Montgomery Capital Advisors LLC

Page 1 Item 1 Contact Information MONTGOMERY CAPITAL ADVISORS, LLC FORM ADV PART 2A FIRM BROCHURE June 16, 2026 250 West 55th Street, 17th Floor New York, NY 10019 Telephone: (212) 201-7911 Toll Free: (800) 883-8596 Website: www.montcapital.net Mark J. Montgomery Chief Executive Officer, Managing Director and Senior Portfolio Manager Mark@montcapital.net Stephen Kinsella Chief Compliance Officer, Chief Financial Officer, Chief Operating Officer and Director of Operations Steve@montcapital.net CRD No. 138148 This brochure provides information about the qualifications and business practices of Montgomery Capital Advisors, LLC. If you have any questions about the contents of this brochure, please contact Montgomery Capital Advisors, LLC at (212) 201-7911. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Registration as an investment adviser with the SEC does not imply a certain level of skill or training.  Page 2 Item 2 Material Changes This brochure, dated June 16, 2026, has been revised to update and clarify disclosures regarding: • Advisory fees and fee billing practices; • Brokerage practices and best execution; • Custody and advisory fee deduction authority; • Code of Ethics and personal trading procedures; • Client reporting and account reviews; • Investment discretion; • Client referrals and compensation arrangements; • Form ADV disclosure and compliance review procedures; • Business continuity and succession planning procedures; and • Other regulatory disclosures. These revisions were made to ensure that the brochure accurately reflects Montgomery Capital Advisors, LLC's current business practices, supervisory procedures, compliance controls, and regulatory disclosures.  Page 3 Item 3 Table of Contents Page 1 Cover Page Contact Information Page 2 Material Changes Page 3 Table of Contents Page 4 Advisory Business Pages 5-5A Fees and Compensation Page 6 Performance-Based Fees and Side-by-Side Management Page 7 Types of Clients Page 8 Methods of Analysis, Investment Strategies and Risk of Loss Page 9 Disciplinary Information Page 10 Other Financial Industry Activities and Affiliations Page 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Page 12 Brokerage Practices Page 13 Review of Accounts Page 14 Client Referrals and Other Compensation Page 15 Custody Page 16 Investment Discretion Page 17 Voting Client Securities Page 18 Financial Information Page 19 Requirements for State-Registered Advisers (Not Applicable) Page 20 Personnel  Page 4 Item 4 Advisory Business Montgomery Capital Advisors, LLC ("MCA") is an SEC-registered investment adviser providing discretionary portfolio management services to individuals, trusts, and estates. MCA offers personalized investment management based upon each client's financial circumstances, investment objectives, risk tolerance, liquidity needs, and other relevant factors. This brochure provides information about the qualifications and business practices of MCA. If you have any questions regarding the contents of this brochure, please contact Mark J. Montgomery, Chief Executive Officer and Managing Director. The information contained in this brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Registration with the SEC does not imply a certain level of skill or training. MCA provides investment supervisory services, which include ongoing portfolio management and continuous investment advice tailored to each client's individual needs and objectives. Through discussions with clients, MCA develops an investment strategy and manages portfolios consistent with the client's financial goals and investment policy. MCA manages client accounts on a discretionary basis pursuant to written advisory agreements and client authorization. Under discretionary authority, MCA is authorized to determine the securities to be purchased or sold and the amount of securities to be bought or sold without obtaining client approval prior to each transaction. Clients may impose reasonable restrictions on investing in certain securities or types of securities, subject to acceptance by MCA. Client portfolios may include individual equities, corporate debt securities, municipal securities, certificates of deposit, mutual funds, exchange-traded funds ("ETFs"), and other investment products deemed appropriate for the client's investment objectives and circumstances. Investment selections are based upon factors including a client's investment objectives, risk tolerance, time horizon, liquidity needs, diversification considerations, economic conditions, and overall suitability. Clients retain ownership of all securities and assets held in their accounts, which are maintained with a qualified independent custodian. As of December 31, 2025, MCA managed approximately $130,138,998. in regulatory assets under management on a discretionary basis on behalf of approximately 51 clients.  