VAN DIEST CAPITAL

Van Diest Capital Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Van Diest Capital. If you have any questions about the contents of this brochure, please contact us at (515) 620-2085 or by email at: james@vandiestcapital.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 Van Diest Capital is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital’s CRD number is: 334743. 302 West Broadway, Suite #9, Polk City, IA 50226 PO Box 55 Polk City, IA 50226 (515) 620-2085 james@vandiestcapital.com https://vandiestcapital.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 04/20/2026 i  Item 2: Material Changes Van Diest Capital has the following material changes to report. Material changes relate to Van Diest Capital’s policies, practices or conflicts of interests. • Van Diest Capital has successfully transitioned to formal registration with the Securities and Exchange Commission from its previous registration at the state level. • Van Diest Capital added Charles Schwab & Co Inc. as a custodian (Items 12 and 14). • Van Diest Capital updated Item 8.C to disclose hedge funds, private equity funds, Venture capital funds and private placements. • Van Diest Capital updated its fee calculation for portfolio management fees. Portfolio management fees are paid in advance. (Item 5) • Van Diest Capital updated its contact email address and phone number. (Cover page) • Van Diest Capital has updated its Outside Business Activities. (Item 10.C) • Van Diest Capital has updated its ownership information. (Item 4) • Van Diest Capital has added Socially Responsible Investing and the risks associated with Environmental, Social, and Governance (“ESG”) considerations (Items 4 and 8). ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................8 Item 7: Types of Clients ..........................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................9 Item 9: Disciplinary Information .........................................................................................................................13 Item 10: Other Financial Industry Activities and Affiliations .........................................................................13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............15 Item 12: Brokerage Practices ................................................................................................................................16 Item 13: Review of Accounts ................................................................................................................................17 Item 14: Client Referrals and Other Compensation ..........................................................................................18 Item 15: Custody ....................................................................................................................................................19 Item 16: Investment Discretion ............................................................................................................................20 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................20 Item 18: Financial Information .............................................................................................................................20 iii  Item 4: Advisory Business A. Description of the Advisory Firm Van Diest Capital (hereinafter “VDC”) is a Limited Liability Company organized in the State of Iowa. The firm was formed in March 2024, and the principal owner is Van Diest Capital, LLC. B. Types of Advisory Services Portfolio Management Services VDC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. VDC creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring VDC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. VDC 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. VDC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VDC’s economic, investment or other financial interests. To meet its fiduciary obligations, VDC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, VDC’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 VDC’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. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. 2  Retirement Planning Services VDC offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Retirement Planning services may include, but is not limited to: identifying investment objectives and restrictions o o providing guidance on various assets classes and investment options o recommending money managers to manage plan assets in ways designed to achieve objectives o monitoring performance of money managers and investment options and making recommendations for changes o recommending other service providers, such as custodians, administrators and broker-dealers o creating a written pension consulting plan These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Socially Responsible Investing Socially Responsible Investing (“SRI”) involves the incorporation of Environmental, Social, and Governance (“ESG”) considerations into the investment due diligence process. There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities are generally more limited compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including the potential for underperformance. Correspondingly, the number of ESG mutual funds and ETFs are few when compared to those that do not maintain such a mandate. As with any type of investment, including any investment and/or investment strategies recommended and/or undertaken by the Adviser, there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Services Limited to Specific Types of Investments VDC generally limits its investment advice to fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities and non-U.S. securities, although VDC primarily recommends equities. VDC may use other securities as well to help diversify a portfolio when applicable. 