Firm Description Patton Fund Management, Inc. is a corporation organized in the State of Indiana. The firm was formed in June 2002 and the principal owner is Mark A. Patton. Throughout the remainder of this brochure, any use of "Patton" is intended to be inclusive of all services. Types of Advisory Services Portfolio Management Services Patton offers portfolio management services in two distinctly different manners. Patton serves as investment adviser to two proprietary private funds as well as provides investment management services to clients via separately managed accounts. Client accounts are generally managed pursuant to one of five investment strategies offered by Patton and as further explained in Item 8. Private Funds The Patton Funds are privately offered pooled investment vehicles exempt from registration under the Investment Company Act of 1940, as amended. Patton manages the private funds in a manner consistent with the investment strategy described in each respective Fund’s offering documents. Patton does not generally provide specifically tailored advice to investors in the Patton Funds unless the investors have also engaged Patton to provide Portfolio Management Services through a separately executed investment management agreement. The Patton Funds and separately managed account clients are collectively referred to herein as “Clients”. Separately Managed Accounts Patton offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Portfolio management services include, but are not limited to, the following: - Investment strategy - Asset allocation - Asset selection - Risk tolerance - Regular portfolio monitoring Patton evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Patton requires discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Patton seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its clients and without consideration of Patton’s economic, investment or other financial interests. To meet its fiduciary obligations, Patton attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client 5 | P a g e portfolios, and accordingly, Patton’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 Patton’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. Advice Limited to Specific Types of Investments Patton generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and private placements, although Patton primarily recommends ETFs. Patton may use other securities as well to help diversify a portfolio when applicable. Pension Consulting Services Patton offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
• identifying investment objectives and restrictions
• providing guidance on various assets classes and investment options
• recommending money managers to manage plan assets in ways designed to achieve objectives
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monitoring performance of money managers and investment options and making recommendations for changes
• recommending other service providers, such as custodians, administrators and broker- dealers
• 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. Financial Planning Services Financial plans and financial planning may include the following: investment planning, life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Patton will provide some input on such things as life insurance and tax concerns but does not sell life insurance or provide tax services. Patton also provides similar services, including investment advice, to employees of companies electing to subscribe to “Financial Mosaic”, a service offered directly to companies who are interested in providing such benefits to their employees. Educational Seminars / Workshops Mark Patton periodically hosts (or serves as a guest speaker at) various educational seminars and workshops where he discusses topics such as market history and trends, principles of diversification, differences between active and passive management styles, etc. Information about Mr. Patton’s background and the services offered by Patton may also be presented. 6 | P a g e Tailored Relationships Patton offers the same suite of services to all separately managed account clients. However, specific client investment strategies and their implementation are dependent upon the client’s goals and circumstances (income, tax level, risk tolerance, etc.). We provide many clients and/or prospective clients with a custom portfolio analysis. Proposals include in-depth analysis of the client’s current holdings and up to three customized portfolios for comparison purposes. Circumstances that are considered include age of investor, risk tolerance, need for withdrawals, retirement, other investments, etc. A similar analysis for company retirement plans may include a review of current plan documents, type of plan, investment menu, plan provisions, number of participants and age distribution and size of plan. Client imposed restrictions may be accommodated in certain instances. IRA Rollover Recommendations 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. Wrap Fee Programs Patton does not participate in wrap fee programs. Assets Under Management As of December 31, 2023, Patton has regulatory assets under management of $ 593,611,703, all of which are managed on a discretionary basis. 7 | P a g e Item 5