Victoria Capital Management, Inc.

Victoria Capital Management, Inc. is an SEC registered investment advisor specializing in managing portfolios of individual fixed income, equity securities, and exchange-traded funds since 2000. The firm offers investment management services through various strategies, including Growth Equity, Growth & Income, and Target Return portfolios. VCM provides written quarterly investment perspectives and customized client letters to inform clients about the investment process. The firm caters to a range of clients, including individuals, trusts, foundations, and retirement plans. VCM's investment philosophy involves fundamental and technical analysis, considering fiscal and monetary policies, economic variables, and client expectations. The firm charges fees based on a percentage of assets under management, with a maximum fee of 1%. VCM does not offer performance-based fees and has no disciplinary history. The firm has sub-advisory agreements with other entities and offers investment models through various platforms. VCM operates under a Code of Ethics to ensure ethical conduct and places client interests first. The firm has full discretion for account management and votes on proxy materials. All client assets are held by an independent custodian, and VCM has a policy to prevent money laundering. Key personnel include Diane V. Nugent, President/CEO, Thomas E. Nugent, Executive Vice President, and Ryan L. Harper, Director of Operations.