3  Written Acknowledgement of Fiduciary Status When we provide investment advice to you 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: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions VDC will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by VDC on behalf of the client. Clients undergo a comprehensive inventory check of their financial and interpersonal situations to aid in arriving at a unique solution for them based on their investment time horizon, short to long-term goals, personal interests or distastes and desired investment objectives. We create an “Investment Fingerprint™” for each client which boasts their financial plans, investment strategies, potential risks and intricacies that make their situation unique to them. VDC may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent VDC from properly servicing the client account, or if the restrictions would require VDC to deviate from its standard suite of services, VDC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. VDC does not participate in wrap fee programs. 4  E. Assets Under Management VDC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 144,104,427 $0 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $500,000 1.35% $500,001 - $1,000,000 1.25% $1,000,001 - $2,500,000 1.00% $2,500,000 - $5,000,000 0.90% $5,000,001 - $10,000,000 0.80% $10,000,001 - $25,000,000 0.70% $25,000,001 - $50,000,000 0.40% $50,000,001 - $100,000,000 0.30% $100,000,001 - AND UP 0.25% Fees are paid in advance. VDC calculates fees based on the account value on the last business day of the prior billing cycle. VDC uses a prorated feed based on the date funds are initially received and the aggregate amount of assets under management for the household. If aggregate household assets are below $150,000 then VDC will charge a $1,500 financial planning fee. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of VDC's fees within five business days of signing the Investment Advisory 5  Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 15 days' written notice. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans for individuals or high-net worth individuals is between $1,500 and $10,000. The negotiated fixed rate for more complex plans for charitable organizations, corporations or business entities in an outsourced Chief Investment Officer role is up to $250,000. Hourly Fees The negotiated hourly fee for these services is between $150 and $5,000. Clients may terminate the agreement without penalty, for full refund of VDC’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Retirement Planning Services Asset-Based Fees Total Assets Under Management Annual Fee All Assets 1.00% In determining the plan account's value for calculating asset-based fees, VDC will rely upon the valuation of assets provided by the plan sponsor or the plan’s custodian or record keeper without independent verification. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of VDC's fees within five business days of signing the Retirement Planning Agreement. Thereafter, clients may terminate the Retirement Planning Agreement generally with 15 days' written notice. Fixed Fees The rate for retirement planning is between $2,000 and $100,000. The final fee schedule will be memorialized in the client’s advisory agreement. This service may be canceled with 15 days’ notice. 6  B. Payment of Fees Payment of Portfolio Management 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 advance. Payment of Financial Planning Fees Financial planning fees are paid via check and wire. Fixed financial planning fees are paid in arrears upon completion. Hourly financial planning fees are paid in arrears upon completion. Payment of Retirement Plan Fees Retirement planning fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis, or may be invoiced and billed directly to the client on a monthly basis. Clients may select the method in which they are billed. Fees are paid in arrears. 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 VDC. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees VDC collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients James Roger Van Diest is a registered representative of a broker-dealer and an insurance agent and in these roles, accepts compensation for the sale of investment products to VDC clients. 1. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset based sales charges or service fees from the sale of mutual funds to VDC's clients. This presents a conflict of interest and gives the supervised person an 7  incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receives compensation, VDC will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. Clients Have the Option to Purchase Recommended Products From Other Brokers Clients always have the option to purchase VDC recommended products through other brokers or agents that are not affiliated with VDC. 3. Commissions are not VDC's primary source of compensation for advisory services Commissions are not VDC’s primary source of compensation for advisory services. 4. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management VDC 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. Item 7: Types of Clients VDC generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Pension and Profit Sharing Plans Charitable Organizations Corporations or Business Entities There is no account minimum for any of VDC’s services. 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis VDC’s methods of analysis include Cyclical analysis, Fundamental analysis, Modern portfolio theory and Quantitative analysis. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies VDC uses long term trading and short term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in 9  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. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis 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. Investment Strategies Long term trading 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. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Equity investment 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. 10  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. 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. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The 11  degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Hedge Funds often engage in leveraging and other speculative investment practices that may increase the risk of investment loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; may involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private Equity Funds: In addition to the risks associated with hedge funds, there are risks specifically associated with investing in private equity. Capital calls can be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Venture Capital Funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Private Placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. 12  Index Funds employ a strategy that aims to replicate the movements of an index of a specific financial market (which may include debt securities), or a set of rules of ownership that are held constant, regardless of market conditions. Products that utilize an index tracking strategy may suffer a risk of loss, including as a result of tracking error. Imperfect correlation between a portfolio of securities and those in the underlying index, rounding of prices, changes to the underlying index and regulatory requirements may cause tracking error, which is the divergence of the portfolio’s performance from that of the underlying index. This risk may be heightened during times of increased market volatility or other unusual market conditions. Tracking error also may result because a portfolio incurs fees and expenses while the underlying index does not. ESG Investing Risk - Certain strategies consider environmental, social and governance factors, and strategies may choose to avoid investments that might otherwise be considered or sell investments due to ESG changes at the investment level. The use of environmental, governance and social factors may impact investment exposure to issuers, industries, sectors, and countries and may impact a portfolio’s relative performance. 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 A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither VDC nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. 13  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither VDC nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests James Roger Van Diest is a licensed insurance agent through Van Diest Capital Risk Management, LLC. Van Diest Capital Risk Management, LLC and VDC are both owned by Van Diest Capital Management, LLC. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of VDC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. VDC addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. VDC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. VDC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by VDC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. James Roger Van Diest is a Board Member for Ankeny Community Champions, an organization comprised of local business leaders focused on community engagement. He provides guidance on maximizing impact and growing a sustainable organization to help those in need in Ankeny. James dedicates 1 hour per month to this role during trading hours. James Roger Van Diest serves as a Board Member and Treasurer for the Greater Des Moines Partnership's Young Professionals Connection (YPC). He contributes to the organization's strategic growth and provides oversight on budgetary matters, dedicating 2 hours per month during trading hours and 2 hours outside of trading hours. James Roger Van Diest serves as a Board Member and Treasurer for Ankeny Young Professionals, a subchapter of the Ankeny Chamber of Commerce. He supports the 14  organization’s strategy and growth while providing guidance on its budgetary outlook. James dedicates 1 hour per month to this role during trading hours. James Roger Van Diest is the founder of Van Diest Land Partners, LLC, a multi-owner entity used for acquiring and leasing land. He dedicates 1 hour to it with no securities trading involved. James Roger Van Diest owns Van Diest Holdings, LLC, a real estate holding company focused on commercial properties in Iowa. He spends 1 hour managing investments, including identifying, vetting, and pursuing opportunities. James Roger Van Diest is owner and manager of Acro Capital Group, LLC, an administrative role involving commercial real estate investments and multi-unit properties, requiring minimal time and no securities trading activities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections VDC does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics VDC 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, Annual Review, and Sanctions. VDC's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests VDC does not recommend that clients buy or sell any security in which a related person to VDC or VDC has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of VDC may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of 15  VDC 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. VDC will always document any 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 VDC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of VDC 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, VDC will never engage in trading that operates to the client’s disadvantage if representatives of VDC buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on VDC’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 VDC 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 VDC's research efforts. VDC