F&V CAPITAL MANAGEMENT, L.L.C.

Part 2A of Form ADV: Firm Brochure F&V Capital Management, LLC 2300 Glades Road Ste. 220W Boca Raton, FL 33431 Telephone: 561-208-1081 Email: HTR@FVCM.US Web Address: www.FVCM.US December 31, 2025 This brochure provides information about the qualifications and business practices of F&V Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at 561-208-1081 or HTR@FVCM.US. 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 with the SEC or with any state securities authority does not imply a certain level of skill or training. Additional information about F&V Capital Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 146399.  Item 2 Material Changes This Firm Brochure, dated December 31, 2025, provides you with a summary of F&V Capital Management, LLC's (FVCM) advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows. 1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm’s fiscal year end (FYE) of December 31st. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item. 2. Material Changes: Should a material change in our operations occur, depending on its nature we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business. The following summarizes new or revised disclosures based on information previously provided in our Firm Brochure dated December 31, 2024: There have been no material changes since our last brochure update. 2  Item 3 Table of Contents Page Item 1 Cover Page Item 2 Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information 1 2 3 4 6 8 8 9 11 11 11 13 14 15 15 15 16 16 3  Item 4 Advisory Business F&V Capital Management, LLC is a SEC-registered investment adviser with its principal place of business located in Boca Raton, FL. F&V Capital Management, LLC began conducting business in March 2008. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).  KMMP, Inc., an S-Corp 100% owned by Karin M. Mueller-Paris, Partner  HTR3, Inc., an S-Corp 100% owned by H. Terrence Riley III, Partner F&V Capital Management, LLC offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our information gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker- dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Foreign issuers  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  United States governmental securities 4   Options contracts on securities  Options contracts on commodities  Interests in partnerships investing in real estate  Interests in partnerships investing in oil and gas interests Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. MUTUAL FUND PORTFOLIO MANAGEMENT F&V Capital Management, LLC is the investment advisor to a Luxembourg-based mutual fund known as the FVCM U.S. Equity Fund, which is registered for sale in Germany, Austria and Luxembourg. The fund has not been registered under the Investment Company Act of 1940 and is not available to U.S. Investors. F&V Capital Management, LLC serves as the investment manager to the Mutual Fund, and continuously manages the fund assets based on the investment goals and objectives as outlined in the Mutual Fund's prospectus. The decision to invest in this fund by qualified non-U.S. investors should be made with the information contained in the prospectus or in other literature on the fund. Those documents are the sole basis for the decision to buy this fund and can be obtained from F&V Capital Management, LLC, 2300 Glades Road, Ste. 220W, Boca Raton, FL 33431, or DZ BANK AG, Platz der Republik 6, 60325 Frankfurt am Main, Germany. Prior to making any investment in the fund, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Fund. PUBLICATION OF PERIODICALS F&V Capital Management, LLC periodically distributes written market commentaries which provide general information on various financial topics including, but not limited to, global and U.S. economic conditions, market trends, etc. FVCM may also periodically provide clients with a company report explaining the investment rationale for an investment. The information provided does not purport to meet the objectives or needs of any individual. These reports are distributed free of charge to our advisory clients. 5  FINANCIAL PLANNING SERVICES F&V Capital Management, LLC provides financial planning services to the firm’s clients, upon request, as a service provided free of charge. As part of this service, a financial advisor will assess the client’s financial condition, including factors such as income, expenses, assets, liabilities, and existing investments. The advisor will work with clients to establish financial goals. Such goals may involve tax planning, retirement planning, insurance needs and estate planning. The advisor will make recommendations on strategies that align with the clients’ goals and risk profile. AMOUNT OF MANAGED ASSETS As of December 31, 2025, FVCM was actively managing $557,811,265 of clients' assets, with $540,562,787 on a discretionary basis and $17,248,478 on a non-discretionary basis. Item 5 Fees and Compensation INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT FEES Our annual fees for Investment Supervisory Services are based upon a percentage of assets under management and generally range from 0.50% to 2.50% depending on assets under management and other factors. On a case-by-case basis, F&V Capital Management, LLC determines an appropriate fee structure based on the size, complexity and investment objectives of the client's account. Fee arrangements may include a fee based on a percentage of assets under management or a combination of a management fee and a performance-based fee. The terms and conditions of the fee structure are mutually agreed upon prior to entering into an advisory agreement. Account Management Fees: F&V Capital Management, LLC typically charges