AMERICANA PARTNERS, LLC

[LOGO GOES HERE] Americana Partners, LLC a Registered Investment Adviser 811 Louisiana Street, Suite 2420 Houston, TX 77002 June 18, 2025 This brochure provides information about the qualifications and business practices of Americana Partners, LLC (hereinafter "Americana Partners" or the "Firm"). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC's website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training. 1  Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment, dated March 21, 2024, we have made the following material changes to our Form ADV: • Items 7 and 10 disclose the launch of a new division, Americana Partners International, LLC catering to high net worth and ultra-high net worth international clients. • Item 5, Item 10, Item 12 and Item 14 were updated to disclose that certain persons providing investment advice on behalf of our firm are no longer registered representatives with SP Securities, LLC and Purshe Kaplan Sterling Investments, Inc. ("PKS"), securities broker-dealers, and members of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation and have removed all references to our previous broker-dealers. • Item 5, Item 10, Item 12 and Item 14 were updated to disclose that certain persons providing investment advice on behalf of our firm are also registered representatives with Saxony Securities, Inc., a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. • Item 12 was updated to include Pershing LLC as a new custodian we will use for custody and execution of transactions for international clients. We also disclose benefits available to us for recommending certain custodians and related conflicts arising from such arrangements. Item 13 provides additional information regarding consolidated reports we make available to clients. • 2  Item 3 Table of Contents Item 1 Cover Page Page 1 Item 2 Material Changes Page 2 Item 3 Table of Contents Page 3 Item 4 Advisory Business Page 4 Item 5 Fees and Compensation Page 8 Item 6 Performance-Based Fees and Side-By-Side Management Page 13 Item 7 Types of Clients Page 13 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Page 13 Item 9 Disciplinary Information Page 17 Item 10 Other Financial Industry Activities and Affiliations Page 17 Item 11 Code of Ethics Page 20 Item 12 Brokerage Practices Page 21 Item 13 Review of Accounts Page 27 Item 14 Client Referrals and Other Compensation Page 28 Item 15 Custody Page 29 Item 16 Investment Discretion Page 30 Item 17 Voting Client Securities Page 30 Item 18 Financial Information Page 31 Item 19 Additional Information Page 31 3  Item 4 Advisory Business Americana Partners offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to Americana Partners rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Americana Partners setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement"). Americana Partners is registered as an investment adviser since April 2019 and is primarily owned by Jason Fertitta. While this brochure generally describes the business of Americana Partners, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on Americana Partners' behalf and are subject to the Firm's supervision or control. Financial Planning and Consulting Services Americana Partners offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: Investment Consulting Insurance Planning • Business Planning • Cash Flow Forecasting • Trust and Estate Planning • Financial Reporting • • • Retirement Planning • Risk Management • Charitable Giving • Distribution Planning • Tax Planning • Manager Due Diligence While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, Americana Partners is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Americana Partners recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage Americana Partners or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Americana Partners under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Americana Partners' recommendations and/or services. Investment and Wealth Management Services Americana Partners manages client investment portfolios on a discretionary basis. In addition, Americana Partners provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary management of investment portfolios. 4  Americana Partners primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"), individual debt and equity securities, options, structured products, and independent investment managers ("Independent Managers") in accordance with their stated investment objectives. In addition, Americana Partners also recommends that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage Americana Partners to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Americana Partners directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider. Finally, clients can utilize the custodial relationships that the Firm has negotiated to custody assets that are not managed by the Firm. Americana Partners tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Americana Partners consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Americana Partners if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Americana Partners determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts. Options trading is permitted in the Investment and Wealth Services' program offered by Americana Partners. Clients should be aware that the use of options involves additional risks. Some of these risks are provided under Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss below. Clients with accounts custodied at Schwab that are approved for level 3 options trading, allows for all types of options trading. When purchasing options there is a risk that the entire premium paid (the purchase price) for the option can be lost if the option is not exercised or otherwise sold prior to the option's expiration date. When selling (or "writing") options, the risk of loss is much greater if the options are written uncovered or "naked". The risk of loss can far exceed the amount of the premium received for an uncovered option and in the case of an uncovered call option the potential loss is unlimited. Options trading is used for a limited number of clients and Americana Partners always strives to only allow trading activity that is in the best interest of the client. Management Services to Private Pooled Investment Vehicles We provide specialized discretionary advisory services to private pooled investment vehicles herein referred to as "the Funds" (or if individually, "the Fund"). The Funds are unregistered investment companies organized as limited partnerships. Investments in the Funds are not registered under the Securities Act of 1933, as amended, and are only offered after delivery of a private placement memorandum and execution of the subscription agreement and other offering documents. Investments in the Funds are offered only to accredited investors within the meaning of SEC Rule 501 of Regulation D of the Securities Act of 1933. Some Funds are offered only to qualified clients as defined within the meaning of Rule 205-3 under the Advisers Act. Investments in the Funds are offered by private offering memorandum which provides investors with full disclosure regarding the objectives of the Funds, the risks involved with the offering and the minimum initial capital contribution or commitment required. 5  Different strategies may be carried out for each Fund and therefore, there should be no expectation that the performance of any individual Fund would or should be similar to that of any other Fund. You should refer to the subscription agreement and other offering documents for a complete description of the fees, investment objectives, risks, and other relevant information associated with investing in the Funds. The Funds undergo an independent audit annually by a Public Company Accounting Oversight Board ("PCAOB") registered firm. Americana Partners does not use its discretionary trading authority to authorize purchases of the Funds. Instead, clients must complete and sign the required paperwork before the purchase is processed. Americana Partners charges advisory fees each quarter for the sale of the Funds. Use of Independent Managers As mentioned above, Americana Partners selects certain Independent Managers to actively manage a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. The Independent Managers' fees are in addition to the Firm's fees. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. Americana Partners evaluates a variety of information about Independent Managers, which includes the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance and risk results in relation to its clients' individual portfolio allocations and risk exposure. Americana Partners also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. Americana Partners continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Americana Partners seeks to ensure the Independent Managers' strategies and target allocations remain aligned with its clients' investment objectives and overall best interests. Held Away Assets We may leverage an Order Management System through Pontera to implement investment selection and rebalancing strategies on behalf of the client in held away accounts (i.e., accounts not directly held with our recommended custodian). These are primarily 401(k) accounts, HSAs, 403bs, 529 education savings plans, 457 plans, profit sharing plans, and other assets not custodied with our recommended custodian. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. Use of Dynasty Financial Partners, LLC TAMP Americana Partners has entered into a contractual relationship with Dynasty Financial Partners, LLC ("Dynasty"), which provides Americana Partners with operational and back office support including access to a network of service providers. Through the Dynasty network of service providers, Americana Partners may receive preferred pricing on trading technology, reporting, custody, brokerage, compliance and other related services. Dynasty charges a "Platform Fee," for which, unless otherwise disclosed, the client will be charged, separate from and in addition to such client's annual investment management fee, as described in Item 5 below. In addition, Dynasty's subsidiary, Dynasty Wealth Management, LLC ("DWM") is an SEC registered investment adviser, that provides access to a range of investment services including: separately managed accounts ("SMA"), mutual fund and ETF asset allocation strategies, and unified managed accounts ("UMA") 6  managed by external third party managers (collectively, the "Investment Programs"). Americana Partners and its clients may separately engage the services of Dynasty and/or its subsidiaries to access the Investment Programs. Under the SMA and UMA programs, Americana Partners will maintain the ability to select the specific, underlying third party managers that will, in turn, have day-to-day discretionary trading authority over the requisite client assets. DWM sponsors an investment management platform (the "Platform" or the "TAMP") that is available to the advisers in the Dynasty Network, such as Americana Partners. Through the Platform, DWM and Dynasty collectively provide certain technology, administrative, operations and advisory support services that allow advisers to manage their own portfolios and access independent third-party managers that provide discretionary services in the form of traditional managed accounts and investment models. Advisers can allocate all or a portion of client assets among the different independent third-party managers via the Platform. Advisers may also use the model management feature of the TAMP by creating their own asset allocation model and underlying investments that comprise the model. Through the model management feature, advisers may be able to outsource the implementation of trade orders and periodic rebalancing of the model when needed. Americana Partners will maintain the direct contractual relationship with each client and obtain, through such agreements, the authority to engage independent third-party managers, DWM and/or Dynasty, as applicable, for services rendered through the Platform in service of such client. Americana Partners may delegate discretionary trading authority to DWM and/or independent third-party managers to effect investment and reinvestment of client assets with the ability to buy, sell or otherwise effect investment transactions and allocate client assets. If a client is participating in certain Investment Programs, DWM or the designated manager, as applicable, is also authorized without prior consultation of Americana Partners or the client to buy, sell, trade or allocate such client's assets in accordance with the client's designated portfolio and to deliver instructions to the designated broker-dealer and/or custodian of such client's assets. IRA 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; • 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. 7  Assets Under Management As of January 31, 2025, we provide continuous management services for $4,517,931,927 in client assets on a discretionary basis, and $1,564,680,393 in client assets on a non-discretionary basis. We also manage $2,857,276,390 in client assets on a non-continuous basis. Item 5 Fees and Compensation Americana Partners offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under management or advisement. Additionally, certain of the Firm's Supervised Persons, in their individual capacities, offer securities brokerage services and/or insurance products under a separate commission-based arrangement. Financial Planning and Consulting Fees Americana Partners can charge a fixed fee or an asset-based fee for providing financial planning and consulting services under a stand-alone engagement. These fees are negotiable, but either range from $2,500 for projects and financial planning and up to $250,000 per year or from 5 to 50 basis points (0.05% - 0.50%) for ongoing investment consulting. The fixed fee or asset-based fee will depend upon the scope and complexity of the services and the representative rendering the financial planning and/or the consulting services. If the client engages the Firm for additional investment advisory services, Americana Partners may offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. You may terminate the financial planning or consulting services agreement upon written notice to our firm. If you have pre-paid financial planning and/or consulting fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning and/or consulting fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning and/or consulting agreement. The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement and Americana Partners requires the fixed fee will be due and payable upon delivery of the financial plan or completion of the agreed upon services. The asset-based fee will be due quarterly in advance based on the value of the assets on which consulting is provided. The Firm does not, however, take receipt of $1,200 or more in prepaid fees in excess of six months in advance of services rendered. Investment Management Fees Americana Partners offers investment management services for an annual fee based on the amount of assets under the Firm's management. This management fee, which does not include the additional fees discussed below, varies up to 200 basis points (2.00%), depending upon the size and composition of a client's portfolio and the type of services rendered. Americana Partners' annual fee is billed and payable on a pro-rata basis, quarterly in advance, based upon the market value of the assets being managed by the Firm on the last day of the previous quarter. Adjustments will be made for deposits and withdrawals in excess of $50,000 during the quarter. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, Americana Partners' fees will apply on a pro rata basis, which means that the management fee is payable in proportion to the number of days in the quarter for which you are a client. In the event the portfolio management agreement is terminated, the fee for the final billing period will be prorated through the effective date of termination, and the outstanding or unearned portion of the fee will be charged or refunded to the client, as appropriate. The Firm's management fee is negotiable, depending on individual client circumstances. 8  Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Americana Partners may negotiate a fee rate that differs from the range set forth above. Held Away Assets For assets held at a custodian that is not directly accessible by our firm ("Held Away Accounts"), we may, but are not required to, manage these Held Away Accounts using the Pontera Order Management System ("Pontera") that allows our firm to view and manage assets. Our annual fee for investment management services for held away accounts will follow our portfolio management fee schedule and termination instructions as noted above. Our advisory fees will not be deducted directly from the accounts managed through the Pontera Order Management System. The client does not pay an additional fee for Pontera. Fees will be based upon your negotiated fee in accordance to our portfolio management fee schedule and your Agreement. Clients will give written authorization to deduct the fee from an account managed by our firm, in which case, the advisory fee would be deducted from the account each quarter. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements and invoices for accuracy. We pay 0.25% from our advisory fee to Pontera. Due to the use of Pontera, you will not pay our firm a higher advisory fee other than what is listed above. Management Services to Pooled Investment Vehicles Americana Partners, LLC serves as the Investment Manager or Investment Adviser to the Funds. Typically, the Investment Manager or Investment Adviser is responsible for the management, operation and control of the investment activities of the Funds, to the extent provided in the Partnership Agreement and Management Agreement. The Investment Manager's primary functions will be to identify, analyze and select potential Portfolio Investments. Americana Partners, LLC charges a management fee or administration fee in accordance with the terms of each Fund. You should refer to the offering documents for a complete description of the fees and other relevant information associated with investing in the Funds. Generally, the management fees and administration fees are between 0% and 0.65% of the investors' capital or capital commitment. The fees are deducted from each Fund's account on a quarterly basis. For the Americana - Jet Linx Partners, LP fund, each Limited Partner will pay to the Partnership, and the Partnership will pay to the Investment Manager an annual management fee (the "Management Fee") equal to one percent (1%) of such Limited Partner's aggregate subscription amount. The Management Fee will be calculated and payable annually in advance for each calendar year. The General Partner may waive or reduce the Management Fee with respect to any Limited Partner. Fee Discretion Americana Partners may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention and pro bono activities. 