ACM is an investment management firm formed in 1980 to provide superior relative returns for its clients by investing in quality small and medium sized growth companies – the most innovative and more rapidly growing sector of the U.S. economy. These companies average approximately $1 billion in sales and $6.0 billion at 3/31/19 in market capitalization with expected growth potential 50% greater than the Standard & Poor’s 500. We emphasize management ability and strong fundamentals in our selection process, and the growth, profitability and financial strength of our investments are high. Flexibility is emphasized and we adjust our equity commitments to capitalize on market volatility. Equity emphasis favors companies that possess accelerating earnings momentum and appear undervalued relative to our universe list. Since we emphasize growth companies, the majority of our potential investments are focused on health care and technology – two above average growth segments of our economy. Primary emphasis is on companies with managements of demonstrated competence, effective marketing organizations, strong research efforts and dominant market positions for their products. In addition, companies are selected that possess the necessary profitability and financial strength to support their growth. Companies with these characteristics provide a favorable risk/reward ratio over time. We are long-term investors and prefer to hold our investments through market cycles if their fundamentals remain favorable and we have a positive market outlook. We do not emphasize asset plays, turnarounds or large companies with small capitalizations. A personal investment advisory service is provided to all clients. All accounts are individually managed and invested in publicly traded companies selected from our stock universe list supplemented with convertible and fixed income investments as necessary. We have a few select exchange traded funds and mutual funds for bond investments available for purchase if appropriate. ACM offers a specific investment strategy and does not modify its strategy based on a client’s financial situation, investment experience or investment objective if it differs from ACM’s investment strategy. We permit reasonable investment flexibility if it does not materially affect our investment strategy. Assets – The firm had $ 2,246,961,197 of discretionary funds under management on March 31, 2019. Ownership – The firm was founded in 1980 with Luke P. La Valle, Jr. as principal majority owner and Cesna, S.A. as a principal owner. In August 2014, the ownership changed with Cesna, S.A. transferring its remaining interest to Longlevens, LLC., with Longlevens, LLC. becoming a minority owner. In March 2016, Luke LaValle transferred shares to two LaValle trusts which became minority owners. please register to get more info

Compensation per annum is 1% of assets, or as stipulated in our investment management agreement. Under certain circumstances, ACM at its discretion may discount management fees. Further, some existing clients may pay a lower fee than new clients. Fees are payable quarterly, in advance, based upon 1/4 of 1% of the portfolio’s market value as of the last business day of each calendar quarter. Fees may be negotiable on accounts in excess of $50 million. We forward a quarterly bill to the client’s custodian for payment from the portfolio showing the method of calculation and period covered. A copy of our quarterly bill is forwarded to the client. ACM receives income only from the management of client assets. Other Fees or Expenses – Certain custodians who hold client assets may also charge a fee. Clients will also incur transaction costs, which are commissions paid to brokers through which ACM processes trades for its accounts. Assets invested in exchange traded funds or mutual funds are charged a fee by the fund managers in addition to ACM’s management fee. Termination – Our investment management agreement may be terminated within 10 days from inception without penalty or by either party thereafter upon 30 days written notice of such termination. Fees are refundable on a pro rata per diem basis from the date of notification. please register to get more info

ACM does not manage any accounts with a performance-based fee structure. please register to get more info

ACM manages portfolios for corporations, foundations, high net worth individuals, IRAs and trusts. We generally require a minimum of $2 million for new accounts. However, smaller accounts may be accepted at the discretion of management. please register to get more info

