General Description of the Firm HCM was formed as a corporation in Texas in May 1989. HCM is a wholly owned subsidiary of Hodges Capital Holdings, Inc. Chairman/CEO, Craig D. Hodges, owns approximately 23.7% equity stock. Hodges Capital Holdings’ largest shareholder is the Hodges Capital Holdings Voting Trust at 46.9%; of which Craig Hodges, Camille Hodges Hays and Clark Hodges, trustees, each has approximately 1/3 voting control. Advisory Services HCM provides investment management to clients under the Hodges Private Client Wrap Program (“HPC Wrap Program”) as sponsor and portfolio manager. We collaborate with you to determine the best method to invest and manage your account(s). We may recommend one or more portfolios to manage the investments in your account(s). The two types of portfolios offered are: Hodges Private Client Free Style Portfolios – a fully discretionary account that is managed by your Hodges Capital Management Investment Adviser Representative, who serves as your principal contact and account manager. The Investment Adviser Representatives takes into consideration your particular investment objectives, guidelines and restrictions and constructs a customized Free Style Portfolio that may hold equities, fixed income, cash and cash equivalents, mutual funds, ETFs or option securities. Hodges Capital Management’s Investment Adviser Representatives operate independent of each other and therefore may place trades before or after trades for other client accounts, including the Hodges Mutual Funds, which may adversely affect the trade price for your account. Due to the unique treatment of each client account, there may be instances where one account will not hold the same securities or perform similarly to other Free Style accounts even if they share the same investment goals and objectives. Hodges Private Client Strategy Portfolios – a fully discretionary account that invests in a portfolio constructed and managed by Hodges Capital Management’s Portfolio Management team. The Investment Advisor Representative works with you to tailor the portfolio based on your particular investment objectives, guidelines and restrictions. The Strategy Portfolio may hold equities, ETFs, cash and cash equivalents. Hodges Capital Management Investment Advisors may function as a Portfolio Manager for one or more of the Hodges Family of Mutual Funds, and in some instances may act as the Portfolio Manager for a model portfolio as well as the Investment Advisor for a client account, depending on the type of client and type of investment selected. HPC Wrap Program Client Assets As of July 31, 2023, HCM had $ 969,372,598 in discretionary assets under management. Fees and Compensation HCM is compensated through an annualized asset-based fee (“advisory fee”), which is paid on a quarterly basis in advance. Clients invested in the HPC Wrap Program will have the fees deducted directly from their account. Wrap Fee Brochure | 5 Fees are payable within thirty (30) days of the last day of the billing period. Fees are charged based on the number of days the account is under management during the period for any advisory agreement that comes into effect or is terminated mid-period. Advisory fees range from 1%-1.5% and are negotiable. Fees may differ based on a number of factors including, but not limited to, the:
• Amount of your assets,

• Number and size of related accounts
• Fluctuations that occur intra-quarter
• Portfolio strategy The amounts and specific way fees are charged is memorialized in our contract with the Client. Portfolio managers may be paid a portion of the total advisory fee. The investment advisor recommending the wrap fee program to the client receives compensation because of the client's participation in the program. The amount of this compensation may be more than what the person would receive if the client participated in our other programs or paid separately for investment advice, brokerage, and other services. The investment advisor, therefore, may have a financial incentive to recommend the wrap fee program over other programs or services. The HPC Wrap Program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the HPC Program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). HCM will wrap investment advice, portfolio management and trade execution for wrap fee portfolio management accounts and HCM will charge clients one advisory fee. Accounts participating in the HPC Wrap Program are not charged higher advisory fees based on trading activity. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, custodial fees, account fees, margin costs, charges imposed directly by an exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Custody of your accounts for both securities and funds will be maintained at Fidelity Investments, the designated custodian and clearing Firm. Clients receive account statements not less than quarterly directly from the custodian of the accounts. Clients also receive performance reports at least annually from HCM. 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 interests 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 Brochure | 6