9  Custodial Fees Schwab and Fidelity Transaction Fees For accounts custodied at Schwab, Fidelity or Pershing, additional transaction fees could be assessed for the following, as applicable: Transactions in NMS Securities U.S. Exchange-Listed Securities per Executed Trade Transactions in Non-NMS Securities U.S. Over-the-Counter (OTC) Securities Market Commissions per Executed Trade Canadian Stock Transactions Foreign Stock Transactions Mutual Fund Transaction Fee Electronic Channels Broker-Assisted Channels Options contract trades Prime Broker/Trade Away and Step-In Trades Custody Fees for Non-Publicly Traded Securities These fees are charged to you by the custodian/broker and are not shared with Americana Partners. The various fees you pay impact your investment's rate of return, and you should take these into account when selecting a custodian. When your account is opened, you will receive documentation from your custodian outlining the various fees that you pay, as applicable. You should keep this list as reference. Additional Fees and Expenses In addition to the advisory fees paid to Americana Partners, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively "Financial Institutions"). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent Managers, margin costs, charges imposed directly by a mutual fund or ETF in a client's account, as disclosed in the fund's prospectus (e.g., fund management fees and other fund expenses), 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. The Firm's brokerage practices are described at length in Item 12, below. As discussed above, Americana Partners uses Dynasty's TAMP services. TAMP related charges are not included in the Firm's investment management fee. Clients will be charged, separate from and in addition to the investment management fee, any applicable Platform Fees as well as applicable Independent Manager fees. Americana Partners does not receive any portion of the fees paid directly to Dynasty or the service providers made available through its platform, including the Independent Managers. 10  Each of the Platform Fee and independent manager fees are determined by the particular program(s) and manager(s) with which a client's assets are invested, and are calculated based upon a percentage of the assets under management, as applicable. The Platform Fee generally ranges from 0 - 0.45% annually, independent fixed income manager fees generally range from 0 - 0.90% annually, and independent equity manager fees generally range from 0 – 1.50% annually. Clients will note the total fee reflected on their custodial statement will represent the sum of Americana Partners' investment management fee, Platform Fee(s) and Independent Manager fee(s), accordingly. Clients should review such statements to determine the total amount of fees associated with their requisite investments, and should review their investment management agreement with Americana Partners to determine the investment management fee paid to the Firm. Direct Fee Debit Clients provide Americana Partners and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Americana Partners. Use of Margin Americana Partners can recommend that certain clients utilize margin in the client's investment portfolio or other borrowing. Americana Partners only recommends such borrowing for non-investment needs, such as bridge loans and other financing needs. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to Americana Partners' right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client's account. Clients can withdraw account assets on notice to Americana Partners, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client's investment objectives. Americana Partners may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Commissions and Sales Charges for Recommendations of Securities Clients can engage certain persons associated with Americana Partners (but not the Firm directly) to render securities brokerage services under a separate commission-based arrangement. Clients are under no obligation to engage such persons and may choose brokers or agents not affiliated with Americana Partners. Under this arrangement, the Firm's Supervised Persons, in their individual capacities as registered representatives of Saxony Securities, Inc. ("Saxony"), can provide securities brokerage services and implement securities transactions under a separate commission based arrangement. Supervised Persons are entitled to a portion of the brokerage commissions paid to Saxony, as well as a share of any ongoing distribution or service (trail) fees from the sale of mutual funds. Americana Partners can also recommend no- 11  load or load-waived funds, where no sales charges are assessed, but where the Supervised Person receives other forms of compensation. Prior to effecting any transactions, clients are required to enter into a separate account agreement with Saxony. The Firm can execute trades with a broker-dealer other than the client's primary custodian that nonetheless settle at and are held at the client's primary custodian ("trade away transactions"). Trade away transactions can be entered into on behalf of clients that have entered into agreements for prime brokerage clearing services with their custodian. Because clients are not required to execute a separate agreement with the other broker-dealer to enter into trade away transactions, the Firm and its Supervised Persons have discretion in selecting the broker-dealer to use to effect client transactions. The Firm will use Saxony for trade away transactions ("trade away transactions"). As discussed herein, certain of the Firm's Supervised Persons are registered representatives of Saxony and will receive transaction based compensation for the trade away transactions. Various conflicts of interest arise out of the trade away transactions. Among other things, the Firm's Supervised Persons have an incentive to engage in the trade away transactions where the advisory fees that the Supervised Person would otherwise earn for managing such assets is less than the compensation that the Supervised Person would earn by executing the transaction as a registered representative through Saxony. Such Supervised Persons also have an incentive to engage in frequent transactions through the trade away transactions arrangement because of the compensation that they can earn as registered representatives of Saxony. Frequent trading can increase the transaction costs charged to clients, negatively impact performance results, and have adverse tax consequences for clients. A conflict of interest also exists because the Firm's Supervised Persons have an incentive to recommend Saxony to execute trade away transactions on behalf of clients because they can earn brokerage compensation as registered representatives of Saxony (as opposed to other broker-dealers where the Supervised Person would not receive brokerage compensation). Additionally, because trade away transactions are deemed to be unsolicited trades by Saxony, Saxony does not conduct any suitability reviews with respect to securities acquired through trade away transactions. The Firm will continue to have a fiduciary duty over the client's advisory assets that are executed through the trade away transactions and has policies and procedures in place to mitigate the impact of the conflicts. In addition, the assets purchased through a trade away transaction will be held in accounts separate, or otherwise tracked separately, from other assets over which the Firm provides management services and charges management fees. The Firm does not charge clients advisory fees on assets acquired through trade away transactions. A conflict of interest exists to the extent that a Supervised Person of Americana Partners recommends the purchase or sale of securities through a brokerage relationship where that Supervised Persons receives commissions or other additional compensation as a result of that recommendation (the "Brokerage Relationship"). The Firm has procedures in place to ensure that any recommendations made by such Supervised Persons to engage in the Brokerage Relationship are in the best interest of that client. The Firm does not allow Supervised Persons to receive brokerage compensation on assets managed by the Firm. Because the Supervised Persons receives compensation in connection with the sale of mutual funds in the Brokerage Relationship, a conflict of interest exists as such Supervised Persons, has an incentive to recommend more expensive mutual fund share classes to clients where such Supervised Persons earn more compensation with respect to the sale of such mutual fund share classes. Clients should understand that the investments made in the Brokerage Relationship are not receiving advisory services from the Firm. Therefore, the Firm does not have a fiduciary duty over the Brokerage Relationship recommendations. Trade away transaction costs can be substantial and clients should ask their financial professional about the frequency of the trades and what costs are imposed by the trade away broker. 