View Document Text
Form ADV
Disclosure Brochure
October 2, 2025
Business Address:
11700 Katy Freeway, Suite 100
Houston, TX 77079
Phone Number: (713) 244-8848
Website: www.PatronPartnersAdvisors.com
This Brochure provides information about the qualifications and business practices of Patron Partners,
LLC (“Patron Partners” or “the Firm”). If you have any questions about the contents of this brochure,
please contact us at the telephone number listed above. For compliance specific requests, please
call 205-847-1343. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov.
The Firm has filed to become an SEC registered investment adviser. Registration does not imply any
level of skill or training.
ITEM 2 - MATERIAL CHANGES
In this Item, Patron Partners, LLC (hereby known as “Patron Partners” or the “Firm”) is required to discuss any
material changes that have been made to the Brochure since the last annual amendment. The business
practices of the Firm are substantially the same as represented in the Firm’s previous and current years’
annual updated Brochures. Any material changes are discussed below:
• The Firm has amended its Form ADV to update current Assets Under Management.
• The Firm has removed having a minimum fee.
We will ensure that all current clients receive a Summary of Material Changes and updated Brochure within
120 days of the close of our business’ fiscal year. A Summary of Material Changes is also included with our
Brochure on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Patron
Partners is # 310629. We may further provide other ongoing disclosure information about material changes
as necessary and will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
Currently, our Brochure may be requested by contacting TJ Claud, Chief Compliance Officer at 205-847-1343
or tclaud@oneascent.com.
2
Patron Partners, LLC Disclosure Brochure
ITEM 3 - TABLE OF CONTENTS
ITEM 2 - MATERIAL CHANGES ......................................................................................................................... 2
ITEM 3 - TABLE OF CONTENTS......................................................................................................................... 3
ITEM 4 - ADVISORY BUSINESS ......................................................................................................................... 4
ITEM 5 - FEES AND COMPENSATION ............................................................................................................... 5
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................................... 8
ITEM 7 - TYPES OF CLIENTS ............................................................................................................................. 8
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .......................................... 8
ITEM 9 - DISCIPLINARY INFORMATION ......................................................................................................... 13
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................................ 14
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ........................................................................................................................................................ 15
ITEM 12 - BROKERAGE PRACTICES ................................................................................................................ 16
ITEM 13 - REVIEW OF ACCOUNTS ................................................................................................................. 19
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION......................................................................... 20
ITEM 15 - CUSTODY ....................................................................................................................................... 21
ITEM 16 - INVESTMENT DISCRETION ............................................................................................................ 22
ITEM 17 - VOTING CLIENT SECURITIES .......................................................................................................... 22
ITEM 18 - FINANCIAL INFORMATION ............................................................................................................ 23
3
Patron Partners, LLC Disclosure Brochure
ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Patron Partners, LLC (“Patron Partners” , “we” , “our,” or “us”) is a privately owned limited liability
company headquartered in Houston, TX.
Patron Partners is a registered investment adviser with the U.S. Securities and Exchange Commission. The
Firm was formed in 2020 and is owned by Stephen Caton and Richard Figueroa.
As of December 31, 2024, Patron Partners managed approximately $295,633,043 in assets for
approximately 633 accounts on a discretionary basis and approximately $53,562,721 in assets for
approximately 26 accounts on a non-discretionary basis. In total, the Firm managed $349,195,764 in
assets for approximately 659 accounts. No accounts are in a wrap fee program.
While this brochure generally describes the business of the Firm, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons
occupying a similar status or performing similar functions), employees or any other person who provides
investment advice on the Firm’s behalf and is subject to the Firm’s supervision or control.
Advisory Services Offered
The Firm offers discretionary and non-discretionary investment management and investment advisory
services. Prior to the Firm rendering any of the foregoing advisory services, clients are required to enter into
one or more written agreements with the Firm setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
Investment Management Services
Patron Partners offers continuous and regular investment supervisory services on a discretionary and non-
discretionary basis. We work with clients and have the ongoing responsibility to select and/or make
recommendations based upon the objectives of the client, as to specific securities or other investments
that he/she recommends or purchases/sells in clients’ accounts. We utilize a variety of investment types
when making investment recommendations/purchases in client accounts which
include, but are not
limited to equity securities, fixed income securities, alternatives, and mutual funds. The investments
recommended/purchased are based off the clients’ individual needs, goals, and objectives. The Firm
offers investment advice on any investment held by the client at the start of the advisory relationship. We
describe the material investment risks under Item 8 – Methods of Analysis,
Investment Strategies, and
Risk of Loss. Financial Planning may be provided to clients as a part of the Investment Management
Services. When being provided as a separate service it is described in this section under Financial
Consulting Services below.