Page 5 Item 5 Fees and Compensation Montgomery Capital Advisors, LLC ("MCA") is an independent fee-only registered investment adviser. Advisory fees paid by clients are MCA's sole source of compensation. MCA does not receive commissions, sales charges, referral fees, or other compensation related to the purchase or sale of securities. MCA acts as a fiduciary and is obligated to place clients' interests ahead of its own. Advisory Fees The annual fee for portfolio management services is based upon a percentage of assets under management and is set forth in the client's advisory agreement. Advisory fees are calculated and billed quarterly in advance based upon the value of assets in the account as of the applicable valuation date. For fixed-income accounts, accrued interest is included in the account value used for calculating advisory fees. Clients should be aware that accrued interest included in MCA's advisory fee calculation may not appear on custodial statements until paid and reflected by the custodian. MCA's current fee schedule is as follows: Assets Under Management Annual Fee 1.75% Up to $750,000 $750,000.01 to $5,000,000 1.50% $5,000,000.01 to $10,000,000 1.25% Over $10,000,000 Negotiable Fee Deduction Clients authorize MCA, pursuant to written authorization contained in the investment management agreement and related custodial documentation, to deduct advisory fees directly from their custodial accounts. This authority is limited solely to the deduction of advisory fees and does not authorize MCA to withdraw client assets for any other purpose. The qualified custodian sends account statements directly to clients at least quarterly showing all account transactions, including advisory fee deductions.  Page 5A Item 5A Fees and Compensation (Continued) Negotiability of Fees MCA may, in its sole discretion, negotiate advisory fees based upon factors such as account size, anticipated future assets, related account relationships, complexity of services, and other relevant considerations. As a result, similarly, situated clients may pay different fees. Calculation Advisory fees are not based upon a share of capital gains or capital appreciation of client assets and therefore do not constitute performance-based compensation under Section 205(a)(1) of the Investment Advisers Act of 1940. Termination of Advisory Relationship Either party may terminate the advisory agreement upon thirty (30) days' written notice. Upon termination, any prepaid advisory fees will be refunded on a pro rata basis for the portion of the billing period during which services were not provided. Clients may terminate their advisory agreement without penalty within five (5) business days after entering into the agreement. Clients may incur transaction costs, custodial fees, wire fees, mutual fund expenses, ETF expenses, or other charges imposed by third parties. Such charges are separate from and in addition to MCA's advisory fees. Mutual Fund and ETF Expenses All fees paid to MCA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds, exchange-traded funds ("ETFs"), and other investment vehicles. These expenses are described in the applicable prospectus or offering documents and are borne indirectly by investors. Clients should carefully review these expenses in conjunction with MCA's advisory fees when evaluating the overall cost of investing.  Pages 6 Item 6 Performance-Based Fees and Side-by-Side Management Montgomery Capital Advisors, LLC ("MCA") does not charge performance-based fees. Performance-based fees are fees based on a share of capital gains or capital appreciation of a client's assets. MCA does not engage in side-by-side management. Accordingly, MCA does not manage accounts that are subject to performance-based fees alongside accounts that are charged asset-based fees, and therefore does not have conflicts of interest associated with such arrangements.  Page 7 Item 7 Types of Clients Montgomery Capital Advisors, LLC ("MCA") provides investment advisory services primarily to individuals, trusts, and estates. MCA generally requires a minimum account size of $750,000 and a minimum annual advisory fee of $10,000. MCA may, in its sole discretion, waive or reduce these minimums based upon factors such as anticipated future assets, related account relationships, complexity of services provided, or other relevant considerations.  Page 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis: Montgomery Capital Advisors, LLC ("MCA") utilizes both fundamental and technical analysis in evaluating investment opportunities and managing client portfolios. Fundamental analysis involves evaluating factors such as a company's financial condition, earnings, management, competitive position, industry trends, and economic conditions. Technical analysis involves the review of market activity, price movements, trading volume, and other market indicators. Sources of information utilized by MCA may include, but are not limited to: • Financial newspapers and periodicals • Research reports prepared by third parties • Value Line reports • Corporate annual reports and regulatory filings • Prospectuses and offering documents • SEC filings and publicly available disclosures Investment Strategies: MCA primarily employs long-term investment strategies, generally involving securities held for one year or longer. Depending upon a client's objectives, market conditions, and investment circumstances, MCA may also engage in shorter-term purchases and sales of securities. Prior to providing investment advice, MCA obtains information regarding each client's financial situation, investment