DeWitt Capital Management ("DCM") is an investment adviser located in the State of Pennsylvania. The firm was founded in 1996 by David T. DeWitt, owner and President of the firm. The firm's main office is located in Collegeville, Pennsylvania. Portfolio Management Services DCM offers investment management services to its clients for a fee. DCM provides investment management services to clients on a discretionary or non-discretionary basis. DCM monitors clients' portfolios on a continuous basis and makes appropriate changes to the portfolio holdings as needed to maintain the objectives and policies of the account. DCM is responsible for the monitoring, review and trading recommendations in the managed account.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and the appropriate trading authorization forms. If you engage us for non-discretionary portfolio management, we will obtain your consent (verbal or in writing) before effecting any transactions in your account and such consent will be document in DCM's books and records.
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.
As part of our portfolio management services, in addition to other types of investments (see disclosures below in this section), we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm.
DCM also offers services to other investment advisors whereby DCM acts as sub-advisor to certain client accounts. DCM offers a strategy of investment management that creates portfolios made up of master limited partnerships ("MLPs"). MLPs are limited partnerships that are publicly traded on securities exchanges. DCM designs strategies to take advantage of the tax benefits offered by limited partnerships, while allowing for the liquidity afforded by publicly traded exchanges. In addition to offering these investment strategies to its own clients, DCM acts as sub-advisor to other investment advisors who wish to utilize DCM's expertise in this area to benefit their own clients. DCM enters into written agreements with these other investment advisors to provide sub-advisory services.
Model Portfolios As part of our portfolio management services, we may invest your assets according to one or more model portfolios developed by our firm or by a third-party. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not be able to set restrictions on the specific holdings or allocations within the model, nor the types of 4 securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm.
For the benefit of no commissions or transactions fees, fully digital account opening, a large variety of security options and complete integration with software tools, DCM recommends Altruist Financial LLC, an unaffiliated registered broker/dealer, member FINRA/SIPC, as introducing broker to Apex Clearing Corporation, an unaffiliated registered broker/dealer, member FINRA/SIPC, which acts as the clients' custodian for these model portfolios. We participate in the Model Marketplace offered by Altruist LLC, a registered investment adviser and affiliate of Altruist Financial LLC. We may select model portfolios generated by Altruist LLC as part of their fully digital account program, or we may place client assets in other models available through Altruist LLC's Model Marketplace. Any applicable Altruist LLC advisory fees are charged directly to client accounts and are disclosed in the Altruist LLC disclosure brochure.
Prior to introducing any clients to another investment adviser, DCM is responsible for determining if the other

investment adviser is properly licensed, notice filed or exempt from registration in the jurisdiction in which the client resides and advisory services are offered.
Financial Consulting Services DCM offers financial consulting services that primarily involve advising clients on specific financial- related topics. The topics DCM addresses may include, but are not limited to, asset allocation, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Clients may elect to engage us for financial consulting services on any of these topics, at the client's discretion and based on their needs. Clients may also engage us for other services, such as Model Portfolios described above, for example, and any such additional service will be described in a separate asset management agreement signed with DCM.
Sub-Advisory Services to Independent Registered Investment Advisers We offer sub-advisory services to unaffiliated third party investment advisers (the "Primary Investment Adviser"). As part of these services, we will manage assets delegated to our firm by the Primary Investment Adviser. While we are responsible for the overall management of the assets delegated to our firm, we will not communicate investment recommendations or selections directly to the Primary Investment Adviser's individual clients.
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; 5
•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.
General Information Related to Investment Recommendations DCM continually seeks the best security candidates for client investment. Although DCM may choose client investments from the universe of securities available, DCM specializes in choosing investments from the pool of publicly traded companies or private offerings located within the "Delaware Valley" of Pennsylvania. DCM analyzes a potential company for investment by reviewing such factors as: earnings per share trends; balance sheet strengths and weaknesses; and discovery of additional information in companies which have little or any research coverage which makes the company more valuable than its current market capitalization in DCM's opinion, and technical factors such as: trading volume, moving average changes, and net insider buying and selling, and other technical factors identified in study materials provided by the Market Technicians study material. DCM also evaluates management through such sources as: personal meetings, evaluating information in the local news; and ascertaining the views of competitors, suppliers, and customers towards the company and its management.
DCM offers an investment strategy it calls Energy Income Strategy, which is designed to produce high cash distributions by investing in publicly traded securities that have a history of raising their distributions. This strategy uses incoming generating master limited partnerships which trade on the NYSE or NASDAQ to provide increasing income to clients.
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.
Assets Under Management As of March 23, 2023, we provide continuous management services for $69,112,603 in client assets on a discretionary basis, and $9,724,858 in client assets on a non-discretionary basis.