We discuss our discretionary authority below under Item 16 – Investment Discretion. For more
information about the restriction’s clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this item below. We describe the fees charged for investment management
services below under Item 5 – Fees and Compensation.
4
Patron Partners, LLC Disclosure Brochure
Financial Planning & Consulting Services
Our Financial Planning and Consulting Service offers clients the ability to have their investment portfolio
allocated among different financial institutions and reviewed by an Investment Adviser Representative
for a negotiated fee. This consultation offers the client a detailed look at their financial condition in
relation to their investment objectives, risk tolerance, time horizon, and any financial goals that they may
be seeking to achieve. This Financial Consultation Service offered by us may or may not be in conjunction
with one of our other fee-based programs.
Patron Partners provides a variety of financial consulting services to individuals, families, and other clients
regarding the management of their financial resources based upon an analysis of client’s current situation,
goals, and objectives. Consulting encompasses one or more of the following areas: Investment Planning,
Retirement Planning, Charitable Planning, Education Planning, Business and Personal Financial Planning.
Our financial consultations rendered to clients usually include general recommendations for a course of
activity or specific actions to be taken by the clients. In performing these services, Patron Partners is not
required to verify any information received from the client or from the client’s other professionals
(e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. We may
recommend clients engage the Firm for additional related services, its Supervised Persons in their
individual capacities as registered representatives of a broker-dealer and/or other professionals to
implement its recommendations. Clients are advised that a conflict of interest exists if clients engage
the Firm or its affiliates to provide additional services for compensation. Clients retain absolute
discretion over all decisions regarding implementation and are under no obligation to act upon any of
the recommendations made by the Firm under a financial planning or consulting engagement. Clients are
advised that it remains their responsibility to promptly notify the Firm of any change in their financial
situation or investment objectives for the purpose of reviewing, evaluating, or revising the Firms
recommendations and/or services.
For financial consulting engagements, we provide our clients with a written summary of our observations
and recommendations. One-time consultations are typically completed within six (6) months of the client
signing a contract with us, assuming that all the information and documents we request from the client
are provided to us promptly. Services provided under an on-going consultation agreement are conducted
on a regular basis, but no less than annually with the client. The client is under no obligation to act upon
If the client elects to act on our recommendations, the client
the investment adviser’s recommendation.
is under no obligation to effect the transaction through us.
We describe fees charged for Financial Consultation Services below under Item 5 - Fees and Compensation.
ITEM 5 - FEES AND COMPENSATION
Fee Schedule & Billing Method
Patron Partners offers services on a fee basis, which may include fixed fees, as well as fees based upon
assets under management or advisement.
5
Patron Partners, LLC Disclosure Brochure
Investment Management Services
The annual management fee for our Investment Management Services is based on the total dollar asset
value of the assets maintained in your account. The fee assessed and/or charged is based on what is
stipulated in the Investment Advisory Agreement signed by each client. The Firm offers services on a fee
basis, which may include fixed fees, as well as fees based upon assets under management. Additionally,
certain of the Firm’s Supervised Persons, in their individual capacities, may offer securities brokerage
services under a separate commission-based arrangement.
Our annual fee ranges up to 2.00% annually and is assessed and/or charged monthly in arrears, based on
prior period-end value. Inflows and outflows of cash are considered on a prorated basis in this calculation.
Margin debits in accounts will decrease the fee calculated.
We discuss our discretionary authority below under Item 16 – Investment Discretion.
