CRESTA ADVISORS, LTD.

Item 1 Cover Page Cresta Advisors, Ltd. 2019 E. Del Mar Blvd., Suite 100 Laredo, TX 78041 (956) 267-8130 www.crestaadvisors.com March 10, 2025 This Brochure provides information about the qualifications and business practices of Cresta Advisors, Ltd. (“Cresta Advisors”, “us”, “we”, “our”). If you have any questions about the contents of this Brochure, please contact us at (956) 267-8130 or via email at manuel@crestaadvisors.com. 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. information about Cresta Advisors is also available via Additional the SEC’s website www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Cresta Advisors is 169641. The SEC’s web site also provides information about any persons affiliated with Cresta Advisors who are registered, or are required to be registered, as Investment Adviser Representatives of Cresta Advisors. Cresta Advisors is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information that you may use to determine whether to hire or retain them.  Item 2 Material Changes Since our last annual filing on March 20, 2024, we have amended our fees for Public Funds Services. Please see our wrap fee brochure for details. In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year end which is December 31st. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure may be requested at any time, without charge, by contacting Manuel Garza at (956) 267-8130. Cresta Advisors ADV Part 2A March 25 Page 2 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Item 3 – Table of Contents Item 1 Cover Page ..........................................................................................................................1 Item 2 Material Changes ................................................................................................................2 Item 3 – Table of Contents .................................................................................................................3 Item 4 – Advisory Business Introduction .............................................................................................4 Item 5 – Fees and Compensation ...................................................................................................... 10 Item 6 – Performance Based Fee and Side by Side Management ....................................................... 11 Item 7 – Types of Client(s) ................................................................................................................ 11 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 12 Item 9 – Disciplinary Information ..................................................................................................... 17 Item 10 – Other Financial Industry Activities and Affiliations ............................................................. 18 Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading ................ 19 Item 12 – Brokerage Practices .......................................................................................................... 20 Item 13 – Review of Accounts ........................................................................................................... 21 Item 14 – Client Referrals and Other Compensation .......................................................................... 21 Item 15 – Custody ............................................................................................................................ 21 Item 16 – Investment Discretion ....................................................................................................... 23 Item 17 – Voting Client Securities ..................................................................................................... 23 Item 18 – Financial Information ........................................................................................................ 24 Cresta Advisors ADV Part 2A March 25 Page 3 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Item 4 – Advisory Business Introduction Our Advisory Business Cresta Advisors is a Registered Investment Adviser (“Adviser”) which offers investment advice, securities, insurance, and other financial services to clients (“you”). We are registered through and regulated by the SEC. We provide investment advice through Investment Adviser Representatives (“Advisor”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all advisors are required to have commensurate industry or educational experience. Cresta Advisors was founded in 2013 by Partners Manuel Garza and Mark Deutsch. We provide portfolio management services primarily to clients in Texas, California, and Mexico, consisting of individuals, high net worth individuals, trusts, estates, corporations, endowments, non-profits and small businesses. We offer our Cresta wrap program to our clients. A wrap program is one in which you pay a single “wrapped” fee for both investment advisory and brokerage execution services. This wrap fee is not based on the number of transactions made in your account. It is based on the size of the account(s) we manage for you. Because wrap programs do not have fees or charges associated with each transaction, wrap fees are generally higher for similar services than non-wrap fees. For more information regarding this program please refer to our Wrap Fee brochure. If we determine that it is in your best interest, we may recommend the use of annuity products including indexed and variable annuities. Annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and some participation growth, if any, of a stock market index. For a description of the risks associated with indexed annuities, please see Item 8 below. Services Non-Discretionary ERISA 3(21) Fiduciary Cresta offers ERISA retirement plan services for Plan Sponsors on a non-wrap fee basis. In this program: Cresta acknowledges that it is a “fiduciary” with respect to the Client as that term is defined under Section 3(21)(A) of ERISA. The Adviser agrees to obtain and maintain an ERISA bond satisfying the requirements of Section 412 of ERISA and include The Adviser and its members, agents and employees among those insured under that bond unless provided by the Plan. The person signing this Agreement on behalf of the Client acknowledges its status as a “named fiduciary” with respect to the control and management of the assets held in the Account, and agrees to notify the Adviser promptly of any change in the identity of the named fiduciary with respect to the Account; When delivering ERISA fiduciary services, we will perform those services for the retirement plan as a fiduciary and will act in good faith and with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances. In our capacity as a 3(21) plan fiduciary, we will conduct research to determine appropriate investment selections and allocations and Cresta Advisors ADV Part 2A March 25 Page 4 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  to project potential ranges of returns and market values over various time periods and using various cash flows to assist the plan sponsor in determining the appropriate model(s)investment(s) for the retirement plan. Under this arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor, who has the ultimate responsibility to accept or reject the recommendation. The Adviser will not have any further responsibility to communicate instructions to any third‐party, including the custodian, and/or third‐party administrator. The Adviser will communicate directly with the recordkeeper regarding administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan. The Adviser will provide the Plan Sponsor with a sample investment policy statement. Each retirement Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the Adviser’s investment advisory services. Based on the circumstances of the Plan Sponsor, the Adviser may offer the following 3(21) services: • Plan design and asset selection consultation • Develop and annually review Investment Policy Statement (“IPS”) • Develop investment menu according to the IPS • Review plan sponsor’s stated financial criteria for each investment option • Monitor each investment option according to the IPS • Quarterly portfolio statements, rate of return reports, asset allocation statements • Provide investment research and performance information on investment options • Investment option replacement guidance • Personal consultations with the plan sponsor as necessary • Develop Plan Investment Committee Charter, as needed • Fiduciary due diligence assistance • Attendance at Plan Committee and other meetings • Annual Fiduciary Plan Review • Fiduciary education services to Plan Committee • Participant education, guidance, and enrollment • Vendor coordination assistance • Benchmarking services The Adviser will conduct research to determine appropriate investment selections and allocations and to project potential ranges of returns and market values over various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate investment options for the retirement plan. Cresta Advisors ADV Part 2A March 25 Page 5 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  The data used to select the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indices that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indices and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to recommend the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the responsibility and authority to make the final decision regarding what investments to include and when to add or exclude a specific security. The Client confirms that any instructions that have been given to the Adviser with regard to the Account are consistent with the governing plan documents and investment policy statements of the plan. Except as otherwise provided under ERISA the Adviser shall not be liable for any error of judgment or mistake of law or for any loss suffered by the Client in connection with the matters to which this Agreement relates except a loss resulting from the Adviser’s breach of its fiduciary duty, negligence, misconduct or bad faith. The Adviser is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended (the “Code”); The Adviser is neither a law firm nor a public accounting firm and Adviser will not provide legal or accounting advice; The Client acknowledges that the services covered by this Agreement are consultative, and give no investment authority (“discretion”) or responsibility to the Adviser over any assets of the Plan or Participant regardless of how and where the assets are held. Throughout the term of this Agreement, the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held with any affiliated or unaffiliated third-party. The Adviser encourages plan sponsors to consult with other professional advisors since we do not provide tax or legal advice that may affect asset classes or allocations. The Adviser will apply any guidelines the client supplies, as directed, however, compliance with these restrictions or guidelines, is the client’s responsibility. Discretionary 3(38) Fiduciary Services When a client engages the Adviser to perform “3(38) Fiduciary Services”, the Adviser acts as an “investment manager” (as defined in Section 3(38) of ERISA) with respect to the performance of discretionary fiduciary investment services. Under this arrangement the Adviser is appointed by the Plan Cresta Advisors ADV Part 2A March 25 Page 6 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Sponsor or trustee and accepts investment discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning investment decisions related to the plan assets. Under this arrangement the Adviser is appointed by the plan sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions related to the plan assets. The Adviser will review the investment options available to the Plan through documents provided by the Plan Sponsor and notifies the Plan’s record-keeper and/or the Plan Sponsor the Adviser’s instructions to add, remove and/or replace these specific investment options offered to Plan participants and/or used for administrative purposes under the Plan, according to the criteria set forth in guidelines selected by the Plan Sponsor. The Plan Sponsor retains all authority, responsibility and decision-making for investment options not available on the Plan record-keeper’s platform (i.e., “non- core” investment options, such as employer stock, plan loans, self-directed brokerage accounts, frozen guaranteed investment contracts, and life insurance). The Adviser will retain final decision-making authority with respect to removing and/or replacing investments in the core