The method of security analysis is a fundamental economic and investment valuation with a rigorous research process to select our investments. A continuous analysis of the economic outlook is conducted to identify cyclical and secular trends and those economic sectors that appear favorably positioned over the intermediate term. The stock selection process concentrates on quality small and medium sized growth companies within these sectors that meet specific qualitative and quantitative criteria. Candidates generally possess a growth rate potential 50% greater than the Standard & Poor’s 500. Primary emphasis is then placed on companies with superior management, effective marketing organizations, strong research efforts and dominant market positions for their products. We select our investments from a universe list of 100 companies that is compiled and maintained by a continuous and extensive fundamental analysis. Finally, this fundamental economic and investment analysis is combined with a technical review of the overall market, the smaller company segment and those fundamentally favored issues to enhance stock selection and the timing of purchases and sales. We reduce or sell positions when our investments appear overvalued, represent an excessive percentage of the portfolio’s total assets or are experiencing deteriorating fundamentals. Fixed income management emphasizes preservation of capital, current income and marketability through quality investments of short to intermediate term duration. Investment strategy is tailored to provide downside protection through a disciplined research effort that emphasizes interest rate trends, yield curve opportunities, sector yield relationships and growth with convertible securities. We invest in U. S.
Government securities, corporates, preferred and convertible bonds through funds or ETFs as necessary.
Unique Approach – Our investment approach is unique relative to most investment management organizations. ACM specializes in our market segment and we are dedicated to this effort. We are consistent and select our investments from a universe list of 100 companies focused on revenue size rather than market capitalization. This list represents a quality group of companies within our market segment that possesses the necessary profitability and financial strength to support their growth. Our approach provides us with the opportunity to hold companies for an extended period of time as they grow from small to medium sized corporations. We invest for the long term and own our investments considerably longer than the industry average. This has resulted in above average returns, lower turnover and greater tax efficiency. In addition, our investment strategy and longer-term approach result in greater “takeover” activity thereby enhancing returns to our clients. We are small and flexible, a major advantage today. Sources of Information – The principal sources of information utilized are company 10Ks, prospectuses and quarterly and annual reports. This information is supplemented by industry and company research reports from professional firms and analysts that specialize in researching small and medium sized growth companies. Other sources include management meetings and presentations, financial periodicals, trade journals and research material published by Moody’s and Standard & Poor’s. Risk of Loss – Investing involves the risk of loss that clients should be willing to accept. ACM makes every effort to achieve its objective of long-term capital appreciation but cannot guarantee it will attain that objective. You could lose money. During any given period, ACM’s growth strategy may achieve better or worse results than other investment strategies and the stock market may decline. Investing in equities is subject to the volatility of the markets. The performance of small and medium sized growth companies could be more volatile than larger companies. Also, buy and sell orders may take longer to complete because of less liquidity. However, our experience has been that there is less risk with our strategy over a market cycle because of the above average increases in revenues and earnings of our investments combined with greater acquisition activity that provides enhanced returns to investors. While generally considered to be more conservative than stocks, fixed income investments carry credit, duration, inflation, and interest rate risk. please register to get more info

There are no disciplinary or legal events to report regarding ACM and its employees. please register to get more info

Neither ACM, its officers nor employees have any other financial activities or affiliations as described by the SEC. please register to get more info

Personal Trading
ACM has adopted a code of ethics pursuant to SEC Rule 204A-1. Our code of ethics is available to any client or prospective client upon written request. ACM’s Code of Ethics covers its directors, officers and staff and requires that they comply with applicable federal securities laws and includes policies and procedures that pertain to securities related conduct and fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The following principles emphasize ACM’s fiduciary duty to its clients and the obligation of its officers and staff to uphold that fundamental duty. These principles include:
•The duty to place the interests of clients first at all times.

•The requirement that all personal securities transactions be conducted to avoid any actual or potential conflict of interest, or abuse of ACM’s position of trust and responsibility.

•ACM’s personnel must not take inappropriate advantage of their positions and responsibilities.

•Information concerning the identity of security holdings and financial circumstances of clients is confidential.