Financial Consultation Service
Patron Partners will quote the client a fixed fee that is based on the estimate of time to complete the
project, or will negotiate another fee arrangement for the client, pursuant to the Financial Planning &
Consulting Agreement. The total estimated fee, as well as the ultimate fee that we charge you, is based
on the scope and complexity of our engagement with you. We may require a negotiable retainer, which
is calculated based on the estimated total financial planning or consulting fee with the remainder of the
fee directly billed to you and due to us within thirty (30) days of your financial plan being delivered or
consultation rendered to you. In all cases, we will not require a retainer exceeding $1,200 when services
cannot be rendered within six (6) months. In the event that the client or the Firm terminates the financial
consulting engagement before completion of the financial plan or consultation, the Firm will determine
the fees due for the services already completed. For flat fee engagements, Client may receive a pro-rata
refund of unearned fees which will be based on the hours Advisor has spent on the engagement, billed
at the Advisor’s hourly rate for such engagements. If the retainer previously paid by you is more than the
fees due, the Firm will refund the amount of the unearned fees to you. If the amount due is more than
the retainer we collected from you, The Firm will send you an invoice for the remainder due, which will
be due within thirty (30) days of the invoice date. For ongoing engagements, Client will receive a pro-
rata refund for any remaining days left in the quarter in which the contract was terminated.
Use of Independent Managers
The Firm may select certain Independent Managers to actively manage a portion of its clients’ assets. The
specific terms and conditions under which a client engages an Independent Manager may be set forth in
a separate written agreement with the designated Independent Managers engaged to manage their
assets.
The Firm evaluates a variety of information about Independent Managers, which may include the
Independent Managers’ public disclosure documents, materials supplied by the Independent Managers
themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks
to assess the Independent Managers’ investment strategies, past performance, and risk results in relation
to its clients’ individual portfolio allocations and risk exposure. The Firm also takes into consideration each
Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and
6
Patron Partners, LLC Disclosure Brochure
research capabilities, among other factors.
The Firm continues to provide services relative to the discretionary selection of the Independent
Managers on discretionary accounts. On an ongoing basis, the Firm monitors the performance of those
accounts being managed by Independent Managers. The Firm seeks to ensure the Independent Managers’
strategies and target allocations remain aligned with its clients’ investment objectives and overall best
interests.
Other Fees and Expenses
In addition to the advisory fees paid to Patron Partners, clients may incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, platform service providers, banks and
other financial institutions (collectively “Financial Institutions”). These additional charges may include
securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets,
reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as
disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales
charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
taxes on brokerage accounts and securities transactions. In addition, fees charged by the Independent
Managers are charged to the clients separately. The Firm’s brokerage practices are described at length in
Item 12, below.
Direct Fee Debit
Clients generally provide Patron Partners and/or the Independent Managers with the authority to directly
debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the
qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees,
have agreed to send statements to clients not less than quarterly detailing account transactions, including
any amounts paid to the Firm.
Account Additions and Withdrawals
As stated above, clients may make additions to and withdrawals from their account at any time, subject
to Patron Partners’ right to terminate an account. Additions may be in cash or securities provided that the
Firm reserves the right to liquidate any transferred securities or declines to accept particular securities
into a client’s account. Clients may withdraw account assets on notice to the Firm, subject to the usual
and customary securities settlement procedures. However, the Firm generally designs its portfolios as
long-term investments, and the withdrawal of assets may impair the achievement of a client’s investment
objectives. The Firm may consult with its clients about the options and implications of transferring
securities. Clients are advised that when transferred securities are liquidated, they may be subject to
transaction fees, short- term redemption fees, fees assessed at the mutual fund level (e.g., contingent
deferred sales charges) and/or tax ramifications.
Termination
Either party may terminate the advisory agreement at any time by providing written notice to the other
party. The client may terminate the agreement at any time by writing Patron Partners at our office.
7
Patron Partners, LLC Disclosure Brochure
The Firm will refund any prepaid, unearned advisory fees.
Terminations will not affect liabilities or obligations from transactions initiated in client accounts prior to
termination. In the event the client terminates the investment advisory agreement. The Firm will not
liquidate any securities in the account unless instructed by the client to do so. In the event of client’s death
or disability, the Firm will continue management of the account until we are notified of client’s death or
disability and given alternative instructions by an authorized party.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Patron Partners does not charge performance-based fees or other fees based on a share of capital gains
on or capital appreciation of the assets of a client.