will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. VDC will require clients to use Altruist Financial LLC and/or Charles Schwab & Co Inc.. 1. Research and Other Soft-Dollar Benefits In addition to the soft dollars program in which soft dollars are used to pay for third party services, VDC may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). VDC may enter into soft-dollar arrangements consistent with (and not outside of) 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 VDC 16  does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. VDC benefits by not having to produce or pay for the research, products or services, and VDC will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that VDC’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals VDC receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use VDC will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts VDC does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for VDC's advisory services provided on an ongoing basis are reviewed at least annually by James Roger Van Diest, Founder, CEO, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at VDC are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by James Roger Van Diest, Founder, CEO. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. 17  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). With respect to financial plans, VDC’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of VDC's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Other than soft dollar benefits as described in Item 12 above, VDC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to VDC's clients. Charles Schwab & Co., Inc. Advisor Services provides VDC with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, 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. For VDC client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. 18  information Charles Schwab & Co., Inc. Advisor Services also makes available to VDC other products and services that benefit VDC but may not benefit its clients’ accounts. These benefits may include national, regional or VDC specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of VDC by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist VDC in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of VDC’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of VDC’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to VDC other services intended to help VDC manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to VDC by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to VDC. VDC is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals VDC does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, VDC will be deemed to have 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. Custody is also disclosed in Form ADV because VDC has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, VDC will follow the safeguards specified by the SEC rather than undergo an annual audit. 19  Item 16: Investment Discretion VDC provides discretionary and non-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, VDC 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. In some instances, VDC’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to VDC. Item 17: Voting Client Securities (Proxy Voting) VDC 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 A. Balance Sheet VDC neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither VDC nor its management has any financial condition that is likely to reasonably impair VDC’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years VDC has not been the subject of a bankruptcy petition in the last ten years. 20  This brochure supplement provides information about William David Bertran that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact William David Bertran if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about William David Bertran is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for William David Bertran Personal CRD Number: 2240774 Investment Adviser Representative Van Diest Capital 522 2nd St., Suite 1 Webster City, IA 50595 (515) 832-3661 bill@vandiestcapital.com UPDATED: 02/23/2026 21  Item 2: Educational Background and Business Experience Name: William David Bertran Born: 1967 Educational Background and Professional Designations: Education: Management Finance, University of Northern Iowa - 1990 Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 08/2015 - Present Asst 7th Grade Football Coach Webster City Community Schools 11/2018 – 11/2025 IAR Osaic Wealth, Inc. Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities William David Bertran is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of VDC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. VDC addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. VDC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any 22  commissions or other benefits. VDC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by VDC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. William David Bertran is a minority owner and Partner of VDC Accounting, LLC in the firm but spends no time working on this activity. Item 5: Additional Compensation William David Bertran does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As a representative of Van Diest Capital, William David Bertran is supervised by James Roger Van Diest, the firm's Chief Compliance Officer. James Roger Van Diest is responsible for ensuring that William David Bertran adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Roger Van Diest is (515) 620-2085. 