objectives, risk tolerance, liquidity needs, time horizon, and other relevant factors. Investment recommendations and portfolio management decisions are based upon this information. Risk of Loss: Investing in securities involves risk, including the possible loss of principal. Clients should be prepared to bear the risks associated with investing and understand that no investment strategy or portfolio management approach can guarantee a profit or protect against loss. The principal risks associated with MCA's investment strategies may include: • Market Risk – The risk that the value of securities will fluctuate due to changes in market conditions. • Interest Rate Risk – The risk that fixed-income securities may decline in value due to rising interest rates. • Credit Risk – The risk that an issuer of a debt security may be unable to meet its financial obligations. • Liquidity Risk – The risk that certain investments may be difficult to sell at a desirable price or time. • Inflation Risk – The risk that purchasing power may decline over time due to inflation. • Economic and Political Risk – The risk that economic developments, geopolitical events, governmental actions, or other external factors may adversely affect financial markets. • Currency Risk – The risk that investments with foreign exposure may be affected by fluctuations in currency exchange rates. While MCA seeks to manage these risks through diversification and ongoing portfolio monitoring, investment results cannot be guaranteed, and clients may experience losses, including the loss of principal.  Page 9 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 a client's evaluation of the adviser or the integrity of its management. Montgomery Capital Advisors, LLC has no legal or disciplinary events to disclose. In addition, Mark J. Montgomery and Stephen Kinsella, the firm's management persons, have no reportable legal or disciplinary events to disclose.  Page 10 Item 10 Other Financial Industry Activities and Affiliations Neither Montgomery Capital Advisors, LLC ("MCA") nor its management persons are registered representatives of a broker-dealer. Neither MCA nor its management persons receive compensation for the sale of securities, insurance products, or other investment products. MCA is an independent investment advisory firm and is not affiliated with any broker-dealer, investment company, private fund, insurance company, bank, accounting firm, law firm, pension consulting firm, commodity firm, or other financial services organization that would create a material conflict of interest requiring disclosure. MCA does not recommend or select other investment advisers for clients and does not maintain any material business relationships with other investment advisers. MCA does not compensate any person or entity for client referrals and does not receive compensation from any third party for referring clients to other professionals or service providers.  Page 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Montgomery Capital Advisors, LLC ("MCA") has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act of 1940. The Code of Ethics establishes standards of conduct and requires supervised persons to act in accordance with MCA's fiduciary duty to clients and applicable federal securities laws. The Code of Ethics is designed to promote honesty, integrity, professionalism, and compliance with fiduciary obligations, including the duty to place client interests ahead of the interests of MCA and its personnel. MCA's Code of Ethics addresses, among other things: • The fiduciary duty owed to clients; • Personal securities trading by supervised persons; • Conflicts of interest; • Protection of material nonpublic information; • Compliance with applicable securities laws and regulations; and • Reporting and review requirements for personal securities transactions and holdings. MCA and its supervised persons may buy or sell securities that are also recommended to, or purchased for, client accounts. This practice presents a potential conflict of interest because employees may have an incentive to trade for their own accounts. Access persons are required to report personal securities holdings and personal securities transactions in accordance with MCA's Code of Ethics and applicable regulatory requirements. MCA reviews personal trading activity through supervisory and compliance procedures designed to identify potential conflicts of interest and to promote compliance with fiduciary obligations and federal securities laws. To address these conflicts, MCA has adopted policies and procedures reasonably designed to ensure that client interests are placed first. These procedures include personal trading reviews, transaction monitoring, pre-clearance requirements when applicable, and ongoing compliance oversight. Employees are prohibited from engaging in fraudulent, deceptive, or manipulative practices and may not place their personal interests ahead of client interests. Clients may obtain a complete copy of MCA's Code of Ethics upon request and at no additional charge.  