ITEM 7 - TYPES OF CLIENTS
Patron Partners provides asset management, financial consulting, ERISA plan advisory & consulting,
investment advisory consultation, and selection of third-party money managers. Our services are
provided on a discretionary or non-discretionary basis to a variety of clients, such as institutional
investors, individuals, high net worth individuals, trusts and estates, qualified purchasers, and individual
participants of retirement plans. In addition, we may also provide advisory services to entities such as
pension and profit-sharing plans, businesses, and other investment advisers.
Account Requirements
The Firm does not impose a stated minimum fee or minimum portfolio value for starting and maintaining
an investment management relationship. Certain Independent Managers may, however, impose more
restrictive account requirements and billing practices from the Firm. In these instances, the Firm may alter
its corresponding account requirements and/or billing practices to accommodate those of the
Independent Managers.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF
LOSS
Methods of Analysis and Investment Strategies
We will typically use fundamental, cyclical, charting, and/or technical analysis in the selection of
individual securities. Patron Partners selects categories of investments based on the clients' attitudes
about risk and their need for capital appreciation or income. Different instruments involve different
levels of exposure to risk. We seek to select individual securities with characteristics that are most
consistent with the client’s objectives. Since the Firm treats each client account uniquely, client portfolios
with a similar investment objectives and asset allocation goals may own different securities. Tax factors
will not influence the Firm’s investment decisions.
General Investment Strategies
Patron Partners generally uses diversification in an effort to minimize risk and optimize the potential
8
Patron Partners, LLC Disclosure Brochure
return of a portfolio. More specifically, we utilize multiple asset classes, investment styles, market
capitalizations, sectors, and regions to provide diversification. Each portfolio composition is determined
in accordance with the clients’ investment objectives, risk tolerance, and time horizon. We utilize both
passive and active investment management strategies in an effort to optimize portfolios.
Our general investment strategy is to seek real capital growth proportionate with the level of risk the
client is willing to take. We develop a Client Profile to help identify the client’s investment objectives, time
horizon, risk tolerance, tax considerations, target asset allocation, and any special considerations and/or
restrictions the client chooses to place on the management of the account. The Firm will then recommend
investments that we feel are consistent with the Client Profile.
After defining client needs, Patron Partners develops and implements plans for the client’s account. Then,
we monitor the results and make adjustments as needed. As the initial assumptions change, the plans
themselves may need to be adapted. Continuous portfolio management is important in an effort to keep
the client’s portfolio consistent with the client’s objectives.
Methods of Analysis for Selecting Securities
Patron Partners’ investment advisor representatives (“IARs”) may use, among others, technical,
fundamental, and/or charting analysis in the selection of individual equity securities. Additionally, our IARs
may use specific strategies or resources in the method of analysis and selection of mutual funds.
Technical Analysis
The effectiveness of technical analysis depends upon the accurate forecasting of major price moves or
trends in the securities traded by the IAR. However, there is no assurance of accurate forecasts or that
trends will develop in the markets we follow. In the past, there have been periods without discernable
trends and similar periods will presumably occur in the future. Even where major trends develop, outside
factors like government intervention could potentially shorten them.
Furthermore, one limitation of technical analysis is that it requires price movement data, which can
translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic
market, a technical method may fail to identify trends requiring action. In addition, technical methods may
overreact to minor price movements, establishing positions contrary to overall price trends, which may
result in losses. Finally, a technical trading method may under perform other trading methods when
fundamental factors dominate price moves within a given market.
The calculations that underline our system, methods, and strategies involve many variables, including
determinants from information generated by computers and/or charts. The use of a computer in collating
information or in developing and operating a trading method does not assure the success of the method
because a computer is merely an aid in compiling and organizing trade information.
Accordingly, no assurance is given that the decisions based on computer-generated information will
produce profits for a client’s account.
Relative Strength Analysis
Relative strength measures one stock versus another or a group of stocks versus an index, such as the S&P
500. Through relative strength analysis, we can rank areas of the market that are outperforming or
9
Patron Partners, LLC Disclosure Brochure
underperforming the broad market, whether the Russell 3000 or S&P 500. For our purposes, we use the
S&P 500. We then add the highest relative strength sectors and macro areas (i.e. small cap vs. large cap)
to our investment model, using primarily ETFs. The general premise is that those areas of the market with
highest relative strength outperform over the long term. Additionally, as a risk override, we run moving
average analysis to identify when markets are most vulnerable, and from time to time lighten market
exposure.
