
Never put our financial interests ahead of our clients (give loyal advice)
Avoid misleading statements about conflicts of interest, fees, and investments
Follow policies and procedures designed to ensure that we give advice in client’s best
interest
Charge no more than is reasonable for our services
Give you basic information about our conflicts of interest.
Item 5 – Fees and Compensation
The standard advisory fee charged by DEM for portfolio management is as follows:
Asset Value of the Account:
Up to $3 million
$3million to $5 million
Above $5 million
Quarterly Fee
0.375%
0.250%
0.1875%
Clients pay DEM a fee based on the value of assets in their account. Fees are charged
quarterly in arrears based on the value of the account on the last day of the quarter and
adjusted for material cash flows. While DEM intends to charge fees in accordance with the
standard fee schedule in place at the time of executing the portfolio management agreement,
fees are subject to negotiation and may vary from the standard schedules to reflect
circumstances that apply to a specific client account. The fee schedule, and any applicable
terms and conditions, is stated in the client’s portfolio management agreement.
The advisory fee covers only the portfolio management and advisory services provided by
DEM and does not include brokerage commissions, mark-up and mark-downs, exchange
fees, dealer spreads or other costs associated with the purchase and sale of securities,
custodian fees, transfer fees, wire fees, interest, taxes, or other account expenses. All fees
paid to DEM for investment advisory services are separate and distinct from the fees and
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expenses charged by mutual funds or in conjunction with internal expenses associated with
exchange-traded funds. The client will be solely responsible, directly or indirectly, for these
additional expenses. If DEM chooses a third-party manager to manage all or a portion of the
client’s portfolio through a Separately Managed Account, the client will pay an advisory fee
to the third-party manager separate from the advisory fee paid to DEM. DEM will disclose
the additional fees to the client prior to causing the client to incur such fees.
DEM does not receive any portion of the additional fees described above. Refer to Item 12
for a detailed discussion of brokerage practices.
Clients may, but are not required to, grant DEM the authority to debit advisory fees directly
from the clients’ accounts. If the client authorizes DEM to debit fees, DEM is deemed to have
custody of the client’s funds. Clients will receive a statement, usually monthly but no less
than quarterly, directly from their account custodian. DEM urges clients to review the
information on the statement for accuracy and compare the information to any reports
received directly from DEM. Please refer to Item 15 of this document for additional
disclosures relating to Custody.
A client can terminate the portfolio management agreement with 30 days written notice.
Any fees due will be payable through the date of termination.
Item 6 – Performance-Based Fees and Side-By-Side Management
DEM does not charge any performance-based fees.
Item 7 – Types of Clients
DEM provides discretionary investment supervisory services to individuals, trusts, estates,
small business owners, pension plans and charitable entities.
The minimum account size for new clients is $1 million. DEM reserves the right to waive this
minimum.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
DEM uses fundamental analysis and concepts derived from modern portfolio theory to
construct diversified portfolios using a low-cost, passive, asset allocation strategy.
Investing in securities involves risk of loss that clients should be prepared to bear. DEM uses
its best judgment and good faith efforts in providing advisory services to clients. DEM cannot
warrant or guarantee any particular level of account performance, or that an account will be
profitable over time. Not every investment decision or recommendation made by DEM will
be profitable. Investments in securities are subject to various market, currency, inflation,
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economic, political and business risks, which are briefly described below. DEM attempts to
minimize these risks by recommending diversified portfolios constructed to meet the
specific goals and objectives of clients.
• Market Risk:
Investments are subject to risk, including the possibility of a loss of
principal. Fluctuations in the value of an investment may be caused by external
factors independent of an investment’s particular underlying circumstances.
Interest-rate Risk:
•
Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
Inflation Risk:
•
High inflation may adversely affect future purchasing power.
• Currency Risk:
Foreign investments are subject to fluctuations in the value of the
dollar versus the local currency where the investment is made.