23  This brochure supplement provides information about Eric Michael Dawson that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact Eric Michael Dawson if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Eric Michael Dawson is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for Eric Michael Dawson Personal CRD Number: 2521839 Investment Adviser Representative Van Diest Capital 522 2nd St., Suite 1 Webster City, IA 50595 (515) 832-3661 eric@vandiestcapital.com UPDATED: 03/16/2026 24  Item 2: Educational Background and Business Experience Name: Eric Michael Dawson Born: 1975 Educational Background and Professional Designations: Education: BA in Accounting, Buena Vista – 1998 Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 11/2018 – 11/2025 Registered Rep Royal Alliance Associates, Inc. 05/2016 – 11/2018 Registered Rep Signator Investors, Inc. 01/1998 – 05/2016 Registered Rep Transamerica Financial Advisors, Inc. Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities Eric Michael Dawson is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of VDC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. VDC addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. VDC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective 25  evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. VDC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by VDC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Eric Michael Dawson serves as a contracted golf coach for the school. This non-investment-related role involves coaching the boys’ golf team for approximately 20 hours per month, with no securities trading hours. Eric Michael Dawson serves as a Partner at Dawson & Bertran Rentals, dedicating one hour monthly to collecting rent and managing apartment operations, ensuring smooth property oversight and tenant support. Eric Michael Dawson owns and manages Dawson Family Racing Stable, a sole proprietorship involved in a thoroughbred racehorse partnership. His responsibilities include overseeing the horse’s care, monitoring performance updates, and coordinating with the partnership team. This activity is non-investment-related and requires minimal time. Eric Michael Dawson is a minority owner and partner at VDC Accounting, LLC, but he does not devote any time to its operations. Item 5: Additional Compensation Eric Michael Dawson does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. 26  Item 6: Supervision As a representative of Van Diest Capital, Eric Michael Dawson is supervised by James Roger Van Diest, the firm's Chief Compliance Officer. James Roger Van Diest is responsible for ensuring that Eric Dawson adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Roger Van Diest is (515) 620-2085. 27  This brochure supplement provides information about Tyler Paul Dawson that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact Tyler Paul Dawson if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Tyler Paul Dawson is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for Tyler Paul Dawson Personal CRD Number: 4502408 Investment Adviser Representative Van Diest Capital 522 2nd St., Suite 1 Webster City, IA 50595 (515) 297-7957 tyler@vandiestcapital.com UPDATED: 03/16/2026 28  Item 2: Educational Background and Business Experience Name: Tyler Paul Dawson Born: 1978 Educational Background and Professional Designations: Education: Bachelor of Business Administration, University of Iowa - 2001 Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 02/2022 – Present Deacon Missionary Alliance Church Board Member 11/2018 – 11/2025 Investment Advisor Rep Osaic Wealth, Inc. 11/2018 – 11/2025 Registered Rep Royal Alliance Associates, Inc. Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities Tyler Paul Dawson is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of VDC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. VDC addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. VDC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective 29  evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. VDC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by VDC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Tyler Paul Dawson is the owner of Dawson Aronia Berries, an entity with no current duties or operational involvement. The role is not investment-related, and he performs zero weekly hours and no securities trading, with no active responsibilities at this time. Tyler Paul Dawson serves as owner and partner of Dawson & Bertran Rentals, an LLC not related to investments. He spends about 2 hours weekly managing the property, ensuring it is well maintained and in good order for tenants, with no securities trading. Tyler Paul Dawson serves as an elder on the Missionary Alliance Church board, a nonprofit role involving spiritual oversight for the local church body. He contributes 25 hours weekly and maintains 8 securities trading hours without any investment-related responsibilities performed. Tyler Paul Dawson is a minority owner at VDC Accounting, LLC accounting and tax firm affiliated with the RIA, providing bookkeeping, tax filing, and advisory coordination. He performs no public accounting or tax preparation personally, receiving compensation only through ownership or profit distributions. Item 5: Additional Compensation Tyler Paul Dawson does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As a representative of Van Diest Capital, Tyler Paul Dawson is supervised by James Roger Van Diest, the firm's Chief Compliance Officer. James Roger Van Diest is responsible for ensuring that Tyler Paul Dawson adheres to all required regulations regarding the activities of an Investment 30  Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Roger Van Diest is (515) 620-2085. 