•Honesty, integrity and professionalism shall govern all conduct whether or not the conduct is covered by specific standards and procedures.
Non-Public Information – Supervised persons are prohibited from securities trading, either personally or on behalf of others, while in possession of material, nonpublic information and from communicating material nonpublic information to others in violation of the law. This is known as “insider trading.” Finally, we note the SEC’s position that the term “material nonpublic information” relates not only to issuers, but also to ACM’s securities recommendations and client securities holdings and transactions. Personal Trading – Supervised persons must obtain approval from Michael Meagher, Chief Compliance Officer, for all securities transactions in our investments, including IPOs and private placements, and can not execute any trades until all transactions have been executed for clients in that security. However, they may participate with our clients if the trades do not adversely impact the pricing and availability of the transaction for clients or operate to the detriment of clients. This also applies to any relative by blood or marriage living in the same household and any account in which an immediate family member has a direct or beneficial interest such as a trust. Our Code requires supervised persons to report upon hiring and annually thereafter all reportable securities accounts and “reportable securities” in which they have a beneficial ownership and quarterly for all “reportable securities” transactions. please register to get more info

Since the firm invests primarily in quality small and medium sized growth companies, it is important to receive the research services of those brokers specializing in this market segment. Therefore, ACM selects brokers for its business that will assist the firm in providing a highly professional investment service to all its clients. We prefer to deal with a limited number of brokers based upon a combination of their professional research capability, financial strength and willingness to charge a reasonable commission. Factors considered in determining the reasonableness of commissions include the full range of services provided and commissions generally charged by brokers providing services to clients. In many cases, commissions paid are larger than those charged by discount brokers. However, we believe that the benefits gained from research provided by full service brokers will produce more favorable portfolio performance in excess of any incremental commissions. In addition, total annual portfolio commissions are modest since we invest for the longer term with limited portfolio turnover. Some part of the brokerage commission beyond execution costs can be ascribed to payment for research (soft dollar payments). However, we do not use brokerage commissions for client referrals. A few select clients use a custodian that requires trading through that broker dealer. ACM typically combines client purchase and sale orders into blocks for execution to achieve more efficient execution, lower per share commission and an average price for clients. Our transactions are allocated prior to the trade since we review our accounts prior to placing orders. please register to get more info

All investment advisory accounts are managed by an experienced investment professional and reviewed on an ongoing basis. Additional reviews occur in conjunction with any change in strategy, unusual market volatility, fundamentals of a holding, account cash flows or the needs and objectives of the client. This insures a continuous and highly professional service to all clients. As a result, the overall investment strategy and individual holdings are regularly monitored with specific action taken as necessary in all portfolios. Quarterly analyses are forwarded to all clients. These include a summary of the total portfolio with bond and equity percentage breakdowns, current market value, estimated annual income and current yield. A listing of all individual holdings is also provided with similar information along with a realized gain and loss update for taxable accounts. We include a performance summary of the account compared with the Dow Jones Industrial Average, the S&P 500 and the Russell 2500, along with our quarterly Economic & Investment Summary. Our clients also receive a monthly statement from their custodian, and they should compare this statement with our quarterly statement. please register to get more info

From time-to-time, ACM may enter into arrangements with unaffiliated third-parties (“solicitors”) whereby they are compensated for referring investors and/or clients to the Firm. Generally, payments to such solicitors will be based on a percentage of the fee earned by the Firm on the invested amount. ACM does not receive an economic benefit with investment advice from a non-client. Clients and investors should be aware of the potential conflict of interest with respect to the solicitation arrangement described above. Where such an arrangement exists, a referred client is made aware of the details of the solicitation agreement. please register to get more info

ACM does not have physical custody of client funds or securities. please register to get more info

ACM exercises investment discretionary authority over its client accounts as agent and attorney-in-fact with the broadest possible power of management and investment as stipulated in our investment management agreement signed by each client. Accordingly, we implement our investment strategy and execute orders without prior consultation or approval and invest and reinvest available funds as ACM deems to be in the client’s best interests. However, we periodically discuss our investment strategy and future plans with our clients in coordination with investment objectives. please register to get more info