• Reinvestment Risk:
Reinvestment risk occurs when proceeds from an investment
may be reinvested at lower prevailing rates.
• Business Risk:
Business risks are associated with a particular industry or a
particular company within an industry.
• Liquidity Risk:
Liquidity risk occurs when there is a possibility an investment
cannot be readily converted to cash.
• Financial Risk:
Excessive borrowing to finance a business’ operations increases the
risk of profitability, because the company must meet the terms of its obligations in
good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of DEM or its management.
DEM has no disciplinary actions to disclose.
Item 10 – Other Financial Industry Activities and Affiliations
Don Davey is a partial owner of several privately held restaurant franchise companies. DEM
does not recommend clients invest in this corporation or in any other partnership or
corporation owned or partially owned by the principals of Disciplined Equity Management,
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Inc. Don’s time spent on business operations relating to this company does not have a
material effect on DEM’s operations.
Don Davey participates in other business ventures, opportunities or arrangements in which
clients may be involved. However, Don does not recommend these investments as part of
the advisory services offered by DEM. Typically, these other businesses are operating
businesses and are not related to the securities industry. These arrangements are outside of
the scope of the investments selected on behalf of clients.
Item 11 – Code of Ethics
DEM has adopted a Code of Ethics for the purpose of instructing its personnel in their ethical
obligations and to provide rules for their personal securities transactions. DEM and its
personnel owe a duty of loyalty, fairness and good faith towards their clients, and the
obligation to adhere not only to the specific provisions of the Code, but to the general
principles that guide the Code. In order to detect any conflicts of interest with regard to
personal trading by principals and employees, DEM requires all Access Persons to submit
personal securities holdings reports within 10 days of becoming an Access Person and
annually thereafter, and personal securities transaction reports within 30 days of the end of
each calendar quarter.
DEM employees are permitted to buy or sell securities that are also recommended to clients
provided they conduct their personal trading in a manner that does not create a conflict of
interest with a client, or otherwise take unfair advantage of the client relationship. Employee
accounts managed by DEM could trade at the same time as clients and in the same securities
as clients provided that, in accordance with DEM’s brokerage practices, each account
participating in the trade receives the average price of all shares traded on behalf of DEM to
ensure allocations are fair and equitable.
DEM will provide a copy of the Code of Ethics to any client or prospective client upon
request.
Item 12 – Brokerage Practices
DEM recommends clients maintain accounts at Charles Schwab & Co, Inc. The reason for
preferring Schwab is their discounted commission rates, favorable margin rates, availability
of no-load mutual funds, electronic trading, daily transaction downloads, and dedicated
service team. Not all advisors require the use of a particular custodian or broker/dealer.
DEM receives no fees or compensation for recommending Schwab, but receives other
benefits as described in Item 14.
DEM executes client trades through the account custodian, which is Schwab for a large
majority of client accounts. DEM regularly assesses the services provided by Schwab to
determine that the reasonableness of commissions is consistent with their ability to provide
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quality services to DEM and its clients. DEM believes that, in consideration of all services
provided by Schwab, including but not limited to commission rates and other fees, Schwab
is providing overall execution quality consistent with DEM’s duty to seek best execution for
its clients.
Clients may direct DEM to use the services of a specific broker/dealer. However, DEM may
decline to accept an account if the client’s request is inconsistent with DEM’s investment
approach. If DEM accepts an account subject to client direction, DEM may not be able to
attain best execution of client transactions. Directed transactions could result in additional
costs to the client.
DEM may choose to, but is not required to, aggregate client orders consistent with its duty
to seek best price and execution. Clients participating in an aggregated order will receive
the average price of all transactions executed on a pro rata basis. If an order is partially filled,
shares will be allocated pro rata based on the client’s initial participation in the transaction.
To the extent that the limited availability of a security would result in a de minimis allocation,
DEM may exclude one or more accounts from participating in the order and select an
alternative allocation method provided that such method is fair and equitable to all client
accounts over time.