Page 12 Item 12 Brokerage Practices Montgomery Capital Advisors, LLC ("MCA") generally recommends that clients maintain their accounts with Charles Schwab & Co., Inc. ("Schwab"), a qualified custodian and broker-dealer. Clients are not required to use Schwab and may choose another qualified custodian. For discretionary accounts, MCA is authorized to place transactions through the client's selected custodian and broker-dealer. Clients may impose reasonable restrictions on MCA's discretionary authority by providing written instructions acceptable to MCA. Any modifications to such restrictions must be submitted in writing. MCA has a fiduciary duty to seek best execution for client transactions. In evaluating brokerage and custodial services, MCA considers a variety of factors, including execution capability, financial stability, custodial services, responsiveness, transaction costs, operational efficiency, available technology, and overall service quality. Although MCA generally recommends Schwab as custodian, MCA seeks best execution for client transactions and periodically reviews the quality, competitiveness, execution capability, custodial services, transaction costs, responsiveness, and overall services provided by Schwab and any other custodians utilized by clients. MCA conducts periodic best execution reviews as part of its ongoing fiduciary obligations and evaluates whether brokerage and custodial services continue to meet the needs of clients. Clients who direct MCA to use a custodian or broker-dealer other than Schwab should understand that transaction costs, execution quality, available services, operational capabilities, and administrative procedures may differ from those available through Schwab. MCA does not receive commissions, transaction-based compensation, referral fees, or other compensation from Schwab or any other broker-dealer in connection with client transactions. MCA's compensation consists solely of advisory fees paid by clients as described in this brochure. MCA generally enters transactions individually for client accounts. MCA may evaluate the use of trade aggregation or block trading where appropriate and consistent with client interests. When transactions are executed for multiple accounts, MCA seeks to allocate trades in a manner it believes is fair and equitable under the circumstances and consistent with its fiduciary obligations. MCA periodically reviews brokerage arrangements, execution quality, custodial services, and related practices as part of its compliance and best execution review processes.  Page 13 Item 13 Review of Accounts Client accounts are monitored on an ongoing basis and are reviewed periodically by Mark J. Montgomery, Chief Executive Officer and President of Montgomery Capital Advisors, LLC ("MCA"). Account reviews are conducted in light of each client's investment objectives, risk tolerance, financial circumstances, liquidity needs, time horizon, and any investment restrictions communicated to MCA. Significant changes in a client's objectives, financial condition, risk tolerance, or liquidity needs may result in portfolio adjustments Additional reviews may be performed when warranted by material changes in a client's circumstances or significant market, economic, political, or regulatory developments. Clients receive account statements directly from their qualified custodian, Charles Schwab & Co., Inc. ("Schwab"), on at least a monthly basis. These statements include information regarding account holdings, transactions, and account balances. In addition, MCA provides clients with quarterly portfolio and performance reports prepared through its portfolio accounting and reporting system, Advent APX. These reports may include portfolio holdings, account values, asset allocation information, performance results, and other relevant account information. Clients are encouraged to carefully review all reports received from MCA and compare them with the account statements provided directly by Schwab. The custodial statements provided by Schwab should be considered the official records of the client's account.  Page 14 Item 14 Client Referrals and Other Compensation Montgomery Capital Advisors, LLC ("MCA") does not receive compensation from any third party in connection with providing investment advisory services to clients. MCA does not pay cash or non-cash compensation, directly or indirectly, to any person or entity for client referrals, endorsements, testimonials, or solicitations. MCA does not receive referral fees, revenue sharing payments, commissions, or other compensation from broker-dealers, custodians, mutual fund companies, insurance companies, or other third parties in connection with client accounts or investment recommendations. Accordingly, MCA does not have any client referral arrangements or compensation-related conflicts of interest requiring disclosure under this Item.  