a fee for account management that is calculated and paid as a percentage of the assets under management. The Account Management Fee is calculated at an annual rate not to exceed 2.50%, excluding performance-based fees. Fees are calculated on a quarterly basis, and are payable in arrears based on the value of the account at the beginning of each billing period. The Account Management Fee is prorated for periods less than a full billing cycle and adjusted to cover any additional contributions made during that period. Minimum fees may apply. Managed Account Incentive Fees: Certain Managed Accounts may pay F&V Capital Management, LLC performance-based compensation ("Incentive Fees"). The Incentive Fee is calculated based on a percentage of the net profits of the account(s) on a basis mutually agreed upon with the client. F&V Capital Management, LLC's incentive fee is up to 20% of the net profits above the benchmark return. Such incentive fees are received in addition to a base fee which is a fixed percentage of assets 6  under management. Such clients who elect to terminate their contracts will be charged a performance- based fee based on the performance of the account for the measuring period going back from the termination date and pro-rated from the date on which the performance-based fee was last assessed. In measuring the Managed Account client's assets for the calculation of performance-based fees, F&V Capital Management, LLC includes the realized capital losses and unrealized capital losses of securities over the period being measured, as well as both realized and unrealized capital gains. The client must understand the performance-based fee method of compensation and its risks prior to entering into a management contract with us. PERFORMANCE-BASED FEES WILL ONLY BE CHARGED IN ACCORDANCE WITH THE PROVISIONS OF REG. 205-3 OF THE INVESTMENT ADVISERS ACT OF 1940 AND/OR APPLICABLE STATE REGULATIONS. THE FEES WILL NOT BE OFFERED TO ANY CLIENT RESIDING IN A STATE IN WHICH SUCH FEES ARE PROHIBITED. Pursuant to an order by the Securities and Exchange Commission (SEC) on June 17, 2021, performance-based fees may be offered only to Qualified Clients with a minimum of $1,100,000 of assets under management, or a net worth of more than $2,200,000. These amounts are expected to be increased again on or about May 1, 2026. FVCM’s ability to offer performance-based fees will remain consistent with all future adjustments made by the SEC. Account size may be negotiable under certain circumstances. F&V Capital Management, LLC may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although F&V Capital Management, LLC has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by- client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. We 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 and friends of associated persons of our firm. MUTUAL FUND PORTFOLIO MANAGEMENT FEES F&V Capital Management, LLC charges an asset-based fee for this service. The fee arrangement, termination, and refund policies are described in the Mutual Fund's prospectus and other literature on the fund. Portfolio management clients of our firm who also invest in the FVCM US Equity Fund will pay only those fees charged to investors by the Mutual Fund, i.e., the value of the client's investment in the Mutual Fund is excluded from any quarterly portfolio management fee calculation for individually managed accounts in the United States. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either 7  party, for any reason upon receipt of 30 days written notice. FVCM charges management fees in arrears. Therefore, upon termination of any account, any unpaid fees will be billed to the client upon notice of termination of an advisory agreement. Mutual Fund Fees: All fees paid to F&V Capital Management, LLC for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any charges imposed by a broker dealer chosen by the investment manager in order to execute transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1200 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management PERFORMANCE-BASED FEES As we disclosed in Item 5 of this Brochure, our firm may accept a performance-based fee for certain client(s). Such a performance-based fee is calculated based on a share of capital gains on or capital appreciation of the assets of the client. To qualify for a performance-based fee arrangement, a client must meet minimum amounts of assets under management or demonstrate a minimum net worth as determined by the provisions of Rule 205-3of the Advisers Act. Clients should be aware that a performance-based fee arrangement may create an incentive for a manager to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Furthermore, as some clients do not pay performance-based fees, a manager may have an incentive to favor accounts that do pay such fees because compensation from these clients is more directly tied to the performance of their accounts. Item 7 Types of Clients F&V Capital Management, LLC provides advisory services to the following types of clients: 8   Individuals (other than high net worth individuals)  High net worth individuals  A Luxembourg-based mutual fund not available to U.S. citizens  Corporations or other businesses not listed above  Trusts As previously disclosed in Item 5, our firm has established initial minimum account requirements, based on the nature of the service(s) being provided. Furthermore, our firm has certain minimum account requirements to maintain an account, based on the nature of the service(s) being provided. Clients and potential clients are encouraged to discuss their individual needs and circumstances with a principal of FVCM in order to determine if such minimums apply to their specific needs. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt 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 company itself) to determine if the company 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. This 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 stock. Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate measurements of a company’s quantifiable data, such as the value of a share price or earnings per share, and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement, and predict changes to share price based on that data. A risk is using qualitative analysis is that our subjective judgment may prove incorrect. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an 9  appropriate ratio of equity securities, fixed income and other securities, and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies 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 may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically we employ this strategy when:  we believe the securities to be currently undervalued, and/or  we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short- term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as potentially less favorable tax treatment of short-term capital gains. Short sales. We borrow shares of a stock or ETF for your portfolio from someone who owns the stock or ETF on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On a future date, we buy the same securities and return them to the original owner. We engage in short selling as a means to hedge long investment positions or based on our determination that the stock or ETF is expected to decline in price after we have borrowed the shares. If we are correct and the share price has gone down after purchase, the client account realizes the profit on the 10  short position. Conversely, if the price of the stock or ETF rises, a loss would be realized. Margin transactions. Upon your direction, we will purchase stocks for your portfolio with money borrowed through your brokerage account. This allows you to purchase more stock than you would be able to with your available cash, and allows us to purchase stock without selling other holdings. Risk of Loss. Securities investments are not guaranteed and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Our firm and our related persons are not engaged in other financial industry activities and have no other industry affiliations. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. F&V Capital Management, LLC and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and record keeping provisions. F&V Capital Management, LLC's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non- public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to HTR@FVCM.US, or by calling us at 561-208-1081. 11  As previously disclosed in this brochure, F&V Capital Management, LLC is the investment adviser to an affiliated mutual fund. Please refer to "Advisory Business" (Item 4) and "Fees and Compensation" (Item 5) for a detailed explanation of this relationship and important conflict of interest disclosure. 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. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, thereby preventing such employee(s) from benefiting from transactions placed on behalf of advisory accounts. We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro- rata, with each account paying the average price. Our employee accounts will be included in the pro- rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any IPO or private placement investments by related persons of the firm. 5. We maintain lists of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee. 6. We have established procedures for the maintenance of all required books and records. 7. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 8. We require delivery and acknowledgment of the Code of Ethics by each supervised person of our firm. 12  9. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 10. Any individual who violates any of the above restrictions may be subject to termination. Item 12 Brokerage Practices F&V Capital Management, LLC, as part of its Investment Management Agreement, requires that clients provide us with the authority to determine the broker-dealers or other issuers to use for client transactions, under circumstances determined by the firm. Clients must include any limitations on this discretionary authority in Schedule A of the Investment Management Agreement. Clients may change/amend these limitations as required, provided that such amendments are provided to us in writing. F&V Capital Management, LLC will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate 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. Block trading may allow us to execute equity trades in a timely, more equitable manner, at an average share price. F&V Capital Management, LLC will typically aggregate trades among clients whose accounts are under custody at the firm's chosen custodian, RBC Capital Markets, LLC (RBC), and execute those trades through RBC's trading desk. F&V Capital Management, LLC's block trading policy and procedures are as follows: 1) Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with F&V Capital Management, LLC, or our firm's order allocation policy. 2) The portfolio manager must determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. 3) The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable F&V Capital Management, LLC to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. 4) Prior to execution of an aggregated order, written order documentation must be completed which identifies each client account participating in the order and the proposed allocation of the order, upon completion, to those clients. 