12  Item 6 Performance-Based Fees and Side-By-Side Management Americana Partners does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client's assets). Item 7 Types of Clients Americana Partners offers services to individuals, including high net worth and ultra high net worth international clients, trusts, estates, charitable organizations, corporations and business entities. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Americana Partners utilizes a combination of fundamental, technical, and charting methods of analysis. Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For Americana Partners, this process typically involves an analysis of an issuer's management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm's model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security. Technical analysis involves the examination of past market data rather than specific issuer information in determining the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Americana Partners will be able to accurately predict such a reoccurrence. Charting Analysis - involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data are used to detect departures from expected performance and diversification and predict future price movements and trends. As described above, Americana Partners tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Americana Partners consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. The Firm consider tax implications and all of its investment plans are customized to a particular family's unique situation. The Firm uses alternative investments with a goal of enhancing the risk adjusted returns of its portfolios. In addition, the Firm uses covered call writing strategies in attempt to enhance returns for large single stock positions. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm's investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. 13  Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Americana Partners' recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that Americana Partners will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client's assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Equity-Related Securities and Instruments The Firm may take long in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities Fixed income securities are subject to the risk of the issuer's or a guarantor's inability to meet principal and interest payments on its obligations and to price volatility. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund's stated daily per share net asset value ("NAV"), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund's holdings. The trading prices of a mutual fund's shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund's shares trading at a premium or discount to actual NAV. 14  Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of Independent Managers As stated above, Americana Partners selects certain Independent Managers to manage a portion of its clients' assets. In these situations, Americana Partners continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers' ability to successfully implement their investment strategies. In addition, Americana Partners does not have the ability to supervise the Independent Managers on a day-to-day basis. Use of Private Collective Investment Vehicles Americana Partners recommends that certain clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. Clients should consult each fund's private placement memorandum and/or other documents explaining such risks prior to investing. Options Options allow investors to buy or sell a security at a contracted "strike" price at or within a specific period of time. Clients may pay or collect a premium for buying or selling an option. Investors transact in options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate on the performance of the underlying securities. Options transactions contain a number of inherent risks, including the partial or total loss of principal in the event that the value of the underlying security or index does not increase/decrease to the level of the respective strike price. Holders of options contracts are also subject to default by the option writer which may be unwilling or unable to perform its contractual obligations. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer exercises the option, and will receive the specified number of shares. The option writer/seller receives a premium (the market price of the option at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Options Contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: 15  A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks pertaining to options buyers are: • Risk of losing your entire investment in a relatively short period of time. • The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). • European style options which do not have secondary markets on which to sell the options prior to expiration can only realize its value upon expiration. • Specific exercise provisions of a specific option contract may create risks. • Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks pertaining to options sellers are: • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk substantial losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. • Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how the leverage in options can work against the option trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. • Call options can be exercised outside of market hours such that effective remedy actions cannot be performed by the writer of those options. • Writers of stock options are obligated under the options that they sold even if a trading market is not available or that they are unable to perform a closing transaction. • The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: • The complexity of some option strategies is a significant risk on its own. • Option trading exchanges or markets and option contracts themselves are open to changes at all times. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. • Risk of erroneous reporting of exercise value. • • Risks that are not specific to options trading include market risk, sector risk and individual stock risk. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. 16  Use of Structured Products Structured products are securities whose value is derived from, or based on, a reference asset, market measure or investment strategy. Reference assets and market measures may include single equity or debt securities, indexes, commodities, interest rates and/or foreign currencies, as well as baskets of these reference assets or market measures. Structured products are created to meet specific needs that may not be met from the standardized financial instruments available in the markets. Structured products have standard investment risks as well as risks specific to the product, including: i) potential loss of principal, especially if the investor does not hold the instrument to full maturity; ii) market prices may fluctuate based on the underlying asset and issuer's creditworthiness; iii) credit risk; and iv) call provisions. Use of Margin While the use of margin borrowing for investments can substantially improve returns, it may also increase overall portfolio risk. Margin transactions are generally effected using capital borrowed from a Financial Institution, which is secured by a client's holdings. Under certain circumstances, a lending Financial Institution may demand an increase in the underlying collateral. If the client is unable to provide the additional collateral, the Financial Institution may liquidate account assets to satisfy the client's outstanding obligations, which could have extremely adverse consequences. In addition, fluctuations in the amount of a client's borrowings and the corresponding interest rates may have a significant effect on the profitability and stability of a client's portfolio. Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Item 9 Disciplinary Information Americana Partners has not been involved in any legal or disciplinary events that are material to a client's evaluation of its advisory business or the integrity of its management. Item 10 Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. Registered Representatives of a Broker-Dealer Certain of the Firm's Supervised Persons are registered representatives of Saxony and provide clients with securities brokerage services under a separate commission-based arrangement. This arrangement is described at length in Item 5. Arrangements with Affiliated Entities We are affiliated with Americana PE GP, LLC by virtue of common control and ownership. Specifically, Jason Fertitta, Robert Wellington and Michael Mithoff serve as the Principals of this entity. We are also affiliated with Americana Partners International LLC by virtue of common control and ownership. In addition, Americana PE GP, LLC serves as the General Partner to Americana - TB Discover Fund III, LP, Americana - El Energy Transition Fund I, LP, Americana - SG Credit Fund II, LP, Americana - TB Series 2022, LP, Americana - LGP Series 2022, LP, Americana - Jet Linx Partners, LP, Americana - TB Series 2024, LP, AP Private Markets 2024 Vintage Fund LP and Americana - Big Flow Partners, LP (the "Funds" or if individually, "the Fund") where Americana Partners, LLC is also the Investment Manager or Investment Adviser. 17  The Fund is offered to certain sophisticated investors, who meet certain requirements under applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a private placement memorandum and other offering documents. The fees charged by the Fund are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Fund. Persons affiliated with our firm may have made an investment in the Fund and may have an incentive to recommend the Fund over other investments. We are also affiliated with Americana Partners Planning Strategies through common control and ownership. Therefore, persons providing investment advice on behalf of our firm may be licensed as insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate from our advisory fees. See the Fees and Compensation section in this brochure for more information on the compensation received by insurance agents who are affiliated with our firm. This affiliated firm is otherwise regulated by the professional organizations to which it belongs and must comply with the rules of those organizations. These rules may prohibit paying or receiving referral fees to or from investment advisers that are not members of the same organization. Referral arrangements with an affiliated entity present a conflict of interest for us because we may have a direct or indirect financial incentive to recommend an affiliated firm's services. While we believe that compensation charged by an affiliated firm is competitive, such compensation may be higher than fees charged by other firms providing the same or similar services. You are under no obligation to use the services of any firm we recommend, whether affiliated or otherwise, and may obtain comparable services and/or lower fees through other firms. Private Pooled Investment Vehicles Americana Partners, LLC serves as the Investment Manager or Investment Adviser to Americana - TB Discover Fund III, LP, Americana - El Energy Transition Fund I, LP, Americana - SG Credit Fund II, LP, Americana - TB Series 2022, LP, Americana - LGP Series 2022, LP, Americana - Jet Linx Partners, LP Americana - TB Series 2024, LP, AP Private Markets 2024 Vintage Fund LP and Americana - Big Flow Partners, LP (the "Funds" or if individually, "the Fund"). The Funds' objective is to allow investors to participate in strategic investment opportunities in the private equity space. To the extent that Americana Partners LLC's individual advisory clients qualify and determine that an investment is appropriate given their investment objective(s) and financial situation, they may participate as limited partners of the Funds. The terms and conditions for participation in the Funds, including management and/or incentive fees, conflicts of interest, risk factors, and liquidity constraints, are set forth in the Funds offering documents, which each prospective investor client shall receive and shall be required to complete. The client shall be required to submit the corresponding Subscription Agreement to the General Partner in order to demonstrate qualification for investment in the Fund. Please Note: We may provide investment advice regarding private investment funds. Private investment funds generally involve risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund's offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may maintain, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. 18  Conflicts of Interest: Because Americana Partners, LLC, our affiliates and/or our members shall earn compensation from the Private Fund that may exceed the fee that Americana Partners would earn under its standard "assets under management" fee schedule, this presents a conflict of interest. No client is under any obligation to become a Private Fund investor. Certain Associated Persons of our firm are also invested in the Fund. As investors, they have an incentive to devote more time to the Fund than to your or to provide limited investment opportunities to the Fund instead of you. Furthermore, they may have an incentive to recommend the Fund rather than recommending other investments. We address these conflicts by disclosing them in this brochure and in the offering documents of the Fund. While we believe these relationships are commonplace in the investment industry and bring added value to our clients, the Associated Persons serving in these separate capacities are fiduciaries and are required to act at all times in accordance with our Code of Ethics and to act only from principles of fair and equitable dealing and good faith with respect to all parties. Licensed Insurance Agents A number of the Firm's Supervised Persons are licensed insurance agents and offer certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that Americana Partners recommends the purchase of insurance products where its Supervised Persons are entitled to insurance commissions or other additional compensation. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients' best interest regardless of any such affiliations. Relationship with Crescent Capital Americana has entered into a credit facility with Crescent Capital to finance certain business operations. This financial arrangement creates a potential conflict of interest to the extent that it may provide an incentive for the firm to favor investment products, strategies, or business decisions that support the repayment or terms of the credit facility. Americana does not believe that this arrangement compromises its fiduciary duty to clients. We maintain policies and procedures designed to identify and mitigate conflicts of interest, and all investment decisions are made in the best interest of our clients. Relationship with Dynasty Financial Partners, LLC As described herein, Americana Partners maintains a business relationship with Dynasty. Dynasty offers operational and back office core service support including access to a network of service providers. Through the Dynasty network of service providers, Americana Partners may receive preferred pricing on trading technology, transition support, reporting, custody, brokerage, compliance, and other related consulting services. While Americana Partners believes this open architecture structure for operational services best serves the interests of its clients, this relationship may potentially present certain conflicts of interest due to the fact that Dynasty is paid by Americana Partners or its clients for the services referenced above. In light of the foregoing, Americana Partners seeks at all times to ensure that any material conflicts are addressed on a fully-disclosed basis and handled in a manner that is aligned with its clients' best interests. Americana Partners does not receive any portion of the fees paid directly to Dynasty, its affiliates or the service providers made available 19  through Dynasty's platform. In addition, Americana Partners reviews such relationships, including the service providers engaged through Dynasty, on a periodic basis in an effort to ensure clients are receiving competitive rates in relation to the quality and scope of the services provided. Americana Partners has entered into an agreement with Dynasty Capital Strategies, LLC, a wholly-owned subsidiary of Dynasty and an affiliate of DWM to sell, via a note, an agreed percentage of the revenue generated by Americana Partners and in return receives a fixed amount of funds payable over an agreed time frame. Such funds may be used for business transition expenses and other costs associated with launching operations and for business expansion. Americana Partners is not obligated to enter into such a note in order to obtain other services from Dynasty, however, such notes are only made available for advisers who remain members of the Dynasty Network of registered investment advisers. The notes are subject to standard underwriting practices by Dynasty and are based on commercially reasonable terms. Americana Partners and its representatives may refer clients to the Demand Deposit MarketplaceSM Program (the "DDM Program") operated by Stable Custody Group II, LLC with administrative assistance from Reich & Tang Deposit Solutions, LLC. The Firm may receive compensation for client participation in the DDM Program, such as an advisory