31  This brochure supplement provides information about Seth Bradley Fulton that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact Seth Bradley Fulton if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Seth Bradley Fulton is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for Seth Bradley Fulton Personal CRD Number: 6027031 Investment Adviser Representative Van Diest Capital 6165 NW 86th St. Johnston, IA 50131 (515) 318-5112 seth@vandiestcapital.com UPDATED: 04/20/2026 32  Item 2: Educational Background and Business Experience Name: Seth Bradley Fulton Born: 1985 Educational Background and Professional Designations: Education: Bachelor's Business Management, Luther College - 2008 Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 11/2018 – 11/2025 IAR Osaic Wealth, Inc Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities Seth Bradley Fulton serves as Treasurer for Johnston Youth Football, a non-profit board member dedicated to youth sports. He receives no commissions or income, ensuring transparent, volunteer-driven financial stewardship. Seth Bradley Fulton is the owner of Fulton Financial, a DBA for his securities business. He actively manages investment-related activities, dedicating 140 hours weekly, including securities trading, overseeing operations and client accounts under this business entity. Seth Bradley Fulton is a minority owner and partner in VDC Accounting, LLC. He holds an ownership interest but does not dedicate any time to the firm’s operations or activities. 33  Seth Bradley Fulton is owner and manager of Acro Capital Group, LLC, an administrative role involving commercial real estate investments and multi-unit properties, requiring minimal time and no securities trading activities. Item 5: Additional Compensation Seth Bradley Fulton does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As a representative of Van Diest Capital, Seth Bradley Fulton is supervised by James Roger Van Diest, the firm's Chief Compliance Officer. James Roger Van Diest is responsible for ensuring that Seth Bradley Fulton adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Roger Van Diest is (515) 620-2085. 34  This brochure supplement provides information about Bryce William Littler that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact Bryce William Littler if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Bryce William Littler is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for Bryce William Littler Personal CRD Number: 7363969 Investment Adviser Representative Van Diest Capital 302 West Broadway Suite 9 Polk City, IA 50226 (515) 620-2085 bryce@vandiestcapital.com UPDATED: 04/20/2026 35  Item 2: Educational Background and Business Experience Name: Bryce William Littler Born: 2001 Educational Background and Professional Designations: Education: Bachelor of Science Finance & Accounting, Iowa State University - 2023 Designations: CFP® - Certified Financial Planner The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: 36  i. ii. Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 11/2025 - Present CFO Van Diest Capital 09/2022 - 11/2025 Associate Advisor WealthCharter Retirement Planning 05/2022 - 08/2022 Financial Analyst Intern Principal 12/2020 - 05/2022 Intern HK Solutions Group 05/2021 - 08/2021 Intern WealthCharter Retirement Planning 08/2020 - 11/2020 NA Unemployed 01/2020 - 08/2020 Bank Intern Guthrie County State Bank 11/2015 - 10/2019 Laborer Jason Roberts 37  Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities Bryce William Littler is an accountant. From time to time, he will offer clients advice or products from this activity. Van Diest Capital always acts in the best interest of the client. Clients are in no way required to utilize the services of any representative of Van Diest Capital in their capacity as an accountant. Bryce William Littler runs a tax and accounting practice, VDC Accounting, LLCthat prepares taxes and does other accounting services for clients. He receives compensation from the fees for preparing tax returns and providing other accounting services. Bryce William Littler is owner and manager of Acro Capital Group, LLC, an administrative role involving commercial real estate investments and multi-unit properties, requiring minimal time and no securities trading activities. Item 5: Additional Compensation Bryce William Littler does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As a representative of Van Diest Capital, Bryce William Littler is supervised by James Van Diest, the firm's Chief Compliance Officer. James Van Diest is responsible for ensuring that Bryce William Littler adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Van Diest is (515) 620-2085. 38  This brochure supplement provides information about Benjamin Rasmussen that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact Benjamin Rasmussen if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about Benjamin Rasmussen is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for Benjamin Rasmussen Personal CRD Number: 7330358 Investment Adviser Representative Van Diest Capital 522 2nd St., Suite 1 Webster City, IA 50595 (515) 325-4103 ben@vandiestcapital.com UPDATED: 03/16/2026 39  Item 2: Educational Background and Business Experience Name: Benjamin Rasmussen Born: 1991 Educational Background and Professional Designations: Education: Kineisology Exercise Science, Iowa State University - 2016 Business Background: 11/2025 - Present Investment Adviser Representative Van Diest Capital 08/2018 - Present Coach Webster City Schools 01/2023 – 11/2025 Investment Advisor Representative Dawson & Bertran Investment Advisors 01/2021 – 12/2022 Assistant Dawson & Bertran Investment Advisors 08/2017 – 12/2020 Prevention Specialist Community and Family Resources Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities Benjamin Rasmussen is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of VDC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. VDC 40  addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. VDC periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. VDC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by VDC’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Benjamin Rasmussen is a coach in Webster City Schools which is a local school. It is not investment related business. He dedicates 40 hours