Page 15 Item 15 Custody Montgomery Capital Advisors, LLC ("MCA") has authority to deduct advisory fees directly from client accounts pursuant to written authorization contained in the applicable investment management agreement. As a result, MCA is deemed to have limited custody of client assets under Rule 206(4)-2 of the Investment Advisers Act of 1940. Because MCA has authority to calculate and deduct advisory fees directly from client accounts, a conflict of interest exists because MCA has the ability to determine the amount of fees deducted. MCA addresses this conflict through written client authorization, supervisory review of fee calculations, periodic testing of advisory fee billing practices, and the delivery of independent custodial account statements directly to clients by the qualified custodian. Client assets are maintained with qualified custodians, including Charles Schwab & Co., Inc. ("Schwab"), which sends account statements directly to clients on at least a monthly basis. These statements reflect account holdings, transactions, account balances, and advisory fee deductions. Clients should carefully review the custodial statements they receive and compare them to any reports provided by MCA. The custodial statements provided by the qualified custodian should be considered the official records of the client's account. MCA does not maintain custody of client funds or securities beyond its limited authority to deduct advisory fees pursuant to written client authorization. MCA does not have authority to withdraw client assets for any purpose other than the deduction of earned advisory fees. MCA does not maintain Standing Letters of Authorization ("SLOAs"), participate in third-party money movement arrangements, accept authority to transfer client assets to third parties, or maintain any authority that would result in custody beyond the firm's limited custody arising from advisory fee deduction authority. Clients should promptly notify MCA if they identify any discrepancies between custodial statements and reports received from MCA.  Page 16 Item 16 Investment Discretion Montgomery Capital Advisors, LLC ("MCA") provides investment management services on a discretionary basis. Discretionary authority is granted by the client through the investment management agreement and related account documentation. When granted discretionary authority, MCA is authorized to determine the securities to be purchased or sold, the amount of securities to be bought or sold, and the timing of transactions without obtaining the client's prior approval for each transaction. Clients may impose reasonable restrictions on MCA's discretionary authority, including restrictions on investing in certain securities, industries, or types of investments. Any such restrictions must be communicated to MCA in writing and accepted by MCA. Clients may modify or amend their investment restrictions at any time by providing written notice to MCA. MCA will implement such changes as soon as reasonably practicable following receipt and review of the written instructions.  Page 17 Item 17 Voting Clients Securities Montgomery Capital Advisors, LLC ("MCA") does not accept authority to vote proxies on behalf of clients and does not vote proxies for securities held in client accounts. Clients retain the responsibility for receiving and voting proxies and other shareholder communications relating to securities held in their accounts. Clients will receive proxy materials and related communications directly from their qualified custodian, transfer agent, or issuer. Because MCA does not vote proxies, MCA does not maintain proxy voting policies and procedures. Upon request, MCA may provide clients with information or analysis regarding a particular proxy issue; however, the ultimate decision regarding how to vote proxies remains solely with the client.  Page 18 Item 18 Financial Information Montgomery Capital Advisors, LLC ("MCA") does not require or solicit the prepayment of advisory fees six months or more in advance and therefore is not required to include an audited balance sheet with this brochure. MCA has no financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. MCA has not been the subject of a bankruptcy petition.  Page 19 Item 19 Requirements for State-Registered Advisors Not Applicable. Montgomery Capital Advisors, LLC is registered with the United States Securities and Exchange Commission.  Page 20 Item 20 Personnel Mark J Montgomery. CEO, Managing Director, Senior Portfolio Manager EDUCATION: Graduated from Georgetown University in 1979 with a B.S. in Political Science. 1980-82 Attended the Securities Institute’s Advanced Management Program at the Wharton School of Business. EMPLOYMENT HISTORY: President, CEO & Managing Director for Montgomery Capital Advisors, LLC from 7/05 to present. Managing Director for Montgomery Brothers, Cappiello from 12/03 to 12/05. Managing Director for Montgomery Brothers, Inc. from 06/99 to 12/05. Vice President for Shields & Company from 02/97 to 10/04. Vice President for Tucker Anthony from 05/83 to 02/97. Steve Kinsella, CFO, CCO, Director of Operations EDUCATION: Graduated from Parsons New York School of Design in 1981 in Communications. 1982-84 Attended New York University’s Continuing Education Program of Business Production and Advertising. EMPLOYMENT HISTORY: Vice President, CFO, CCO, Director of Operations for Montgomery Capital Advisors, LLC from 07/05 to present. Director of Operations for Montgomery Brothers New York from 12/03 to 12/05. Executive VP Head of Production, Development and New Business for Fierce Films, Ltd. 02/93 to 11/03. Senior Producer for BBDO Worldwide NY from 06/88 to 02/93. Associate Producer for Grey Advertising New York from 05/84 to 06/88.