DEM manages client portfolios based on the specific objectives of each client. In some cases,
it is advantageous to implement a client’s asset allocation across all their household
accounts. Other times, the client’s current financial condition and objectives would warrant
that each account separately adhere to the overall portfolio allocation. In the latter case,
clients will likely incur more transaction charges; however, we believe the costs are
reasonable and necessary in pursuit of the long term financial goals.
Item 13 – Review of Accounts
Don Davey, as Portfolio Manager and Principal of DEM, reviews all portfolios to ensure
compliance with each client’s goals and objectives. Portfolio reviews and any necessary
rebalancing are conducted quarterly. Additional reviews occur more frequently due to such
factors as inflows to or outflows from an account, significant market movements, or other
factors as deemed necessary by the Portfolio Manager.
Upon request, clients are furnished quarterly reports from DEM which could include
holdings, market value and/or performance.
Schwab provides monthly statements to the client detailing account activity and market
value of securities held. DEM urges clients to compare information contained in reports
provided by DEM with the account statements received directly from the account custodian.
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Item 14 – Client Referrals and Other Compensation
DEM has access to free or discounted research materials from broker-dealers and/or third-
party providers in exchange for having client assets custodied at Schwab. Schwab provides
free industry information that does not qualify as research, such as newsletter or other
publications pertaining to compliance, marketing, practice management, etc. In addition,
events such as workshops or conferences are occasionally offered to DEM at reduced cost or
no cost. These benefits are not provided on the basis of client transactions. Under no
circumstances do any clients pay additional fees or commissions in order to obtain these
products or services.
Item 15 – Custody
DEM is deemed to have custody of client funds because investment advisory fees are directly
debited from client accounts. Debiting of fees is done pursuant to authorization provided by
each client. Usually monthly, but no less than quarterly, clients receive account statements
directly from the custodian of their account. Custodial statements include account holdings,
market values and any activity that occurred during the period, including the deduction of
investment advisory fees. DEM urges clients to compare information contained in reports
provided by DEM with the account statements received directly from the account custodian.
Differences in portfolio value may occur due to various factors, including but not limited to:
(1) unsettled trades; (2) accrued income; (3) pricing of securities; and/or, (4) dividends
earned but not received.
DEM is also deemed to have custody of client assets as a result of clients authorizing DEM to
distribute assets from their accounts to a specific named recipient in accordance with a
standing letter of instruction. DEM intends to comply with the SEC No-Action Letter dated
February 21, 2017 (Investment Adviser Association) allowing firms who comply with all of
the provisions of the no-action letter to forego the annual surprise custody examination
requirement with respect to those assets.
For all other accounts which DEM is deemed to have custody, and for which there is no
exemption from the requirement to conduct an annual surprise custody examination, DEM
will engage the services of an independent CPA firm to examine those accounts in accordance
with the rules, regulations and guidance outlined in federal securities laws.
Item 16 – Investment Discretion
DEM manages client portfolios on a discretionary basis. Clients grant DEM discretion over
their account by providing authorization in the portfolio management agreement. This
discretionary authority authorizes DEM to determine the type and amount of securities to
be bought or sold. Investment discretion is limited only by specific instructions, guidelines
and/or mandates provided by clients in writing and to which DEM agrees.
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Item 17 – Voting Client Securities
DEM does not take action or render any advice with respect to voting of proxies for the
securities in client accounts. DEM will have no obligation to render advice or take any action
with respect to any securities subject to any legal proceedings, such as class action lawsuits
or bankruptcy. Clients will receive all proxies and other solicitations directly from their
custodian.
Item 18 – Financial Information
Registered investment advisers are required to provide certain financial information or
disclosures about DEM’s financial condition. DEM has no financial commitment that impairs
its ability to meet contractual and fiduciary commitments to its clients, and has not been the
subject of any bankruptcy proceeding.
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