Form ADV 2A

According to regulatory guidelines, Punch & Associates updates its Form ADV 2A annually.

General Disclosures

The material shown is for informational purposes only and should not be construed as accounting, legal, or tax advice.  Punch & Associates Investment Management, Inc. (“Punch & Associates”) is a registered investment advisor with the Securities and Exchange Commission; registration does not imply a certain level of skill or training.  While efforts are made to ensure information contained herein is accurate, Punch & Associates cannot guarantee the accuracy of all such information presented.

The performance information contained herein represents the unaudited and approximated composite performance of Punch & Associates Investment Management Inc. (“Punch & Associates”) clients’ accounts managed pursuant to the mandate described herein (the “Composite”).  The performance information was calculated by Punch & Associates, may be based upon certain assumptions and is shown net of all actual investment advisory fees paid by the client accounts included within the Composite.  Certain clients in the Composite direct Punch & Associates to reinvest income and dividends, while other clients direct Punch & Associates to not reinvest such earnings.  As such, performance data shown for the Composite includes or excludes the reinvestment of income and dividends as appropriate, depending on whether the client directed Punch & Associates to reinvest income and dividends.  Actual client accounts may incur other fees and expenses such as brokerage commissions, custodial costs and other expenses.  Accordingly, an account’s actual performance results will be reduced by any such other fees and expenses.  Punch & Associates’ investment advice, and the timing for implementing the advice, varies across clients.  Consequently, some of Punch & Associates’ clients experienced returns that were higher than those included in the Composite, while others experienced returns that were lower.  Past performance is not indicative of future performance, and all investments are subject to the risk of loss.  This material is not intended to meet the investment objectives or risk tolerance of any particular viewer and should not be construed as an offer to sell or buy any security.

Any benchmark indices shown are for illustrative and/or comparative purposes and have only been included to show the general trend in the markets in the periods indicated.  Such indices have limitations when used for comparison or other purposes because they may have volatility, credit, or other material characteristics (such as number and types of securities or instruments represented) that are different from those of the Composite and/or any client account, and they do not reflect the Composite’s investment strategy or any other investment strategies generally employed by Punch & Associates.  For example, the Composite for a particular client’s investment portfolio will generally hold substantially fewer securities than are contained in a particular index.

*Up & Down Capture: A statistical measure of an investment adviser's overall performance in up or down markets.  The up-market capture ratio is used to evaluate how well an investment adviser performed relative to an index during periods when that index has risen while down-capture ratio applies during periods when the market has fallen. The ratio is calculated by dividing the investment adviser's net of fee returns by the returns of the index during the respective up-market or down-market months and multiplying that factor by 100.

Some information may have been provided by or compiled based on information provided by third party sources.  Although Punch & Associates believes the sources are reliable, it has not independently verified any such information and makes no representations or warranties as to the accuracy, timeliness or completeness of such information.

Punch & Associates claims compliance with the Global Investment Performance Standards (GIPS^®) and has prepared and presented this report in compliance with the GIPS^® standards. Please contact us for current GIPS^® performance information.