Fundamental Analysis
Fundamental analysis assesses the financial health and management effectiveness of a business by
analyzing a company’s financial reports, key financial ratios, industry developments, economic data,
competitive landscape, and management. The objective of fundamental analysis is to use historical and
current financial data to assess the stock valuation of a company, evaluate company profitability, credit
risk, and forecast future performance of the company and its share price. Fundamental analysis
assumptions and calculations are based on historical data and forecasts; therefore, the quality of
information and assumptions used are critical. Differences can exist between market fundamentals and
how you analyze them.
Charting Analysis
Charting analysis involves the use of patterns in performance charts. Our IARs use this charting technique
to search for patterns in an effort to predict favorable conditions for buying and/or selling a security.
Mutual Funds
In analyzing mutual funds, our IARs use various sources of information, including data provided by
Morningstar. We review key characteristics such as historical performance, consistency of returns, risk
level, and size of fund. Expense ratio and other costs are also significant factors in fund selection. We also
subscribe to/access additional information from other sources that inform our general macro-economic
view.
Alternative Investments
IARs may use Alternative Investments as a way to diversify a portfolio. Alternative Investments are
considered to be “non-correlated” assets, meaning that they do not tend to run up or down (track) with
the market like standard securities typically do. The main goal of alternatives is to provide access to other
return sources, with the potential benefit of reducing risk of a client’s portfolio, improving returns, or
both.
Specific Investment Strategies for Managing Portfolios
IARs may use Modern Portfolio Theory tactical asset allocation, cash as a strategic asset, long-term
holding, trend, dollar-cost-averaging, defensive portfolio strategies in the construction and management of
client portfolios. There is no guarantee that any of the following strategies will be successful , and we make
no promises or warranties as to the accuracy of our market analysis.
Modern Portfolio Theory (MPT)
IARs use the Modern Portfolio Theory, which has a basic concept of using diversification in an effort to
10
Patron Partners, LLC Disclosure Brochure
help minimize risk and optimize the potential return of a portfolio.
Tactical Asset Allocation
IARs may use a tactical asset allocation strategy in the shorter term to deviate from a client’s long- term
strategic asset allocation target in an effort to take advantage of what we perceive as market pricing
anomalies or strong market sectors or to avoid perceived weak sectors. Once they achieve the desired
short-term opportunities or perceives those opportunities have passed, we generally return a client’s
portfolio to the original strategic asset mix.
Cash as a Strategic Asset
IARs may use cash as a strategic asset and at times move or keep client’s assets in cash or cash
equivalents. While high cash levels can help protect a client’s assets during periods of market decline, there
is a risk that our timing in moving to cash is less than optimal upon either exit or reentry into the market,
potentially resulting in missed opportunities during positive market moves.
Long-term Holding
IARs do not generally purchase securities for clients with the intent to sell the securities within 30 days of
purchase, as we do not generally use short-term trading as an investment strategy. However, there may
be times when we will sell a security fora client when the client has held the position for less than 30 days.
IARs do not attempt to time short-term market swings. Short-term buying and selling of securities is
typically limited to those cases where a purchase has resulted in an unanticipated gain or loss in which we
believe that a subsequent sale is in the best interest of the client.
Trend
IARs may manage client assets using a trend following methodology based on the 200-day average and
grounded in a strong sell discipline for all positions within the portfolio.
Dollar-Cost-Averaging
Dollar cost averaging involves investing money in multiple installments over time to take advantage of price
fluctuations in the attempt to get a lower average cost per share.
Defensive Strategies
If our IAR anticipates poor near-term prospects for equity markets, we may adopt a defensive strategy
for clients’ accounts by investing substantially in fixed income securities and/or money market
instruments. We may also utilize low, non or negative correlated investments through mutual funds and
EFT’s. There can be no guarantee that the use of defensive techniques would be successful in avoiding
losses.
Margin
Some clients of Patron Partners maintain margin accounts to facilitate short-term borrowing needs, which
are unrelated to our investment strategy(ies). For some high-net worth (HNW) clients that are seeking a
more aggressive strategy for their portfolio, our IARs may work with those clients on an individual basis
to develop a leveraged strategy utilizing margin to increase market participation portfolio as part of a
11
Patron Partners, LLC Disclosure Brochure
customized investment strategy. Clients are responsible for any brokerage or margin charges in addition
to advisory fees. Risks of using margin include “margin calls” (also called "fed calls" or "maintenance
calls.") Margin calls occur when account values decrease below minimum maintenance margin levels
established by the broker-dealer that holds the securities in the client’s account, requiring the investor to
deposit additional money or securities into their margin account.
