TOWLE & CO

CRD 110862File 801-16622

APPROVED

Retail clients

Custody

Filing as of Jul 16, 2026

Feed vintage Aug 17, 2026

Regulatory AUM

$473.7M

Above cohort median (national)

Discretionary AUM

$473.7M

Clients

31 accounts

Employees

Above cohort median in CO

Identity & registration

ADV Item 1

Organization form: Corporation
Firm type: Registered
SEC region: DRO
Registration date: Dec 10, 1981
Principal office: 720 S. COLORADO BLVD, SUITE 730-S, DENVER, CO, 80246
Phone: 303-731-2494
Website: HTTP://WWW.SMALLCAPVALUE.COM

Assets & accounts

ADV Item 5F

Total regulatory AUM: $473.7M
Discretionary AUM: $473.7M
Non-discretionary AUM: $0
Discretionary accounts: 31
Non-discretionary accounts: 0
Total accounts: 31
AUM per client: $15.3M

Clients by type

ADV Item 5D

Client type	Clients	AUM
Investment companies	2	$168.7M
Charitable organizations	7	$73.2M
High net worth individuals	17	$51.4M
Pooled investment vehicles	3	$152.6M
Pension and profit sharing plans	Fewer than 5	$4.4M
State or municipal government entities	Fewer than 5	$23.5M

Compensation & activities

ADV Items 5E, 5G

Compensation

Performance-based fees
A percentage of assets under your management

Advisory activities

Portfolio management for businesses
Portfolio management for investment companies
Portfolio management for pooled investment vehicles
Portfolio management for individuals and/or small businesses

Custody

ADV Item 9

Firm Custody Cash: Yes
Firm Custody Assets: Yes
Firm Custody Clients: Yes
Firm Custody Securities: Yes
Related Person Custody Cash: No
Related Person Custody Assets: No
Related Person Custody Clients: No
Related Person Custody Securities: Yes

Disclosure events

ADV Item 11

This firm answered no to every Item 11 disclosure question in this filing.

Filed changes

Date	Field	From	To
Aug 17, 2026	Clients	32	31
Aug 12, 2026	Registration	—	APPROVED

Every value above is reproduced from this firm's Form ADV filing. Fields the firm left blank are shown as “Not reported” rather than filled in from other sources.