ACM typically does not vote proxies on behalf of our clients. Our clients receive proxies and other corporate communication directly from their custodian and vote as they may wish. ACM as a matter of policy may in certain circumstances offer the ability to vote proxies on behalf of it’s advisory clients. Such delegation of proxy voting authority must be agreed to jointly and will be reflected in the written Investment Management Agreement between the client and the Firm. ACM will utilize ISS Governance Services (“ISS”) to provide both research analysis, with respect to proxy vote items, as well as process voting ballots. Generally, the Firm’s Proxy Voting Policy is to vote proxies according to ISS recommendations except in those instances where the client instructs us to override ISS’ recommendations. please register to get more info

ACM does not require prepayment of client fees six months or more in advance and is, therefore, not required to include a balance sheet. In addition, the firm does not have any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.
Item 19. Additional Information
Legal Actions – We do not advise nor act for our clients in any legal proceedings, including bankruptcies or class actions, involving securities held in our portfolios. October, 2019
FORM ADV – PART 2B
BROCHURE SUPPLEMENT
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Item 1. Cover Page
The investment professionals that provide investment management and research services to our clients include the following: Luke P. La Valle, Jr. President M. Catherine McRaeExecutive Vice President Kristin GambleSenior Managing Director David M. La ValleManaging Director Michael P. La ValleManaging Director Thomas W. VailManaging Director Evelyn LuSenior Associate John P. GibsonResearch Analyst The firm’s investment professionals are located in the company’s office at 551 Madison Avenue, Suite 902, New York, NY 10022.
Item 2. Educational Background & Business Experience
Luke P. La Valle, Jr., President & Chief Investment Officer Date of Birth – April 2, 1942 Founded ACM – 1980 Luke is the founder of American Capital Management, Inc. (ACM). He began his career in 1967 at the U.S. Trust Company of New York and was a Senior Investment Officer in the Investment Division. During this period, he specialized in smaller company investing and research and managed a pooled fund of smaller company investments for over a decade. His responsibilities also included the management of pension portfolios and he served on the Stock Selection Committee. He has a BS from Boston College and an MBA from the University of Massachusetts. Luke is a retired Lieutenant Colonel, Military Intelligence, U.S. Army Reserve and served with the 101st Airborne Division and on the Army Staff, The Pentagon. M. Catherine McRae, Executive Vice President Date of Birth – November 28, 1952 Joined ACM – 2010 Cathy joined our firm after eight years as a Managing Director and Principal at European Investors where she was the head portfolio manager of a U.S. equities fund and Chairperson of the U.S. and Global Investment Committees. Cathy was also a portfolio manager of a mid-sized hedge fund at Ridgecrest Partners and the lead manager of two small cap core funds at the Guardian Life Insurance Co. For a number of years, she was a research analyst covering various industry sectors including small cap technology companies at Bear Stearns, Drexel Burnham, Furman Selz and NatWest Securities. Her investment career began in 1975 in the Corporate Finance Department of the Irving Trust Company where she was a financial consultant for six years. Cathy graduated from Dartmouth College, magna cum laude, and is a Chartered Financial Analyst.

Kristin Gamble, Senior Managing Director Date of Birth – October 15, 1945 Joined ACM – 2015

Kristin and her late husband, Charles Flood, were in business together as Flood Gamble Associates, Inc. (FGA), an investment counseling firm formed in 1983. Kristin was the President and Chief Investment Officer of FGA. Prior to forming their firm, she was Senior Vice President-Deputy General Manager of Manufacturers Hanover in charge of equity investments for the Trust Division. Earlier, she was a securities analyst with New Court Securities; Clotty Bellman & Co.; and Merrill Lynch, Pierce, Fenner & Smith. Kristin served on the Board of Trustees of Federal Realty Investment Trust from 1995-2017 and the Board of Directors of Ethan Allen Interiors Inc. from 1992-2015. In addition, she is Chairman of Scenic Hudson, Inc., an environmental organization involved in land preservation and advocacy for the Hudson River Valley. Kristin graduated from Wellesley College as a Durant Scholar with a BA in Economics and is a Chartered Financial Analyst and a Chartered Investment Counselor.

