Description of Firm Mendel Capital Management, LLC is a registered investment adviser primarily based in Little Rock, AR. We are organized as a limited liability company ("LLC") under the laws of the State of Arkansas. We are primarily owned by Geoffrey H. Niebaum, Chief Executive Officer and Maureen P. Ruggiero, Chief Financial Officer.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," "us" and "Mendel" refer to Mendel Capital Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives.
We offer discretionary, and on occasion, non-discretionary portfolio management services where our investment advice is tailored to meet your needs and investment objectives. We will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables us to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
Our investment process incorporates Fundamental Analysis as part of our long-term out-look by reviewing historical and present data from multiple sources, with the objective of identifying, examining, comparing, and selecting an investments growth potential. Additionally, we also incorporate Technical Analysis as part of our shorter-term out-look by reviewing patterns of a sector or investments pricing and volume trends with the assumption that future patterns and movement will often be similar to previous patterns and movement. Charting Analysis assist us in our investment selection process because this type of analysis captures the concept that all the information that is publicly known about a particular company, by those who are trading it, and their activities are directly reflected in how chart patterns emerge, aiding Mendel Capital Management in identifying beneficial entry and exit points for a given opportunity.
If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. We will also have discretion over the broker or dealer to be used for securities transactions in your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
4 We may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
As part of our Portfolio Management Services, we offer clients the ability to include basic financial planning services as part of our Portfolio Management Services as described above. For those clients who elect to take advantage of our financial planning services you will be provided written financial plan based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. There is no additional fees for this service when you engage our firm for our Portfolio Management Services. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing

consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.
Bookkeeping and Small Business Consulting We offer Bookkeeping and Small Business Consulting services based upon your organization's needs or requirements. We will work with you to determine the type of bookkeeping services appropriate for your organization. In general, these services may include a review and analysis of your existing bookkeeping records and recommendations and a plan for recording your financial transactions such 5 as may include purchases, sales, receipts, and payments by an individual person or an organization/corporation. Our Basic Bookkeeping services includes bookkeeping entries for one bank account, 50 monthly transactions, monthly profit and loss statement and balance sheet.
We also offer bookkeeping fee for small businesses which includes financial transactions your bank account and credit card transactions, vendor/customer invoices, monthly profit and loss statement and balance sheet.
Additionally, we offer Small Business Consulting where we may provide financial information throughout the year so you can test the success of your business strategies and make course corrections to ensure that you reach your year-end profit goals.
Types of Investments We offer advice on equity securities, corporate debt securities (other than commercial paper), certificates of deposit, municipal securities, mutual fund shares, United States government securities, money market funds, REITs and ETFs.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
6 Assets Under Management As of December 31, 2023, we provide continuous management services for $5,430,669 in client assets on a discretionary basis, and $206,185,081 in client assets on a non-discretionary basis.