to securities trading hours in a business. Item 5: Additional Compensation Benjamin Rasmussen does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As a representative of Van Diest Capital, Benjamin Rasmussen is supervised by James Roger Van Diest, the firm's Chief Compliance Officer. James Roger Van Diest is responsible for ensuring that Benjamin Rasmussen adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. The phone number for James Roger Van Diest is (515) 620-2085 41  This brochure supplement provides information about James Roger Van Diest that supplements the Van Diest Capital brochure. You should have received a copy of that brochure. Please contact James Roger Van Diest if you did not receive Van Diest Capital’s brochure or if you have any questions about the contents of this supplement. Additional information about James Roger Van Diest is also available on the SEC’s website at www.adviserinfo.sec.gov. Van Diest Capital Form ADV Part 2B – Individual Disclosure Brochure for James Roger Van Diest Personal CRD Number: 6978124 Investment Adviser Representative Van Diest Capital 302 West Broadway, Suite 9 Polk City, IA 50226 (515) 620-2085 james@vandiestcapital.com UPDATED: 04/20/2026 42  Item 2: Educational Background and Business Experience Name: James Roger Van Diest Born: 1998 Educational Background and Professional Designations: Education: Master of Business Administration, Iowa State University - 2023 Master of Finance, Iowa State University - 2023 Bachelor of Science - Finance, Iowa State University - 2021 Bachelor of Science - Business Economics, Iowa State University - 2021 Business Background: 04/2025 - Present CCO, CEO, CIO & Partner Van Diest Capital 03/2024 - 04/2025 Private Wealth Advisor Van Diest Capital 03/2023 – 04/2025 Registered Representative Osaic Wealth, Inc. 03/2024 - 04/2025 Private Wealth Advisor Van Diest Capital 06/2023 - 03/2024 Private Wealth Advisor Dawson & Bertran Investment Advisors Full-Time Student - Master of Business 08/2021 – 05/2023 Administration & Master of Finance Iowa State University 05/2022 - 03/2023 Senior Financial Analyst Intern - Strategy & Finance Principal Financial Group - Principal International 05/2021 - 05/2022 Student Associate, Strategic Initiatives Chevron Corporation - Renewable Energy Group Inc. 43  02/2019 - 05/2021 Membership Consultant Ames Racquet & Fitness Center 08/2017 - 05/2021 Student Iowa State University 04/2020 - 08/2020 Investment Analyst Intern Summit Agricultural Group - Summit Investments 01/2020 - 04/2020 Accounting & Tax Intern McGowen, Hurst, Clark & Smith P.C. 05/2019 - 08/2019 Sales & Marketing Intern Chevron Corporation - Renewable Energy Group Inc. 05/2018 – 08/2018 Financial Analyst Intern Dawson & Bertran Investment Advisors 05/2015 - 08/2018 Marketing Intern / Grounds Man Van Diest Supply Company 08/2013 - 05/2017 Student, High School Webster City High School Item 3: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business. Item 4: Other Business Activities James Roger Van Diest is a licensed insurance agent through Van Diest Capital Risk Management, LLC. Van Diest Capital Risk Management, LLC and VDC are both owned by Van Diest Capital Management, LLC. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of Van Diest Capital are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. Van Diest Capital addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. Van Diest 44  Capital periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. Van Diest Capital will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by Van Diest Capital’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. James Roger Van Diest is a Board Member for Ankeny Community Champions, an organization comprised of local business leaders focused on community engagement. He provides guidance on maximizing impact and growing a sustainable organization to help those in need in Ankeny. James dedicates 1 hour per month to this role during trading hours. James Roger Van Diest serves as a Board Member and Treasurer for the Greater Des Moines Partnership's Young Professionals Connection (YPC). He contributes to the organization's strategic growth and provides oversight on budgetary matters, dedicating 2 hours per month during trading hours and 2 hours outside of trading hours. James Roger Van Diest serves as a Board Member and Treasurer for Ankeny Young Professionals, a subchapter of the Ankeny Chamber of Commerce. He supports the organization’s strategy and growth while providing guidance on its budgetary outlook. James dedicates 1 hour per month to this role during trading hours. James Roger Van Diest is the founder of Van Diest Land Partners, LLC, a multi-owner entity used for acquiring and leasing land. He dedicates 1 hour to it with no securities trading involved. James Roger Van Diest owns Van Diest Holdings, LLC, a real estate holding company focused on commercial properties in Iowa. He spends 1 hour managing investments, including identifying, vetting, and pursuing opportunities. James Roger Van Diest is owner and manager of Acro Capital Group, LLC, an administrative role involving commercial real estate investments and multi-unit properties, requiring minimal time and no securities trading activities. Item 5: Additional Compensation 45  James Roger Van Diest does not receive any economic benefit from any person, company, or organization, other than Van Diest Capital in exchange for providing clients advisory services through Van Diest Capital. Item 6: Supervision As the Chief Compliance Officer of Van Diest Capital, James Roger Van Diest supervises all activities of the firm. James Roger Van Diest's contact information is on the cover page of this disclosure document. James Roger Van Diest adheres to applicable regulatory requirements, together with all policies and procedures outlined in the firm’s code of ethics and compliance manual. 46