Thomas W. Vail, Managing Director Date of Birth – December 16, 1970 Joined ACM – 2007

Tom was with the U.S. Trust Company of New York from 1993 to 2007 where he became a Managing Director and Senior Portfolio Manager in the Equities division. His responsibilities included managing an equity mutual fund, a common trust fund and portfolios for private clients. He spent his first two years at U.S. Trust in the Economics Department working closely with the Chief Economist. Tom has a BA from Boston College and an MBA from the Columbia Business School.

David M. La Valle, Managing Director, Co-Chief Investment Officer Date of Birth – September 2, 1980 Joined ACM – 2008 Previously, David worked at Morgan Stanley for two years in its Leveraged and Acquisition Finance Group where his responsibilities included analysis for underwriting and syndicating high yield bonds and leveraged loans. Prior to joining Morgan Stanley, David served as a Captain in the U.S. Army and is a veteran of Operation Iraqi Freedom. He coordinated with foreign militaries in the Pacific region on missile defense measures and deployed to Iraq the Army’s first weapons system designed to identify and destroy incoming mortar and rocket rounds. David began his investment career as a summer research intern at ACM and was subsequently employed as a research analyst before starting active military service. David graduated from Stanford University with a BA in Political Science. Michael P. La Valle – Managing Director Date of Birth – August 25, 1979 Joined ACM - 2014 From 2010 to 2014, Mike was the CEO and Co-Founder of New York based, venture-backed Gojee, Inc. which was acquired by XO Group, Inc. Previously, Mike worked at Morgan Stanley for three years in the Investment Banking Division advising technology companies on strategic execution and in Equity Capital Markets focused on corporate return of capital. Prior to Morgan Stanley, Mike served in the U.S. Army as a 1st Lieutenant and led an Infantry platoon in the Kunar Province of Afghanistan. He graduated from the U.S. Army's Airborne, Air Assault and Ranger Schools and the United States Military Academy at West Point with a BS in Literature, Philosophy and Systems Engineering. Mike began his investment career at ACM as a summer research intern.

Evelyn Lu – Senior Associate Date of Birth – October 15, 1985 Joined ACM - 2014

Previously, Evelyn worked at Alpine Woods Capital Management for two years researching global public equities in the consumer, healthcare and real estate sectors. Prior to Alpine Woods, she was an investment banking analyst with BMO Capital Markets in the Healthcare Group and with Bank of America Merrill Lynch in the Financial Institutions Group. Evelyn graduated from Columbia University with a BA in Economics and Political Science and was a National Merit Scholar. She is a Chartered Financial Analyst and is fluent in Mandarin Chinese.

John P. Gibson – Research Analyst Date of Birth – April 27, 1993 Joined ACM - 2018

Previously, John was an Investment Banking Analyst within the Real Estate coverage group at Credit Suisse. While there, he assisted companies in the gaming, homebuilding, leisure, lodging and REIT industries with capital raises and M&A. Additionally, he held investment banking positions within the Industrials and Securities, Defense and Government Services sectors during college. John graduated from Vanderbilt University where he earned a BA in Economics and minored in Financial Economics and Spanish.
Item 3. Disciplinary Information
There are no disciplinary events regarding the investment professionals of ACM.

Item 4. Other Business Activities
The investment professionals of American Capital Management, Inc. are only involved in the investment related business of our firm.

Directorships
• Kristin Gamble is also Chairman of Scenic Hudson, Inc. an environmental organization involved in land preservation and advocacy for the Hudson River Valley.
• Luke P. La Valle, Jr. is a Director of Inrad Optics, Inc. where he is Chairman of the Audit Committee and member of the Compensation and Nominating Committees. Luke is also a member of the Investment Committee of the New York Athletic Club Endowment Fund. please register to get more info