lineup. The Plan Sponsor will not have responsibility to communicate instructions to any third‐party, custodian and/or third‐party administrator. The data used to determine the investment options is based on estimated, forward-looking performance of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g., expected return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the asset classes and the indexes that correspond to these asset classes may not be representative of actual future performance. Actual results could differ, based on various factors including the expenses associated with the management of the portfolio, the portfolio’s securities versus the securities comprising the various indexes and general market conditions. Before a specific investment is selected, other factors such as economic trends, which may influence the choice of investments and risk tolerance, should be considered. The Adviser has the responsibility and authority to determine the investment line up including evaluating investment managers and mutual fund companies, individual mutual funds, and money market funds which may be retained or replaced. The Adviser will also monitor the current managed investment line up including the investment’s performance compared to an applicable benchmark. If the Adviser determines that a fund no longer meets the criteria, they will select alternatives and replace them. Other Optional Retirement Plan Services Plan Structure We will assist our client in evaluating the current plan’s structure to determine if a change in the design of the plan better suits the needs of plan participants. We will facilitate any changes with the appropriate parties including the third-party administrator, record keeper, and custodian as well as facilitating the execution of the required plan document amendments or new plan documents. However, we will not draft any amendments as an attorney or a TPA will need to perform this service. Cresta Advisors ADV Part 2A March 25 Page 7 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Investment Committee We will assist you in the establishment of the Investment Committee (if a Committee is deemed appropriate) and the establishment of a formal investment committee charter, delineating committee responsibilities and fiduciary roles. We will also serve on the Committee in a non-fiduciary capacity if needed. The Investment Committee may be charged with the fiduciary responsibility of the prudent management of the investment portfolio, selecting and retaining professional advisors to the portfolio including investment managers, investment consultants, custodians, attorneys, and clerical staff, and the establishment, execution, and interpretation of an Investment Policy Statement for the portfolio. We will assist the Investment Committee in meeting the committee’s responsibilities according to the investment committee charter, and fulfilling its fiduciary duty to the plan, including their review of service providers, third-party administration firms, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to other alternatives that are available to the client. Investment Policy Service Our Investment Policy Service is designed to assist you in creating a written investment policy statement (“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals. The service is generally designed for corporate retirement plans that are managed on a discretionary basis. We will assist the Investment Committee with the establishment, execution, and interpretation of the Investment Policy Statement. The Investment Policy Statement serves as a guide to assist the Investment Committee in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile various factors for the account such as investment objectives, risk tolerances, projected cash flow, and demographics of your retirement plan participants. It is the client’s responsibility to provide all necessary information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This draft IPS is then submitted to you for review and approval. We recommend that your professional advisors, such as an attorney, actuary, and/or accountant, also review the IPS. The review and acceptance of the IPS is the responsibility of the plan fiduciary and your retirement program’s governing entity. Upon client’s final approval, the IPS is ready to be sent to client’s Investment Committee. It is client’s responsibility to confirm the Investment Committee’s acceptance of the IPS, and it is the Investment Committee’s responsibility to adhere to the IPS in managing the retirement program. We encourage you to review accounts periodically to verify investment committee’s compliance with the IPS. The Investment Policy Statement will be reviewed at least annually to determine whether stated investment objectives are still relevant and the continued feasibility of achieving those objectives. However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will not be updated to account for short term changes in market conditions or the economic environment. Cresta Advisors ADV Part 2A March 25 Page 8 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Participant Meetings We will conduct plan participant meetings when a change is made either to the structure of the plan or if the investment lineup changes as a result of the decisions of the Investment Committee. We will detail the changes being made, how it affects the current participants, review the current investment opportunities, how participants may make changes to their investment selections, and will answer any and all questions a participant may have. We will review with the participants how to select the investments. Reporting We will send a performance report annually or as requested by the Client detailing the overall performance of the plan’s assets and a detailed list of the investment holdings. Financial Consulting Fee based financial consulting is a comprehensive relationship which incorporates many different aspects of your financial status into an overall plan that meets your goals and objectives. The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or your other advisors (attorneys, accountants, etc.) as necessary. It is essential that you provide the information and documentation we request regarding your income, investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and goals, but you are obligated to inform us of any changes. We do not verify any information obtained from you, your attorney, accountant or other professionals. If you engage us to perform these services, you will receive a written agreement detailing the services, fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no obligation to implement recommendations through us. You may implement your financial plan through any financial organization of your choice. We obtain information from a wide variety of publicly available sources. We do not have any inside private information about any investments that are recommended. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Choosing which advice to follow is your decision. We can also work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many different aspects of your financial status into an overall plan designed to meet your goals and objectives. We will create a formal IPS and deliver it to you upon completion. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We recommend using either TD Ameritrade or Pershing. Assets Under Management As of December 31, 2024, we provided asset management services for 557 accounts, managing total assets of $533,116,217. Approximately $527,331,362 of the assets we manage are discretionary and $5,804,855 are non-discretionary. Cresta Advisors ADV Part 2A March 25 Page 9 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Item 5 – Fees and Compensation Retirement Plan Services Fees The standard fee schedules for the Discretionary 3(38) and Non-Discretionary 3(21) Fiduciary Services programs (the “Programs”) is 1.5% of assets under management or lower. This fee may be negotiable based upon certain circumstances. Advisory fees for the plan are paid to us by the plan, or directly from the plan sponsor, or in some cases a combination of both. These fees are generally collected by the plan record keeper or vendor and paid directly to our firm. This fee includes services as an ERISA section 3(21) or 3(38) fiduciary with respect to client’s plan. The timing of fees paid is generally at the beginning of the upcoming quarter, based upon asset levels at the end of the preceding quarter. Cresta Advisors’ advisory agreement with each plan sponsor outlines the timing of fees collected and the process of fee remittal to our firm. You may also incur fees related to your use of outside service providers including third-party administrators and record keepers. The fee schedule for each outside service provider varies dramatically from service provider to service provider. The service provider’s fees will also vary from plan to plan as each plan’s structure and characteristics are different from the next. We believe our services help plan sponsors and plan fiduciaries meet their fiduciary duty to the plan and its participants. As a part of our services, we review the fees of service providers and the transparency of their fees. We will assist the plan sponsors with a review of service providers including the third-party administrator, daily record keeper, and custodian to ensure that their services, along with ours, remain competitive to alternatives that are available. Financial Consulting Fees If sought separately from asset management services, we will charge an hourly fee of $250 for our financial consulting services. We can provide an-in depth analysis of your financial situation or other defined projects as requested. Based upon your needs, we may provide consultations throughout the year to advise and counsel you about other financial issues. We can help you with transition planning, transaction services, major transaction analysis, coordinated with cash flow needs, retirement needs, estate planning needs, income tax planning, life and disability insurance needs, investment needs, and college education planning. All recommendations developed by us are based upon our professional judgment. We cannot guarantee the results of any of our recommendations. Portfolio Management Fees We offer portfolio management services to individuals, high net worth individuals, trusts, estates, corporations, trusts, endowments, non-profits, public entities and small businesses as a part of our wrap fee program. A wrap fee program (“bundled”) allows you to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in your account. Cresta Advisors ADV Part 2A March 25 Page 10 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  The fee is bundled with our costs for executing transactions in your account(s). However, the Adviser does not cover the transaction fees charged in accordance with Section 31 of the Securities Exchange Act of 1934. These are fees that are charged by the SEC and collected by the custodian. Our fee schedule has a fee of 1.5% or lower for asset allocation profiled and 0.65% or lower for fixed income profiled. Please see our wrap fee brochure for additional details regarding our services and fees. Automatic Payment of Fee The Client agrees to authorize the Custodian to pay directly to Cresta Advisors upon receipt of notice, the Account's investment advisory services fee. Fee withdrawals will occur no more frequently than quarterly from the Client's Account, unless specifically instructed otherwise by the Client. The Custodian will send to the Client a statement, at least quarterly, indicating all amounts disbursed from the Account, including the fee paid directly to Cresta Advisors. Cresta Advisors' access to the Assets of the Account will be limited to trading and the withdrawals authorized above. Alternatively, the client may elect to receive an invoice instead of a direct fee deduction from their advisory account. Cresta Advisors will send to the Client an invoice reflecting the amount of the fee, the previous quarterly average daily balance for the Client's Account on which the fee was based, and the specific manner in which the fee was calculated. You can pay the fee directly to us via check, ACH, through an approved third-party payment platform. Fees are due in full 15 days after receipt of the invoice. Item 6 – Performance Based Fee and Side by Side Management We do not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 – Types of Client(s) ERISA 3(21) and 3(38) fiduciary services are only offered for plan sponsors of ERISA based plans. Financial consulting services are offered to individuals, high net worth individuals, trusts, estates, corporations, endowments, public entities, non-profits and small businesses. Wrap Fee Clients For our wrap fee clients, We require an initial minimum account size opening balance of $250,000. The account size may be negotiable based upon the individual circumstances. Participation in the wrap fee program generally is initiated by submitting a completed account application, portfolio management agreement, and risk questionnaire. The Adviser provides portfolio management services to individuals, high net worth individuals, trusts, estates, corporations, trusts, endowments, non-profits and small businesses. Several factors may influence the selection of the account structure including but not limited to: Cresta Advisors ADV Part 2A March 25 Page 11 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  • The Client’s preference for an overall wrap fee instead of a per trade charge on certain or all securities; • Account size; • Anticipated trading frequency; • Anticipated securities to be traded; • Management style; and • Long term investment goals. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We may use fundamental analysis, technical analysis, Modern Portfolio Theory (MPT), cyclical analysis, and targeted asset allocation as part of our overall investment management discipline. We use these method(s) of analysis to determine asset class, region, sector, industry, suitability, and maximum desired allocation for each security selected. We focus on utilizing these methods of analysis when scrutinizing general economic conditions and geopolitical actions, current market conditions, interest rates and yield curves, inflation trends and market volatility, sector valuations and relative asset class valuations, and taxation concerns. In some instances, we utilize a “bottom-up investing” strategy, and focus on the analysis of individual stocks rather than economic and market cycles. The implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following: Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Once we discover undervalued securities or funds that are investing in undervalued stocks; we look at the stability and volatility. In order to perform this fundamental analysis, we use many resources, such as: • Proprietary In house Research Cresta Advisors ADV Part 2A March 25 Page 12 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  • Third Party research • Nationally recognized statistical rating organizations • Morningstar • Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.) • Annual reports, prospectuses, filings with the Securities and Exchange Commission • Research materials prepared by others • Company press releases • Inspections of corporate activities. The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases -securities held at least a year • Short term purchases - securities sold within a year • Trading -securities sold within 30 days Modern Portfolio Theory (MPT) We use publicly available research and reports regarding individual securities, issuers, investment strategies and performance of asset classes to select the funds they will offer. They also use Modern Portfolio Theory to help them select the funds they offer. Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk. Technical Analysis Technical Analysis is a technique that attempts to determine a security’s value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market’s price reflects all relevant information so the analysis focuses on the history of a security’s trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations. In order to perform technical analysis, we may use the following techniques: • Calculate moving averages • Charting and chart patterns • Supply and demand indicators Cresta Advisors ADV Part 2A March 25 Page 13 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  • Investor behavior and psychology. The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return. Cyclical Analysis While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy. Risks We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to handle. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. A list of risks associated with the strategies, products and methodology we offer are listed below: 1. Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include: • Call Risk - The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date. • Credit Risk — the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. • Interest Rate Risk — the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. • Prepayment Risk — the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that Cresta Advisors ADV Part 2A March 25 Page 14 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. 2. Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks: • When using this method with mutual funds, the funds are composed of many companies and not all of them will be undervalued. • The data used may be out of date. • It is difficult to give appropriate weightings to the factors. • It assumes that the analyst is competent. • It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on. • It assumes that there is no monopolistic power over markets. 3. Insurance Product Risk Some of the major risks include: • Liquidity and Early Withdrawal Risk – There may be a surrender charges for withdrawals within a specified period, which can be as long as six to eight years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. • Sales and Surrender Charges – Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero. • Fees and Expenses – There are a variety of fees and expenses which can reach 2% and more such as: o Mortality and expense risk charges o Administrative fees o Underlying fund expenses o Charges for any special features or riders. • Bonus Credits – Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods. • Guarantees – Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them. Cresta Advisors ADV Part 2A March 25 Page 15 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  • Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk – The possibility that an investment will go down in value, or "lose money," from the original or invested amount. 4. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk -The possibility that an investment will go down in value, or "lose money," from the original or invested amount. 5. Overall Fund Risk • Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. • Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the Cresta Advisors ADV Part 2A March 25 Page 16 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. 6. Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services. 7. Technical Analysis Risk • Technical analysis is derived from the study of market participant behavior and its efficacy is a matter of controversy. • Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data. • Models and rules can incur sufficiently high transaction costs. 8. Indexed Annuity Risk Indexed annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and some participation growth, if any, of a stock market index. Such contracts have substantial variation in terms, costs of guarantees and features and may cap participation or returns in significant ways. Any guarantees offered are backed by the financial strength of the insurance company. Surrender charges apply if not held to the end of the term. Withdrawals from non-qualified accounts are taxed as ordinary income and, if taken prior to 59 ½, a 10% federal tax penalty. Investors are cautioned to carefully review an annuities for its features, costs, risks, and how the variables are calculated. Risk of Loss We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to handle. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. Item 9 – Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. Cresta Advisors ADV Part 2A March 25 Page 17 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  We do not have any information to disclose concerning Cresta Advisors or any of our IARs. We adhere to high ethical standards for all IARs and associates. Item 10 – Other Financial Industry Activities and Affiliations The investment adviser representatives of Cresta Advisors have the following outside business activities and/or affiliations to disclose. Other Financial Industry Affiliations Insurance Agency Affiliation Our investment adviser representatives may recommend insurance products through our affiliated entity, Cresta Advisors Insurance Solutions, LLC. This entity is owned by CAIS Mgmt, LLC, which is owned by Manuel Garza, Mark Deutsch, and Luis Emmanuel Guajardo. We have several investment adviser representatives who are licensed to sell insurance products and may recommend and sell life, disability, health, and long-term care insurance and will receive the usual and customary commissions in addition to any agreed upon advisory fee. Our IARs may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products that he recommends. While our IARs endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving compensation from this other entity and/or incentive awards creates a conflict of interest, and may affect their judgment when making recommendations. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended insurance products from other insurance agents not affiliated with us. Tax Services Affiliation Cantu’s Tax Services & Consulting, LLC DBA Cantu Tax Consulting (“Cantu") rents office space from us. We may also recommend their services to our clients. When we refer a client to Cantu, we will receive compensation. While our IARs endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving compensation from this other entity and/or incentive awards creates a conflict of interest, and may affect their judgment when making recommending an accounting firm. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended services from other accountants not affiliated with us. In addition, Cantu may refer clients to us. However, there is no compensation, direct or indirect, from Cresta to Cantu for advisory client referrals to Cresta. Other Activities and Affiliations Manuel Garza and Mark Deutsch have the following business affiliations and activities to disclose, as listed in the table below: Cresta Advisors ADV Part 2A March 25 Page 18 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Affiliation, Name of Firm Hours/year Investment related? 10% of Time Yes Manager, D&G Management Co. LLC (Pays a salary and splits profits at the end of the year, if any) CAIS Mgmt, LLC Less than 1% of Time No Cresta Advisors Insurance Solutions, LLC No Less than 10% of Time Item 11 – Code of Ethics, Participation or Interest in Client Accounts and Personal Trading General Information We have adopted a Code of Ethics for all IAR’s of the firm describing its high standards of business conduct, and fiduciary duty to you, our client. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All of our IAR’s must acknowledge the terms of the Code of Ethics annually, or as amended. Participation or Interest in Client Accounts Our Compliance policies and procedures prohibit anyone associated with Cresta Advisors from having an interest in a client account or participating in the profits of a client’s account without the approval of the CCO. The following acts are prohibited: • Employing any device, scheme or artifice to defraud • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading • Engaging in any fraudulent or deceitful act, practice or course of business • Engaging in any manipulative practices Clients and prospective clients may request a copy of the firm's Code of Ethics by contacting the CCO. Privacy Statement We are committed to safeguarding your confidential information and hold all personal information provided to us in the strictest confidence. These records include all personal information that we collect Cresta Advisors ADV Part 2A March 25 Page 19 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  from you or receive from other firms in connection with any of the financial services they provide. We also require other firms with whom we deal with to restrict the use of your information. Our Privacy Policy is available upon request. Conflicts of Interest Cresta Advisors’ IARs may employ the same strategy for their personal investment accounts as it does for its clients. However, IARs may not place their orders in a way to benefit from the purchase or sale of a security. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. Item 12 – Brokerage Practices Factors Used to Select Custodians In recommending a custodian/broker-dealer, we look for a company that offers relatively low transaction fees, access to desired securities, trading platforms, and support services. We may recommend clients use TD Ameritrade, Charles Schwab, and Pershing as the qualified custodian for their accounts when utilizing our asset management services. For our wrap fee services, please see our wrap brochure for additional details. Soft Dollars We do not have any soft dollar benefits for this service. Brokerage for Client Referrals In selecting and/or recommending broker-dealers, we do not take into consideration whether or not we will receive client referrals from the broker-dealer or third-party. Directed Brokerage We do not permit directed brokerage. We will require you to use the custodian of our choosing as the custodial firm. Trading ERISA 3(21) and 3(38) As it relates to ERISA Plan business, the Adviser’s model does not involve transactional business and, consequently, the Adviser does not currently engage brokers in any transactional capacity. Best Execution The Adviser does not trade in any Plan client accounts. Cresta Advisors ADV Part 2A March 25 Page 20 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Trading The Adviser does not trade in individual Plan participant accounts. Item 13 – Review of Accounts Reviews Reviews with the client are conducted at least annually or as agreed to by Cresta and the client. For our wrap fee services, please see our wrap brochure for additional details. Reviews with the client are conducted at least annually or as agreed to by Cresta and the client. We provide daily monitoring of our asset allocation models. Reviews will be conducted by the Primary advisor for the account and/or the Chief Compliance Officer Manuel Garza. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Reports You will be provided with account statements reflecting the transactions occurring in the account on at least an annual basis. These statements will be available electronically in the client online portal, and will be sent by mail upon request. You need to notify us of any discrepancies in the account(s) or any concerns you have about the account(s). Item 14 – Client Referrals and Other Compensation We do not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients nor do we directly or indirectly pay any compensation to another person if they refer clients to us. As disclosed in Item 10, we are compensated for referrals to Cantu for their accounting services. Item 15 – Custody We do not have physical custody of any accounts or assets. However, we may be deemed to have custody of your account(s) if we have the ability to deduct your advisory fees from the custodian. We use TD Ameritrade and/or Pershing as the custodian and/or broker-dealer for all your accounts. You should receive at least quarterly statements from the broker-dealer or custodian that holds and maintains your investment assets. We urge you to carefully review such statements. Cresta Advisors ADV Part 2A March 25 Page 21 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  We do not debit the client fees directly from your advisory account. We send information to your custodian to debit your fees and to pay them to us. You authorized the custodian to pay us directly at the onset of the relationship. Qualified Retirement Plan Custody We do not have actual or constructive custody of any client’s account. We do not have the ability to deduct fees directly from the plan accounts. If authorized by the Plan Sponsor, the Adviser has the ability to debit fees directly from the Plan Sponsor’s brokerage account through the submission of a billing file to the plan custodian, however, the Adviser does not have authority to possess or take actual custody of clients’ funds or securities. Plan Sponsors and plan participants should receive at least quarterly statements from the recordkeeper and Plan Sponsors and participants should carefully review such statements. Standing Letters of Authorization Cresta Advisors is deemed to have custody of client funds or securities as a result of maintaining standing letters of authorization (SLOA) for the purpose of distributing funds from a client’s account. For those accounts in which we have the ability to initiate distributions from a client’s account, via journal, ACH or wire to a third party, which is an account held in the name of someone other than the client, we will ensure the following conditions have been met in order for us to be in compliance with SEC and State Custody Rules and ensure the safe keeping of our client’s funds: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Cresta Advisors ADV Part 2A March 25 Page 22 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Item 16 – Investment Discretion Our recommendations regarding our 3(21)-qualified retirement plan consulting services are made on a non-discretionary basis. The plan sponsor retains the decision-making authority over the plan. When recommending securities, we observe the investment policies, limitations, and restriction set by the plan and plan sponsor. Our investment decisions regarding our 3(38)-qualified retirement plan consulting services are made on a discretionary basis. In performing discretionary management services, the Adviser is acting as an “investment manager” (as that term is defined in Section 3(38) of ERISA) and as a fiduciary to the Plan and shall act with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in a capacity and familiar with such matters would use in the conduct of an enterprise of like character and with like aims. For our wrap fee clients and our public entity clients, we provide discretionary asset management which means you determine whether we will receive discretionary authority from you at the beginning of the relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account. If you do not give us the authority to manage your account on a discretionary basis, which will be evidenced via the written, non-discretionary agreement between the client and the Adviser, then we cannot buy or sell any security in your account without your prior, express permission. Please be advised that this could adversely affect the Adviser’s ability to take advantage of price swings when attempting to purchase or sell securities in the client’s account, especially in instances where the Adviser is not able to contact the client in a timely manner. When active asset management services are provided on a non-discretionary basis the client will enter into a separate custodial agreement with the custodian. The custodian agreement will include a limited power of attorney to trade in the client’s account(s) which authorizes the custodian to take instructions from us regarding trades approved by the client. When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. Item 17 – Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. Cresta Advisors ADV Part 2A March 25 Page 23 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC  Item 18 – Financial Information We are required to provide you with certain financial information or disclosures about our financial condition. We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of twelve hundred dollars and more than six months in advance of advisory services rendered. Cresta Advisors ADV Part 2A March 25 Page 24 of 24 © 2010 – 2023 Red Oak Compliance Solutions LLC 

ADV Part 2A Appendix 1 Cresta Advisors, Ltd. 2019 E. Del Mar Blvd., Suite 100 Laredo, TX 78041 www.crestaadvisors.com March 10, 2025 This wrap fee program brochure provides information about the qualifications and business practices of Cresta Advisors, Ltd. If you have any questions about the contents of this Brochure, please contact us at (956) 267-8130 or via email at manuel@crestaadvisors.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Cresta Advisors, Ltd. (“Cresta Advisors”) is a Registered Investment Adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information that you may use to determine whether to hire or retain them. Additional information about Cresta Advisors, Ltd. is also available on the SEC’s website at www.adviserinfo.sec.gov. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 1 of 23  Item 2 – Material Changes Since our last annual filing on March 20, 2024, we have amended our fees for public fund services. Cresta Advisors will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year which is December 31st. Cresta Advisors will provide other ongoing disclosure information about material changes as necessary. Cresta Advisors will also provide you with a new Brochure, as necessary, based on changes or new information. Currently, our Brochure may be requested at any time, without charge, by contacting our office at (956) 267-8130. information about Cresta Advisors, Ltd. Additional is also available via the SEC’s website www.adviserinfo.sec.gov. You can search this site by using a unique identifying number, known as a CRD number. The CRD number for Cresta Advisors, Ltd. is 169641. The SEC’s website also provides information about any persons affiliated with Cresta Advisors, Ltd. who are registered, or are required to be registered, as Investment Adviser Representatives of Cresta Advisors, Ltd. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 2 of 23 © 2025 Red Oak Compliance Solutions LLC  Item 3 – Table of Contents I tem 1 – Cover Page ................................................................................................................1 I tem 2 – Material Changes .......................................................................................................2 Item 3 – Table of Contents .................................................................................................................3 Item 4 – Services, Fees and Compensation ..........................................................................................5 Services ................................................................................................................................................. 5 1. Asset Management ....................................................................................................................... 6 2. Other Services ............................................................................................................................... 8 Fees and Compensation ........................................................................................................................ 8 3. Asset Management Fee Schedule ................................................................................................. 9 4. Other Fees ................................................................................................................................... 11 Item 5 – Account Requirements and Types of Clients ........................................................................ 11 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................ 11 1. Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 12 Fundamental Analysis ................................................................................................................. 12 Modern Portfolio Theory (MPT) .................................................................................................. 13 Technical Analysis ........................................................................................................................ 13 Cyclical Analysis ........................................................................................................................... 14 Targeted Asset Allocation ........................................................................................................... 14 2. Risks ............................................................................................................................................. 14 3. Performance-Based Fees and Side-by-Side Management .......................................................... 17 4. Voting Client Securities ............................................................................................................... 18 Item 7 – Client Information Provided to Portfolio Managers .............................................................. 18 Item 8 – Client Contact with Portfolio Managers ............................................................................... 18 Item 9 – Additional Information ....................................................................................................... 