fee and/or a percentage of the fee income generated through the DDM Program. A recommendation by Americana Partners that a client participate in the DDM Program presents a conflict of interest, as the receipt of related compensation may provide an incentive to recommend the product based on such compensation, rather than on a particular client's need. No client is under any obligation to purchase any products or services recommended by Americana Partners or its representatives. Clients are reminded that they may purchase or select other potentially similar products or services recommended by the Firm through parties from which the Firm does not stand to receive any additional benefit or compensation. Item 11 Code of Ethics Description of Our Code of Ethics As discussed above in the Other Financial Industry Activities and Americana Partners has adopted a code of ethics in compliance with applicable securities laws ("Code of Ethics") that sets forth the standards of conduct expected of its Supervised Persons. Americana Partners' Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of Americana Partners' personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm's Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm's policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • 20  • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers' acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Americana Partners to request a copy of its Code of Ethics. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers' acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact Americana Partners to request a copy of its Code of Ethics. Participation or Interest in Client Transactions - Private Pooled Investment Vehicle/Sponsor of Limited Partnership As discussed above in the Other Financial Industry Activities and Affiliations section, we are affiliated with the Funds. As the investment adviser, our firm has a nominal interest in these Funds and our employees invest alongside our investment advisory clients. Such interest and side by side sharing may encourage our firm to advise clients to invest their assets in the partnerships and may influence the allocation of these assets. We review client portfolios on a regular basis in conjunction with allocation guidelines to ensure that they are invested solely in the best interests of the client and in accordance with the client's investment objectives. By virtue of the client's relationship as an advisory client of our firm, all investment adviser representatives of our firm owe a fiduciary duty to any such client and will be required to consider the client's investment objectives and individual situation before and while engaging in any private offering to such client. Aggregated Trading As discussed above in the Other Financial Industry Activities and Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). Refer to the Brokerage Practices section in this brochure for information on our aggregated trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities Item 12 Brokerage Practices Recommendation of Broker-Dealers for Client Transactions Americana Partners recommends that clients utilize the custody, brokerage and clearing services of Charles Schwab & Co, Inc. through its Schwab Advisor Services division ("Schwab"), Fidelity Investments ("Fidelity") and Kingdom Trust for domestic investment management accounts and Pershing LLC ("Pershing") for international clients. The final decision to custody assets with Schwab or Fidelity is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA account holder. Americana Partners is independently owned and operated and 21  not affiliated with Schwab, Fidelity or Pershing. Schwab, Fidelity and Pershing provide Americana Partners with access to their institutional trading and custody services, which are typically not available to retail investors. Factors which Americana Partners considers in recommending Schwab, Fidelity, Pershing or any other broker- dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Schwab, Fidelity, Pershing or any other broker-dealer to clients enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. Schwab has also agreed to reimburse clients for exit fees associated with moving accounts to Schwab. The reimbursement is only available up to a certain amount for all of the Firm's clients over a twelve month period. Fees are reimbursed on a first-come-first-served basis so that no clients are favored. The commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial Institutions. The commissions paid by Americana Partners' clients to Schwab, Fidelity, Pershing or any other broker-dealer to clients comply with the Firm's duty to obtain "best execution." Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Americana Partners determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution's services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Americana Partners seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Consistent with obtaining best execution, brokerage transactions are directed to certain broker-dealers in return for investment research products and/or services which assist Americana Partners in its investment decision-making process. Such research will be used to service all of the Firm's clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client's portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Americana Partners does not have to produce or pay for the products or services. Americana Partners periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The custodian and brokers we use We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15—Custody, below). Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. As noted, we recommend that our domestic clients use Schwab, Fidelity, Pershing, or any other broker-dealer to clients, each a registered broker-dealer, each a member SIPC, as the qualified custodian. We recommend Pershing as the qualified custodian for international clients ("collectively the Custodians/Brokers"). We are independently owned and operated and are not affiliated with Schwab or Pershing. The Custodians/Brokers will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab, Fidelity or Pershing as custodian/broker, you will decide whether to do so and will open your account with the Custodians/Brokers by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. 22  We do not open the account for you, although we may assist you in doing so. Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at the Custodians/Brokers, and we anticipate that most trades will be executed through Custodians/Brokers, we can still use other brokers to execute trades for your account as described below (see "Your brokerage and custody costs"). How we select brokers/custodians We seek to recommend Schwab, Fidelity or Pershing, as custodian/brokers that will hold your assets and execute transactions. When considering whether the terms that the Custodians/Brokers provide are, overall, most advantageous to you when compared with other available providers and their services, we take into account a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Services delivered or paid for by the Custodians/Brokers • Availability of other products and services that benefit us, as discussed below (see "Products and services available to us from the Custodians/Brokers") Your brokerage and custody costs For our clients' accounts maintained at Schwab, Fidelity or Pershing, the Custodians/Brokers generally do not charge you separately for custody services but are compensated by charging you commissions or other fees on trades that it executes or that settle into your account. Certain trades (for example, many mutual funds and ETFs) may not incur commissions or transaction fees. Custodians/Brokers are also compensated by earning interest on the uninvested cash in your account such as in Schwab's Cash Features Program. Schwab charges clients in this program a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we use the Custodians/Brokers to execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Custodians/Brokers, we have determined that using the Custodians/Brokers to execute most trades is consistent with our duty to seek "best execution" of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How we select brokers/custodians"). By using another broker or dealer you may pay lower transaction costs. 