5) If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. 13  6) Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order, and must share in the commissions on a pro rata basis in proportion to the client's participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. 7) If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the Chief Compliance Officer. 8) F&V Capital Management, LLC's client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. 9) Funds and securities for aggregated orders are clearly identified on F&V Capital Management, LLC's records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. 10) No client or account will be favored over another. Officers of FVCM hold a "Best Execution" meeting each year to review broker-transaction performance, which includes a review of information including the quality of transaction execution and the amount of commissions paid to such brokers. FVCM does pay commissions to brokers for transactions at a higher rate than is otherwise available in the marketplace. These additional commissions, sometimes referred to as "soft dollars," are in compensation for research and other information provided by the brokers. The firm pays such commissions with the knowledge and understanding that the research and information received is to the benefit of the firm's clients. FVCM does not pay soft dollars for any other third party services or products. Item 13 Review of Accounts INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least monthly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by: Karin Mueller-Paris, Partner; Walter Manhart, Advisor, and Juergen Streng, Advisor and Nina Sukholenko, Advisor. REPORTS: Clients receive monthly statements from the custodian of the assets detailing transactions, securities positions held, cash balances and other holdings. Furthermore, confirmations of individual transactions are provided to clients when the client desires such information. 14  MUTUAL FUND PORTFOLIO MANAGEMENT REVIEWS: F&V Capital Management, LLC continually reviews and monitors the Mutual Fund's holdings in accordance with the investment objectives as detailed in the Fund Prospectus. REPORTS: Clients should refer to the Fund Prospectus for information regarding regular reports to the fund by F&V Capital Management, LLC. Item 14 Client Referrals and Other Compensation CLIENT REFERRALS We do not engage solicitors, promoters, or any third parties for client referrals. Our firm does not pay referral fees or any other form of compensation for client referrals. Additionally, we do not receive any economic benefits, such as sales awards or other prizes, from non-clients for providing investment advice or other advisory services to our clients. Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. Clients are sent a separate invoice from FVCM with details regarding the fee calculation. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their invoices and the custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in the calculation or their statement. Our firm does not have actual or constructive custody of client accounts. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client:  determine the security to buy or sell; and/or  determine the amount of the security to buy or sell  determine broker or dealer used for securities transactions 15   determine commission rate to be paid in securities transactions Clients give us discretionary authority when they sign a discretionary agreement with our firm, and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 17 Voting Client Securities We vote proxies for all client accounts; however, the client always has the right to vote if so desired. Clients can exercise this right by instructing us in writing to not vote proxies in their account. We will vote proxies in the best interests of its clients and in accordance with our established policies and procedures. Our firm will retain proxy voting books and records for the requisite period of time, a record of how votes are cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. If our firm has a conflict of interest in voting a particular action, we will notify the client of the conflict and retain an independent third-party to cast a vote. Clients may obtain a copy of our complete proxy voting policies and procedures by contacting any employee of the firm by telephone, email, or in writing. Clients may request, in writing, information on how proxies for his/her shares were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for his/her account(s), we will promptly provide such information to the client. We will not act on behalf of the client in legal proceedings involving companies whose securities are held in the client’s account(s). However, the firm will review legal documents, including, but not limited to, the filing of "Proofs of Claim" in class action settlements, if requested by the client. FVCM generally does not accept instructions according to particular criteria (for example, to always vote with management, or to vote for or against a proposal to allow a so-called "poison pill" defense against a possible takeover). Client's wishing to limit voting in a specific way are asked to contact the firm to discuss whether the best course of action is for FVCM to modify its voting or whether it is best for the client to vote on his or her own behalf. Item 18 Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm that maintains discretionary authority, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. F&V Capital Management, LLC has no additional financial circumstances to report. F&V Capital Management, LLC has not been the subject of a bankruptcy petition at any time. 16  17