18 1. Disciplinary Information .............................................................................................................. 18 2. Other Financial Industry Activities and Affiliations ..................................................................... 18 Insurance Agent .......................................................................................................................... 18 Other Activities and Affiliations .................................................................................................. 19 3. Code of Ethics, Participation or Interest in Client Accounts and Personal Trading .................... 20 General Information .................................................................................................................... 20 Personal Trading .......................................................................................................................... 20 Responsibility .............................................................................................................................. 21 Privacy Statement ....................................................................................................................... 21 Conflicts of Interest ..................................................................................................................... 21 Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 3 of 23 © 2025 Red Oak Compliance Solutions LLC  4. Soft Dollars .................................................................................................................................. 21 5. Brokerage for Client Referrals ..................................................................................................... 21 6. Review of Accounts ..................................................................................................................... 21 Reports ........................................................................................................................................ 21 7. Client Referrals and Other Compensation .................................................................................. 22 Standing Letters of Authorization ............................................................................................... 22 8. Financial Information .................................................................................................................. 22 9. Discretion .................................................................................................................................... 23 Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 4 of 23 © 2025 Red Oak Compliance Solutions LLC  Item 4 – Services, Fees and Compensation Cresta Advisors is a Registered Investment Adviser (“Adviser”) which offers investment advice, securities, insurance, and other financial services to clients (“you”). We are registered through and regulated by the SEC. We provide investment advice through Investment Adviser Representatives (“Advisor”) associated with us. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. In addition, all advisors are required to have commensurate industry or educational experience. Cresta Advisors was founded in 2013 by Partners Manuel Garza and Mark Deutsch. We provide portfolio management services primarily to clients in Texas, California, and Mexico, consisting of individuals, high net worth individuals, trusts, estates, corporations, endowments, non-profits and small businesses. Cresta Advisors provides customized investment advisory solutions for our clients. This is achieved through continuous personal client contact and interaction while providing discretionary investment management services. We work with each client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. Our investment approach is based on the belief that the markets are efficient and returns are principally determined by asset allocation decisions. We are committed to the precept that by placing the client’s interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships with our clients whom we regard as strategic partners in our business. We offer our Cresta wrap program to our clients. A wrap program is one in which you pay a single “wrapped” fee for both investment advisory and brokerage execution services. This wrap fee is not based on the number of transactions made in your account. It is based on the size of the account(s) we manage for you. Because wrap programs do not have fees or charges associated with each transaction, wrap fees are generally higher for similar services than non-wrap fees. This brochure describes our wrap fee program. Services We provide various asset management services, with an emphasis on managing assets in order to help build and preserve your wealth. Cresta Advisors follows a disciplined research and evaluation process to determine appropriate investments for each model portfolio based on its target allocation. Cresta has the investment management expertise and analytical tools to construct asset allocation portfolios based on your individual circumstances. We believe in continuous portfolio management, to help ensure we are meeting your goals and objectives. We manage assets on a model driven and non-model driven discretionary basis for our US clients and international clients. If we manage your account on a discretionary basis, this means you have given us the authority to determine the following without your consent: • Securities to be bought or sold for your account (within the model parameters) Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 5 of 23 © 2025 Red Oak Compliance Solutions LLC  • Amount of securities to be bought or sold for your account • Broker-dealer to be used for a purchase or sale of securities for your account • Commission rates to be paid to a broker or dealer for your securities transaction. Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professionals to assist you with tax planning. You will have the opportunity to meet with us periodically to review the assets in your account. If we determine that it is in your best interest, we may recommend the use of annuity products including indexed and variable annuities. Annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and some participation growth, if any, of a stock market index. For a description of the risks associated with indexed annuities, please see Item 6 below. As of December 31, 2024, we provided asset management services for 557 accounts, managing total assets of $533,116,217. Approximately $527,331,362 of the assets we manage are discretionary and $5,804,855 are non-discretionary. 1. Asset Management Asset management is the professional management of securities (stocks, bonds and other securities) in order to meet your specified investment goals. With an Advisory Account, you engage us to assist you in developing a personalized asset allocation program designed to meet your unique investment objectives. The investments in the portfolio account may include mutual funds, stocks, bonds, ETFs, closed end funds, etc. We develop your portfolio based on one of our asset allocation models which most closely reflects your risk tolerance and investment objectives. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. You will be provided with a targeted strategic allocation of assets by class. We will monitor the account, trade as necessary, and communicate regularly with you. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with questions about your account. You will also receive our Advisory Agreement which describes what services you will receive and what fees you will be charged. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 6 of 23 © 2025 Red Oak Compliance Solutions LLC  We will: • Review your present financial situation • Monitor and track assets under management • Provide portfolio statements, asset allocation statement, rebalanced statements as needed • Advise on asset selection • Determine market divisions through asset allocation models • Provide research and information on performance and fund management changes • Build a risk management profile for you • Maintain your asset allocation policy in your portfolio on a continual basis • Monitor your portfolio for style drift and benchmark performance, and provide portfolio rebalancing as necessary • Assist you in setting and monitoring goals and objectives • Provide personal consultations as necessary upon your request or as needed. You must notify us promptly when your financial situation, goals, objectives, personal circumstances, or needs change. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. We may recommend specific positions to increase/decrease sector or asset class weightings. Cresta may recommend employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. Additionally, we may utilize inverse, volatility, and interest rate ETFs to hedge the investment portfolios, or any other hedge vehicle if Cresta determines that it is in the client’s best interest. Cresta may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. If you decide to implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian. We require our clients to use TD Ameritrade Institutional (“TD Ameritrade”) and Pershing as the independent custodian for all accounts that we manage. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 7 of 23 © 2025 Red Oak Compliance Solutions LLC  You will enter into a separate custodial agreement with the custodian. You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We may also provide you with a performance statement during your review. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Public Funds Advisory Services Cresta offers professional investment advisory and administrative services to state and local public funds managers using a variety of strategies and solutions. Cresta advises separately managed accounts on a discretionary basis to public clients with investment advice limited to the purchase or sale of fixed income securities, agencies, commercial paper, banker’s acceptances, corporate bonds, municipal debt, bank deposits, and money market funds. We may also recommend a local government investment pool or other bank deposit programs or products for a client’s cash management needs. We tailor our services to our public clients, utilizing investments permissible under the applicable state investment code and the Public Client’s investment policy. At the outset of each relationship, we will evaluate the Public Client’s needs, objectives, and the terms of the applicable state investment code. Subject to the approval of Cresta Advisors, Public Clients may impose reasonable restrictions on the types or quantities of the securities held in a client’s account. Depending on the scope of your agreement with us, Consulting Services may be offered along with discretionary advisory services or as a separate service. 2. Other Services We may recommend and sell life insurance. We will receive the usual and customary commissions associated with these sales from the insurance company. You will not pay a separate fee for these and your advisory fee will not be reduced by any payments we receive from these sales. Fees and Compensation A wrap fee program (“bundled”) allows you to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in your account. The fee is bundled with our costs for executing transactions in your account(s). However, the Adviser does not cover the transaction fees charged in accordance with Section 31 of the Securities Exchange Act of 1934. These are fees that are charged by the SEC and collected by the custodian. The Adviser monitors all Client accounts to ensure that the Adviser’s fiduciary duty is met for all Clients. Any breaches of the Adviser’s fiduciary duty are noted and appropriate repercussions are initiated to deter such behavior. By participating in a wrap fee program, Clients may end up paying more or less than they would through a non-wrap fee program where a lower advisory fee is charged, but trade execution costs are passed directly through to the Client by the executing broker. Clients could also invest in debt and equities directly, without the Adviser’s services. In that case, Clients would not receive the services provided by the Adviser which are designed, among other things, to assist in determining which funds are appropriate for the portfolio and the Client’s Account. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 8 of 23 © 2025 Red Oak Compliance Solutions LLC  There are other fees that Clients may be charged by other parties. In our wrap fee program we include all trade charges for your account. However, our fees do not include other related costs and expenses. You may incur certain charges imposed by custodians, and other third parties. These include fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. You could invest in a mutual fund directly, without our services. In that case, you would not receive the services provided by us which are designed, among other things, to assist you in determining which mutual fund or funds are most appropriate to your financial condition and objectives. Our Advisory-Agreement defines what fees are charged and their frequency. We bill fees in advance or arrears on a quarterly basis. You will authorize the custodian to directly debit fees from your account held at the custodian and to pay us. Management fees are prorated for each contribution and withdrawal made during the applicable calendar quarter (with the exception of small inconsequential contributions and withdrawals). You will be provided with a quarterly statement reflecting deduction of the advisory fees. Alternatively, the client may elect to receive an invoice instead of a direct fee deduction from their advisory account. Cresta Advisors will send to the Client an invoice reflecting the amount of the fee, the previous quarterly average daily balance for the Client's Account on which the fee was based, and the specific manner in which the fee was calculated. You can pay the fee directly to us via check, ACH, through an approved third-party payment platform. Fees are due in full 15 days after receipt of the invoice. Either party may terminate the relationship at any time. In the event the Agreement is terminated, and the Client has advanced any fees which have been unearned as of the date of termination, such unearned fees shall be refunded to the Client within five (5) business days. We will refund from the date we receive the termination notice or settlement date if funds need to be liquidated to the end of the quarter. 3. Asset Management Fee Schedule Our minimum account opening balance is $250,000 which may be negotiable based upon certain circumstances. The fee charged is based upon the amount of money you invest. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees for clients who are not public funds are charged quarterly, in advance. Fees will be calculated on the average daily balance of the previous quarter. The average daily balance is calculated using an industry standard third-party software application. The average daily balance calculation for the previous quarter is then multiplied by the annual management fee. The computed annual management fee (Avg Daily Balance * Management Fee) is divided by 4 and then applied for that quarter. You will be billed within the first two weeks of the quarter and the fee schedule is as follows: Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 9 of 23 © 2025 Red Oak Compliance Solutions LLC  FEE SCHEDULE FOR ASSET ALLOCATION PROFILES 1.5% or Lower FEE SCHEDULE FOR FIXED INCOME PROFILE .65% or Lower The fees shown above are annual fees and may be negotiable based upon certain circumstances. The fee is computed and billed using an industry standard third-party software application. If accounts are opened in the middle of a quarter, Clients will be charged from the date the account is funded for the number of days remaining in the quarter in advance. No increase in the wrap fee shall be effective without prior written notification to you. We believe our wrap fee is reasonable considering the fees charged by other investment advisers offering similar services/programs. In certain circumstances, advisory fees and account minimums may be negotiable based upon prior relationships as well as related account holdings. In the case of a significant withdrawal or market value fluctuation, your account value may fall to a different fee level based on the table above. In this instance, we may determine to either charge the fee that corresponds to the new account value as outlined in our fee schedule or continue to charge the fee that corresponds to the account value prior to the significant withdrawal or market value fluctuation. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds. Certain strategies offered by us involve investment in mutual funds. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. The 12(b)(1) fee, deferred sales charges and other fee arrangements will be disclosed upon your request and are typically described in the applicable fund’s prospectus. Your account at the custodian may also be charged for certain additional assets managed for you by us but not held by the custodian (i.e. variable annuities, mutual funds, 401(k)s). The fees we charge can be deducted directly from your account at the custodian. We will instruct the custodian to deduct the fees from your account. This fee will show up as a deduction on the current month account statement from the custodian. Public Funds Advisory Services Fees Public Fund Advisory Services is clients shall be billed at a negotiable rate of 0.25% or lower. This fee is billed quarterly, in arrears, based on the value of the eligible assets at the end of the billing period. The fee is computed and billed using an industry standard third-party software application. No increase in the fee shall be effective without prior written notification to you. We believe our fee is reasonable considering the fees charged by other investment advisers offering similar services/programs. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 10 of 23 © 2025 Red Oak Compliance Solutions LLC  In certain circumstances, advisory fees and account minimums may be negotiable based upon prior relationships as well as related account holdings. In the case of a significant withdrawal or market value fluctuation, your account value may fall to a different fee level based on the table above. In this instance, we may determine to either charge the fee that corresponds to the new account value as outlined in our fee schedule or continue to charge the fee that corresponds to the account value prior to the significant withdrawal or market value fluctuation. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds. Certain strategies offered by us involve investment in mutual funds. Load and no load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. The 12(b)(1) fee, deferred sales charges and other fee arrangements will be disclosed upon your request and are typically described in the applicable fund’s prospectus. Your account at the custodian may also be charged for certain additional operational fees, such as wire transfer fees, account closing fees, etc. The fees we charge can be deducted directly from your account at the custodian. We will instruct the custodian to deduct the fees from your account. This fee will show up as a deduction on the current month account statement from the custodian. 4. Other Fees Our Advisors may recommend and sell life insurance and will receive the usual and customary commissions in addition to any agreed upon advisory fee. Item 5 – Account Requirements and Types of Clients We require an initial minimum account size opening balance of $250,000. The account size may be negotiable based upon the individual circumstances. Participation in the wrap fee program generally is initiated by submitting a completed account application, portfolio management agreement, and risk questionnaire. The Adviser provides portfolio management services to individuals, high net worth individuals, trusts, estates, corporations, trusts, endowments, non-profits and small businesses. Several factors may influence the selection of the account structure including but not limited to: • • • • • • The Client’s preference for an overall wrap fee instead of a per trade charge on certain or all securities; Account size; Anticipated trading frequency; Anticipated securities to be traded; Management style; and Long term investment goals. Item 6 – Portfolio Manager Selection and Evaluation Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 11 of 23 © 2025 Red Oak Compliance Solutions LLC  Manuel Garza and Mark Deutsch serve as the portfolio managers for all Client accounts for the wrap fee program. We review performance information provided to us through the custodians TD Ameritrade and Pershing. Performance is reported by using industry approved third party providers. With respect to the wrap program, the Client has the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction requested. If such investment restrictions are implemented, the Client will experience a different investment return than what will be realized by the particular model itself. Such performance may be better or worse than the particular model. For these reasons, if a Client wishes to make a request concerning restrictions based on specific securities, it may be more appropriate for the Client to participate in other portfolio management programs. It should be noted, any standardized reports of model performance will not reflect the performance of the particular model with restrictions applied. However, performance reports of the Client’s account will accurately reflect the Client’s actual account performance with restrictions. 1. Methods of Analysis, Investment Strategies and Risk of Loss We may use fundamental analysis, technical analysis, Modern Portfolio Theory (MPT), cyclical analysis, and targeted asset allocation as part of our overall investment management discipline. We use these method(s) of analysis to determine asset class, region, sector, industry, suitability, and maximum desired allocation for each security selected. We focus on utilizing these methods of analysis when scrutinizing general economic conditions and geopolitical actions, current market conditions, interest rates and yield curves, inflation trends and market volatility, sector valuations and relative asset class valuations, and taxation concerns. In some instances, we utilize a “bottom-up investing” strategy, and focus on the analysis of individual stocks rather than economic and market cycles. The implementation of these analyses as part of our investment advisory services to you may include any, all or a combination of the following: Fundamental Analysis Fundamental analysis is a technique that attempts to determine a security’s value by focusing on the underlying factors that affect a company's actual business and its future prospects. Fundamental analysis is about using real data to evaluate a security's value. It refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. The end goal of performing fundamental analysis is to produce a value that we can compare with the security's current price, with the aim of figuring out what sort of position to take with that security (underpriced = buy, overpriced = sell or short). Once we discover undervalued securities or funds that are investing in undervalued stocks; we look at the stability and volatility. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 12 of 23 © 2025 Red Oak Compliance Solutions LLC  In order to perform this fundamental analysis, we use many resources, such as: • Proprietary In house Research • Third Party research • Nationally recognized statistical rating organizations • Morningstar • Financial newspapers and magazines (e.g. Wall Street Journal, Forbes, etc.) • Annual reports, prospectuses, filings with the Securities and Exchange Commission • Research materials prepared by others • Company press releases • Inspections of corporate activities. The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases -securities held at least a year • Short term purchases - securities sold within a year • Trading -securities sold within 30 days Modern Portfolio Theory (MPT) We use publicly available research and reports regarding individual securities, issuers, investment strategies and performance of asset classes to select the funds they will offer. They also use Modern Portfolio Theory to help them select the funds they offer. Modern portfolio theory tries to understand the market as a whole, rather than looking for what makes each investment opportunity unique. Investments are described statistically, in terms of their expected long-term return rate and their expected short-term volatility. The volatility is equated with "risk," measuring how much worse than average an investment's bad years are likely to be. The end goal is to identify your acceptable level of risk tolerance, and then to find a portfolio with the maximum expected return for that level of risk. Technical Analysis Technical Analysis is a technique that attempts to determine a security’s value by developing models and trading rules based upon price and volume transformation. Technical analysis assumes that a market’s price reflects all relevant information so the analysis focuses on the history of a security’s trading behavior rather than external drivers such as economic, fundamental and news events. The practice of technical analysis incorporates the importance of understanding how market participants perceive and act upon relevant information rather than focusing on the information itself. Ultimately, technical analysts develop trading models and rules by evaluating factors such as market trends, market participant behaviors, supply and demand and pricing patterns and correlations. In order to perform technical analysis, we may use the following techniques: • Calculate moving averages Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 13 of 23 © 2025 Red Oak Compliance Solutions LLC  • Charting and chart patterns • Supply and demand indicators • Investor behavior and psychology. The investment strategies we use to implement any investment advice given to you include, but are not limited to: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) As with other types of analysis, the predictive nature of technical analysis can vary greatly; models and rules are often modified and updated as new patterns and behaviors develop. Past performance is not an indicator of future return. Cyclical Analysis While we do not attempt to time the market, we may use cyclical analysis in conjunction with other strategies to help determine if shifts are required in your investment strategies depending upon long and short-term trends in financial markets and the performance of the overall national and global economy. Targeted Asset Allocation We combine aforementioned analyses above, to determine asset allocation strategies. Targeted asset allocation model portfolios covering everything from conservative income to very aggressive growth oriented approaches have been compiled by us. We will assign you a targeted portfolio that meets your goals and time horizon, while addressing the level of risk you are comfortable assuming. The strategic model portfolio allocation remains constant; your specific portfolio model may change infrequently to reflect shifts in your risk tolerance and goals. We screen and select funds and securities to be added or removed from the model portfolio on a regular basis. Rebalancing can occur after a significant move in the market, or at least once per year based on a change of risk parameters in the market as we perceive them, or on the annual review of your financial situation. 2. Risks We cannot guarantee our analysis methods will yield a return. In fact, a loss of principal is always a risk. Investing in securities involves a risk of loss that you should be prepared to handle. You need to understand that investment decisions made for your account by us are subject to various market, currency, economic, political and business risks. The investment decisions we make for you will not always be profitable nor can we guarantee any level of performance. A list of risks associated with the strategies, products and methodology we offer are listed below: 1. Bond Fund Risk Bond funds generally have higher risks than money market funds, largely because they typically pursue strategies aimed at producing higher yields of the risks associated with bond funds include: • Call Risk - The possibility that falling interest rates will cause a bond issuer to redeem—or call—its high-yielding bond before the bond's maturity date. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 14 of 23 © 2025 Red Oak Compliance Solutions LLC  • Credit Risk — the possibility that companies or other issuers whose bonds are owned by the fund may fail to pay their debts (including the debt owed to holders of their bonds). Credit risk is less of a factor for bond funds that invest in insured bonds or U.S. Treasury bonds. By contrast, those that invest in the bonds of companies with poor credit ratings generally will be subject to higher risk. • Interest Rate Risk — the risk that the market value of the bonds will go down when interest rates go up. Because of this, you can lose money in any bond fund, including those that invest only in insured bonds or Treasury bonds. • Prepayment Risk — the chance that a bond will be paid off early. For example, if interest rates fall, a bond issuer may decide to pay off (or "retire") its debt and issue new bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the proceeds in an investment with as high a return or yield. 2. Fundamental Analysis Risk Fundamental analysis, when used in isolation, has a number of risks: • When using this method with mutual funds, the funds are composed of many companies and not all of them will be undervalued • The data used may be out of date. • It is difficult to give appropriate weightings to the factors. • It assumes that the analyst is competent. • It ignores the influence of random events such as oil spills, product defects being exposed, and acts of God and so on. • It assumes that there is no monopolistic power over markets. 3. Insurance Product Risk Some of the major risks include: • Liquidity and Early Withdrawal Risk – There may be a surrender charges for withdrawals within a specified period, which can be as long as six to eight years. Any withdrawals before a client reaches the age of 59 ½ are generally subject to a 10 percent income tax penalty in addition to any gain being taxed as ordinary income. • Sales and Surrender Charges – Asset-based sales charges or surrender charges. These charges normally decline and eventually are eliminated the longer you hold your shares. For example, a surrender charge could start at 7 percent in the first year and decline by 1 percent per year until it reaches zero. • Fees and Expenses – There are a variety of fees and expenses which can reach 2% and more such as: o Mortality and expense risk charges o Administrative fees o Underlying fund expenses Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 15 of 23 © 2025 Red Oak Compliance Solutions LLC  o Charges for any special features or riders. • Bonus Credits – Some products offer bonus credits that can add a specified percentage to the amount invested ranging from 1 percent to 5 percent for each premium payment. Bonus credits, however, are usually not free. In order to fund them, insurance companies typically impose high mortality and expense charges and lengthy surrender charge periods. • Guarantees – Insurance companies provide a number of specific guarantees. For example, they may guarantee a death benefit or an annuity payout option that can provide income for life. These guarantees are only as good as the insurance company that gives them. • Market Risk – The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk – The possibility that an investment will go down in value, or "lose money," from the original or invested amount. 4. Mutual Funds Risk The following is a list of some general risks associated with investing in mutual funds. • Country Risk - The possibility that political events (a war, national elections), financial problems (rising inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's economy and cause investments in that country to decline. • Currency Risk -The possibility that returns could be reduced for Americans investing in foreign securities because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk. • Income Risk - The possibility that a fixed-income fund's dividends will decline as a result of falling overall interest rates. • Industry Risk - The possibility that a group of stocks in a single industry will decline in price due to developments in that industry. • Inflation Risk - The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-adjusted returns. • Manager Risk -The possibility that an actively managed mutual fund's investment adviser will fail to execute the fund's investment strategy effectively resulting in the failure of stated objectives. • Market Risk -The possibility that stock fund or bond fund prices overall will decline over short or even extended periods. Stock and bond markets tend to move in cycles, with periods when prices rise and other periods when prices fall. • Principal Risk -The possibility that an investment will go down in value, or "lose money," from the original or invested amount. 5. Overall Fund Risk Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 16 of 23 © 2025 Red Oak Compliance Solutions LLC  • Clients need to remember that past performance is no guarantee of future results. All funds carry some level of risk. You may lose some or all of the money you invest, including your principal, because the securities held by a fund goes up and down in value. Dividend or interest payments may also fluctuate, or stop completely, as market conditions change. • Before you invest, be sure to read a fund's prospectus and shareholder reports to learn about its investment strategy and the potential risks. Funds with higher rates of return may take risks that are beyond your comfort level and are inconsistent with your financial goals. While past performance does not necessarily predict future returns, it can tell you how volatile (or stable) a fund has been over a period of time. Generally, the more volatile a fund, the higher the investment risk. If you'll need your money to meet a financial goal in the near-term, you probably can't afford the risk of investing in a fund with a volatile history because you will not have enough time to ride out any declines in the stock market. 6. Stock Fund Risk Overall "market risk" poses the greatest potential danger for investors in stocks funds. Stock prices can fluctuate for a broad range of reasons, such as the overall strength of the economy or demand for particular products or services. 7. Technical Analysis Risk • Technical analysis is derived from the study of market participant behavior and its efficacy is a matter of controversy. • Methods vary greatly and can be highly subjective; different technical analysts can sometimes make contradictory predictions from the same data. • Models and rules can incur sufficiently high transaction costs. 8. Indexed Annuity Risk Indexed annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and some participation growth, if any, of a stock market index. Such contracts have substantial variation in terms, costs of guarantees and features and may cap participation or returns in significant ways. Any guarantees offered are backed by the financial strength of the insurance company. Surrender charges apply if not held to the end of the term. Withdrawals from non-qualified accounts are taxed as ordinary income and, if taken prior to 59 ½, a 10% federal tax penalty. Investors are cautioned to carefully review an annuities for its features, costs, risks, and how the variables are calculated. 3. Performance-Based Fees and Side-by-Side Management The Adviser does not charge any performance-based fees. These are fees based on a share of capital gains on or capital appreciation of the assets of a Client. The Adviser does not perform side-by-side management. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 17 of 23 © 2025 Red Oak Compliance Solutions LLC  4. Voting Client Securities As a matter of firm policy and practice, we do not have any authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in your portfolios. We are authorized to instruct the custodian to forward you copies of all proxies and shareholder communications relating to your account assets. Further, the Adviser will not be required to take any action or render any advice with respect to any securities held in the Account, which are named in or subject to class action lawsuits. The Adviser will, however, forward to the Client any information the Firm receives regarding class action legal matters involving any security held in the Account and discuss such information if the Client so desires. Item 7 – Client Information Provided to Portfolio Managers The Adviser and Manuel Garza and Mark Deutsch, who serve as the portfolio managers, have access to all Client information obtained by the Adviser with respect to the particular Client accounts that they manage. The Adviser does not provide Client information to any other portfolio managers. However, client information will be provided to mutual fund companies as necessary. Item 8 – Client Contact with Portfolio Managers The primary point of contact for Clients with respect to this wrap fee program is Manuel Garza. Clients are always free to directly contact Manuel Garza with any questions or concerns they have about their portfolios or other matters. Item 9 – Additional Information 1. Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. We have no information to disclose here about the Cresta Advisors or any of our investment advisors. We adhere to high ethical standards for all advisors and associates. We strive to do what is in your best interests. 2. Other Financial Industry Activities and Affiliations The investment adviser representatives of Cresta Advisors have the following outside business activities and/or affiliations to disclose. Insurance Agency Affiliation Our investment adviser representatives may recommend insurance products through our affiliated entity, Cresta Advisors Insurance Solutions, LLC. This entity is owned by CAIS Mgmt, LLC, which is owned by Manuel Garza, Mark Deutsch, and Luis Emmanuel Guajardo. We have several investment adviser representatives who are licensed to sell insurance products and may recommend and sell life, disability, health, and long-term care insurance and will receive the usual and customary commissions in addition to Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 18 of 23 © 2025 Red Oak Compliance Solutions LLC  any agreed upon advisory fee. Our IARs may be eligible to receive incentive awards (including prizes such as trips or bonuses) for recommending certain types of insurance policies or other investment products that he recommends. While our employees endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving incentive awards creates a conflict of interest, and may affect their judgment when making recommendations. We require that all employees disclose this conflict of interest when such recommendations are made. Also, we require employees to disclose that Clients may purchase recommended insurance products from other insurance agents not affiliated with us. Tax Services Affiliation Cantu’s Tax Services & Consulting, LLC DBA Cantu Tax Consulting (“Cantu") rents office space from us. We may also recommend their services to our clients. When we refer a client to Cantu, we will receive compensation. While our IARs endeavor at all times to put the interest of our clients first as part of our fiduciary duty, the possibility of receiving compensation from this other entity and/or incentive awards creates a conflict of interest, and may affect their judgment when making recommending an accounting firm. We require that all IARs disclose this conflict of interest when such recommendations are made. Also, we require IARs to disclose that Clients may purchase recommended services from other accountants not affiliated with us. In addition, Cantu may refer clients to us. However, there is no compensation, direct or indirect, from Cresta to Cantu for advisory client referrals to Cresta. Other Activities and Affiliations Manuel Garza is a partner with Cresta Advisors, Ltd., and works full time in this capacity. Mr. Garza has and Mark Deutsch have the following business affiliations and activities to disclose, as listed in the table below: Affiliation, Name of Firm Hours/year Investment related? 10% of Time Yes Manager, D&G Management Co. LLC (Pays a salary and splits profits at the end of the year, if any) CAIS Mgmt, LLC Less than 1% of Time No Cresta Advisors Insurance Solutions, LLC No Less than 10% of Time Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 19 of 23 © 2025 Red Oak Compliance Solutions LLC  3. Code of Ethics, Participation or Interest in Client Accounts and Personal Trading General Information The Adviser may recommend securities to Clients that the Adviser has purchased for their own accounts. The Firm may trade securities in their account that the Adviser has recommended as long as the Adviser places our orders after your orders. This policy is meant to prevent anyone with the Adviser from benefiting as a result of transactions placed on behalf of advisory accounts. The following acts are prohibited: • Employing any device, scheme or artifice to defraud • Making any untrue statement of a material fact • Omitting to state a material fact necessary in order to make a statement, in light of the circumstances under which it is made, not misleading • Engaging in any fraudulent or deceitful act, practice or course of business • Engaging in any manipulative practices • Participating in Client accounts Clients may request a copy of the Firm's Code of Ethics by contacting Manuel Garza. Personal Trading The Firm has established the following restrictions in order to ensure our fiduciary responsibilities to you, the Client, are met: • No securities for our personal portfolio(s) shall be bought or sold where this decision is substantially derived, in whole or in part, from the role of Investment Advisory Representative(s) of the Firm, unless the information is also available to the investing public on reasonable inquiry. In no case, shall the Firm put our own interests ahead of yours. • We emphasize your unrestricted right to decline to implement any advice rendered. However, some securities trade in sufficiently broad markets to permit transactions by clients to be completed without an appreciable impact on the markets of the securities. Under certain circumstances, exceptions may be made to the policies stated above. Records of these trades, including the reasons for the exceptions, will be maintained with our records as required. In addition, open-end mutual funds and/or investment sub-accounts which may comprise a variable insurance product are purchased or redeemed at a fixed net asset value. Therefore, purchases of mutual funds and/or variable insurance products by an advisor are not likely to have an impact on the prices of the fund in which you invest. These types of transactions are not prohibited by our policies and procedures. Certain affiliated accounts may trade in the same securities with your accounts on an aggregated basis when consistent with our obligation of best execution. When trades are aggregated, all parties will share the costs in proportion to their investment. We will retain records of the trade Order (specifying each Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 20 of 23 © 2025 Red Oak Compliance Solutions LLC  participating account) and its allocation. Completed Orders will be allocated as specified in the initial trade order. Partially filled Orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Responsibility It is the responsibility of all supervisory personnel to ensure that the Adviser conducts business with the highest level of ethical standards and in keeping with our fiduciary duties to you. The Adviser must put your interests first and refrain from having outside interests that conflict with your interests. Privacy Statement The Firm is committed to safeguarding Clients’ confidential information and holds all personal information provided in the strictest confidence. These records include all personal information that the Firm collects from you or receives from other firms in connection with any of the financial services they provide. The Firm also requires other firms with whom the Firm deals to restrict the use of your information. Our Privacy Policy is available upon request. Conflicts of Interest Manuel Garza and Mark Deutsch may employ the same strategy for their personal investment account as he does for his clients. However, they do not place their orders in a way to benefit from the purchase or sale of a security. We act in a fiduciary capacity. If a conflict of interest arises between us and you, we shall make every effort to resolve the conflict in your favor. Conflicts of interest may also arise in the allocation of investment opportunities among the accounts that we advise. We will seek to allocate investment opportunities according to what we believe is appropriate for each account. We strive to do what is equitable and in the best interests of all the accounts we advise. 4. Soft Dollars We do not have any soft dollar benefits for the custodial services we receive. 5. Brokerage for Client Referrals We may receive additional compensation for sales of insurance products only. 6. Review of Accounts Reviews with the client are conducted at least annually or as agreed to by Cresta and the client. We provide daily monitoring of our asset allocation models. Reviews will be conducted by the Primary advisor for the account and/or the Chief Compliance Officer Manuel Garza. You may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, we will monitor for changes and shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Reports You will be provided with account statements reflecting the transactions occurring in the account on at least a quarterly basis. These statements will be available electronically in the client online portal, and will be sent by mail upon request. You need to notify us of any discrepancies in the account(s) or any concerns you have about the account(s). Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 21 of 23 © 2025 Red Oak Compliance Solutions LLC  7. Client Referrals and Other Compensation We do not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to our clients nor do we directly or indirectly pay any compensation to another person if they refer clients to us. As disclosed in Item 10, we are compensated for referrals to Cantu for their accounting services. Standing Letters of Authorization Cresta Advisors is deemed to have custody of client funds or securities as a result of maintaining standing letters of authorization (SLOA) for the purpose of distributing funds from a client’s account. For those accounts in which we have the ability to initiate distributions from a client’s account, via journal, ACH or wire to a third party, which is an account held in the name of someone other than the client, we will ensure the following conditions have been met in order for us to be in compliance with SEC and State Custody Rules and ensure the safe keeping of our client’s funds: 1. The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client has the ability to terminate or change the instruction to the client’s qualified custodian. 5. The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. 6. The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. 7. The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 8. Financial Information We have no financial commitment that would impair our ability to meet any contractual and fiduciary commitments to you, our client. We have not been the subject of any bankruptcy proceedings. In no event shall we charge advisory fees that are both in excess of twelve hundred dollars and more than six months in advance of advisory services rendered. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 22 of 23 © 2025 Red Oak Compliance Solutions LLC  9. Discretion We provide discretionary asset management or non-discretionary asset management. Discretionary asset management means you determine whether we will receive discretionary authority from you at the beginning of the relationship to select the identity and amount of securities to be bought or sold. This information is described in the Advisory Agreement you sign with us. In all cases, however, this discretion is exercised in a manner consistent with your stated investment objectives for your account. When selecting securities and determining amounts, we observe the investment policies, limitations and restrictions you have set. For registered investment companies, our authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favor the holding of investments once made. If you do not give us the authority to manage your account on a discretionary basis, which will be evidenced via the written, non-discretionary agreement between the client and the Adviser, then we cannot buy or sell any security in your account without your prior, express permission. Please be advised that this could adversely affect the Adviser’s ability to take advantage of price swings when attempting to purchase or sell securities in the client’s account, especially in instances where the Adviser is not able to contact the client in a timely manner. When active asset management services are provided on a non-discretionary basis the client will enter into a separate custodial agreement with the custodian. The custodian agreement will include a limited power of attorney to trade in the client’s account(s) which authorizes the custodian to take instructions from us regarding trades approved by the client. Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2025 Page 23 of 23 © 2025 Red Oak Compliance Solutions LLC