23  Products and services available to us from the Custodians/Brokers Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. Pershing offers similar services that provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services from other financial institutions without going through us. The Custodians/Brokers also make available to us various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. These support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed description of the various support services available: Services that benefit you. We have access to institutional brokerage services including access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available to us include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. The Custodians/Brokers make available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include proprietary investment research, including third party research. We use this research to service all or a substantial number of our clients' accounts, including accounts not maintained at Schwab or Pershing. In addition to investment research, we also have access to software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements) • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts • Provide pricing and other market data • Facilitate payment of our fees from our clients' accounts • Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. From time to time, the Custodians/Brokers also offer other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support The Custodians/Brokers will offer these services directly or arrange for third-party vendors to provide the services to us at a discount or waive its fees for some of these services or pay all or a part of a third party's fees. The Custodians/Brokers also provide us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Our interest in Receiving Certain Benefits The availability of these services and benefits from Schwab or Pershing benefits us because we do not have to produce or purchase them. These services are not contingent upon us committing any specific amount of business to Schwab or Pershing in trading commissions or assets in custody. The fact that we receive these benefits from Schwab or Pershing is an incentive for us to recommend clients use these Custodians/Brokers rather than making such a decision based exclusively on our client's interest in receiving the best value in 24  custody services and the most favorable execution of securities transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our recommendation of these Custodians/Brokers is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of the overall services provided (see "How we select brokers/ custodians") and not based on the services that benefit only us. Software and Support Provided by Financial Institutions Americana Partners also receives without cost from Schwab and Fidelity administrative support, computer software, related systems support, as well as other third party support as further described below (together "Support") which allow Americana Partners to better monitor client accounts maintained at Schwab and Fidelity and otherwise conduct its business. Americana Partners receives the Support without cost because the Firm renders investment management services to clients that maintain assets at Schwab. The Support is not provided in connection with securities transactions of clients (i.e., not "soft dollars"). The Support benefits Americana Partners, but not its clients directly. Clients should be aware that Americana Partners' receipt of economic benefits such as the Support from a broker-dealer creates a conflict of interest since these benefits will influence the Firm's choice of broker-dealer over another that does not furnish similar software, systems support or services, especially because the support is contingent upon clients placing a certain level(s) of assets at Schwab. In fulfilling its duties to its clients, Americana Partners endeavors at all times to put the interests of its clients first and has determined that the recommendation of Schwab or Fidelity is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, Americana Partners receives the following benefits from Schwab and Fidelity: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. In addition, the Firm receives funds to be used toward qualifying third-party service providers for research, marketing, compliance, technology and software platforms and services. These funds and the Support are generally available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain amount of the advisor's clients' assets are maintained in accounts at Schwab Advisor Services. Schwab's services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For client accounts maintained in its custody, Schwab and Fidelity generally do not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab and Fidelity also make available to the Firm other products and services that benefit the Firm but may not benefit its clients' accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Schwab or Fidelity. Other potential benefits may include occasional business entertainment of personnel of Americana Partners by Schwab or Fidelity personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Americana Partners in managing and administering clients' accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of the Firm\'s fees from its clients' accounts, and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of the Firm's 25  accounts, including accounts not maintained at Schwab or Fidelity. Schwab and Fidelity also make available to Americana Partners other services intended to help the Firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab and Fidelity may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Schwab and Fidelity may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to the Firm. While, as a fiduciary, Americana Partners endeavors to act in its clients' best interests, the Firm\'s recommendation that clients maintain their assets in accounts at Schwab or Fidelity may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab or Fidelity, which creates a potential conflict of interest. Economic Benefits As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we will also have access to research products and services from your account custodian and/or other brokerage firm. These products may include financial publications, information about particular companies and industries, research software, speaking engagements valued up to $15,000, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision- making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms, and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals Americana Partners does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct Americana Partners in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to "batch" client transactions for execution through other Financial Institutions with orders for other accounts managed by Americana Partners (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Americana Partners may decline a client's request to direct brokerage if, in the Firm's sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Commissions or Sales Charges for Recommendations of Securities As discussed above, certain Supervised Persons in their respective individual capacities are registered representatives of Saxony. These Supervised Persons are subject to FINRA Rule 3280 which restricts registered representatives from conducting securities transactions away from their broker-dealer unless the registered representatives give prior notice of such transactions to Saxony and, in most circumstances, Saxony provides written consent. Therefore, clients are advised that certain Supervised Persons are restricted to 26  conducting securities transactions through Saxony if they have not secured written consent from Saxony to execute securities transactions though a different broker-dealer. Absent such written consent or separation from Saxony, these Supervised Persons are generally prohibited from executing securities transactions through any broker-dealer other than Saxony under its internal supervisory policies. The Firm is cognizant of its duty to obtain best execution and has implemented policies and procedures reasonably designed in such pursuit. Trade Aggregation Transactions for each client will be effected independently, unless Americana Partners decides to purchase or sell the same securities for several clients at approximately the same time. Americana Partners may (but is not obligated to) combine or "batch" such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm's clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among Americana Partners' clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Americana Partners' Supervised Persons may invest, the Firm does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Americana Partners does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account's assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Item 13 Review of Accounts Account Reviews Americana Partners monitors client portfolios on a continuous and ongoing basis while regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by the client's primary advisor and the client service associate. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Americana Partners and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and quarterly to discuss the impact resulting from any changes in the client's financial situation and/or investment objectives. Account Statements and Reports 27  Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from Americana Partners and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. At the client's request, we will prepare consolidated reports that may contain assets reported by the client that are not managed by us. For certain non-managed assets such as private equity investments or real estate holdings that cannot be independently priced by us, we will use prices provided by the clients. Non-managed assets will be shown on client reports as an accommodation to the client. Any benchmarks shown on the client reports are presented for informational purposes only and are not a promise or guarantee that an account will meet or exceed the benchmarks. The information in the client reports may vary from custodial statements due to, among other things, differences in reporting dates, or pricing differences. The custodian statements are the accounts only official records. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from Americana Partners or an outside service provider and promptly notify us of any errors or discrepancies. Item 14 Client Referrals and Other Compensation Charles Schwab & Co., Inc - Institutional We receive an economic benefit from Schwab and other financial institutions in the form of the support products and services made available to us and other independent investment advisors whose clients maintain their accounts at Schwab or the designated financial institution. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients' assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab or other financial institutions, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). Client Referrals The Firm has described additional compensation it receives from Schwab in Item 12, above. Dynasty has assisted Americana Partners in negotiating or facilitating the payments described. In some instances, Dynasty may serve in an administrative capacity to support the disbursement of these funds furnished by the custodian. Demand Deposit MarketplaceSM Program Clients and prospective clients should review Item 10 for information about parties to whom we may refer clients and additional compensation we may receive from these parties. As disclosed under the Fees and Compensation section in this brochure, persons providing investment advice on behalf of our firm are licensed insurance agents, and are registered representatives with Saxony Securities, Inc. ("Saxony"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. For information on the conflicts of interest this presents, and how we address these conflicts, refer to the Fees and Compensation section. We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or firm for client referrals. Refer to the Brokerage Practices section above for disclosures on research and other benefits we may receive resulting from our relationship with your account custodian. 28  Item 15 Custody Americana Partners is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm's fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, Americana Partners will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from Americana Partners. Any other custody disclosures can be found in the Firm's Form ADV Part 1. Trustee Services Persons associated with our firm may serve as trustees to certain accounts for which we also provide investment advisory services. In all cases, the persons associated with our firm have been appointed trustee as a result of a family or personal relationship with the trust grantor and/or beneficiary and not as a result of employment with our firm. Therefore, we are not deemed to have custody over the advisory accounts for which persons associated with our firm serve as trustee. Wire Transfer and/or Standing Letter of Authorization Our firm, or persons associated with our firm, may effect asset transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third party asset transfers has access to the client's assets, and therefore has custody of the client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We hereby confirm that we meet the above criteria. 29  Held Away Assets For assets held at a custodian that is not directly accessible by our firm ("Held Away Accounts") and are managed through the Pontera management system, our advisory fees will not be deducted directly from your non-qualified accounts. The client does not pay an additional fee for Pontera. Fees will be based upon your negotiated fee in accordance to our portfolio management fee schedule and your Agreement. Refer to Item 5 - Fees and Compensation for further information. We will bill on a quarterly basis, in advance, based upon the market value of the assets in held away accounts managed through the Pontera Order Management System as of the last day of the previous quarter. Please refer to Item 5, Fees and Compensation for detailed information on billing. Private Investment Companies We serve as the investment adviser to Americana - TB Discover Fund III, LP, Americana - El Energy Transition Fund I, LP, Americana - SG Credit Fund II, LP, Americana - TB Series 2022, LP, Americana - LGP Series 2022, LP, Americana - Jet Linx Partners, LP, Americana - TB Series 2024, LP, AP Private Markets 2024 Vintage Fund LP and Americana - Big Flow Partners, LP (the "Funds" or if individually, "the Fund"), each a private pooled investment vehicle in which our clients are solicited to invest. The Fund is offered to certain sophisticated investors, who meet certain requirements under applicable state and/or federal securities laws. Investors to whom the Fund is offered will receive a private placement memorandum and other offering documents. The fees charged by the Fund are separate and apart from our advisory fees. You should refer to the offering documents for a complete description of the fees, investment objectives, risks and other relevant information associated with investing in the Fund. Persons affiliated with our firm may have made an investment in the Fund and may have an incentive to recommend the Fund over other investments. In our capacity as investment manager or investment adviser to the Fund, we will have access to the Fund's funds and securities, and therefore have custody over such funds and securities. We provide each investor in the Fund with audited annual financial statements. If you are a Fund investor and have questions regarding the financial statements or if you did not receive a copy, contact us directly at the telephone number on the cover page of this brochure. Item 16 Investment Discretion Americana Partners is given the authority to exercise discretion on behalf of clients. Americana Partners is considered to exercise investment discretion over a client's account if it can effect and/or direct transactions in client accounts without first seeking their consent. Americana Partners is given this authority through a power- of-attorney included in the agreement between Americana Partners and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Americana Partners takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17 Voting Client Securities When requested by Client, Americana will determine how to vote proxies based on our reasonable judgment of the vote most likely to produce favorable financial results for you. Proxy votes generally will be cast in favor of proposals that maintain or strengthen the shared interests of shareholders and management, increase shareholder value, maintain or increase shareholder influence over the issuer's board of directors and management, and maintain or increase the rights of shareholders. Generally, proxy votes will be cast against proposals having the opposite effect. However, we will consider both sides of each proxy issue. Unless we receive specific instructions from you, we will not base votes on social considerations. 30  In the event you wish to direct our firm on voting a particular proxy, you should contact our main office at the phone number on the cover page of this brochure with your instruction. Conflicts of interest between you and our firm, or a principal of our firm, regarding certain proxy issues could arise. If we determine that a material conflict of interest exists, we will take the necessary steps to resolve the conflict before voting the proxies. For example, we may disclose the existence and nature of the conflict to you, and seek direction from you as to how to vote on a particular issue; we may abstain from voting, particularly if there are conflicting interests for you (for example, where your account(s) hold different securities in a competitive merger situation); or, we will take other necessary steps designed to ensure that a decision to vote is in your best interest and was not the product of the conflict. We keep certain records required by applicable law in connection with our proxy voting activities. You may obtain information on how we voted proxies and/or obtain a full copy of our proxy voting policies and procedures by making a written or oral request to our firm. Item 18 Financial Information Americana Partners is not required to disclose any financial information due to the following: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Americana Partners has entered into a loan or credit facility with Crescent Capital. While this facility does not impair our ability to meet contractual or regulatory obligations to clients, it may be perceived as a potential conflict of interest. Item 19 Additional Information Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 31