While the use of margin borrowing can increase returns, it can also magnify losses. Clients must specifically
request to establish a margin account.
Additional Strategies
Clients interested in learning more about any of the above strategies should contact us for more
information and/or refer to the prospectus of any mutual fund. We may also consider additional strategies
by specific client request.
Investing Involves Risk
General Risks of Owning Securities
Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market
may increase and your account(s) could enjoy a gain, it is also possible that the stock market may
decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated
with investing in the stock market, are appropriately diversified in your investments, and ask us any
questions you may have.
Risk of Loss
Diversification does not guarantee a profit or guarantee to protect you against loss, and there is no
guarantee that your investment objectives will be achieved. The Firm strategies and recommendations
may lose value. All investments have certain risks involved including, but not limited to the following:
• Stock Market Risk: The value of securities in the portfolio will fluctuate and, as a result, the value
may decline suddenly or over a sustained period of time.
• Managed Portfolio Risk: The manager’s investment strategies or choice of specific securities may
•
be unsuccessful and may cause the portfolio to incur losses.
Industry Risk: The portfolio’s investments could be concentrated within one industry or group of
industries. Any factors detrimental to the performance of such industries will disproportionately
impact your portfolio. Investments focused in a particular industry are subject to greater risk
and are more greatly impacted by market volatility than less concentrated investments.
• Non-U.S. Securities Risk: Non-U.S. securities are subject to the risks of foreign currency
fluctuations, generally higher volatility, and lower liquidity than U.S. securities, less developed
securities markets and economic systems and political economic instability.
• Emerging Markets Risk: To the extent that your portfolio invests in issuers located in emerging
markets, the risk may be heightened by political changes and changes in taxation or currency
controls that could adversely affect the values of these investments. Emerging markets have been
more volatile than the markets of developed countries with more mature economies.
• Currency Risk: The value of your portfolio’s investments may fall as a result of changes in exchange
rates.
12
Patron Partners, LLC Disclosure Brochure
•
• Credit Risk: Most fixed income instruments are dependent on the underlying credit of the issuer.
If we are wrong about the underlying financial strength of an issuer, we may purchase securities
where the issuer is unable to meet its obligations. If this happens, your portfolio could sustain
an unrealized or realized loss.
Inflation Risk: Most fixed income instruments will sustain losses if inflation increases, or the
market anticipates increases in inflation. If we enter a period of moderate or heavy inflation,
the value of your fixed income securities could go down.
Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate.
•
• Margin Risk: The use of margin is not suitable for all investors since it increases leverage in your
Account and therefore risk.
• ETF and Mutual Fund Risk: When we invest in an ETF or mutual fund fora client, the client will
bear additional expenses based on its pro rata share of the ETFs or mutual fund’s operation
expenses, including the potential duplication of management fees. The risk of owning an ETF or
mutual fund greatly reflects the risks of owning the underlying securities the ETF or mutual fund
holds. Clients may also incur brokerage costs when purchasing ETFs.
• Derivative Risk: Derivatives are securities, such as futures contracts or options, whose value is
derived from that of other securities or indices. Derivatives can be used for hedging (attempting
to reduce risk by offsetting one investment position with another) or non-hedging purposes.
Hedging with derivatives may increase expenses, and there is no guarantee that a hedging strategy
will achieve the desired results. Utilizing derivatives can cause greater than ordinary investment
risk, which could result in losses.
• Alternative Investment Risk: Alternative Investments involve a high degree of risk, often engage
in leveraging and other speculative investment practices that may increase the risk of investment
loss, can be highly illiquid, are not always required to provide periodic pricing or valuation
information to
investors, may involve complex tax structures and delays in distributing important
tax information, are not subject to the same regulatory requirements as mutual funds, often
charge high fees which may offset any trading profits, and in many cases the underlying
investments are not transparent and are known only to the investment manager. Alternative
investment performance can be volatile. An investor could lose all or a substantial amount of his
or her investment.
• Management Risk: Your investment with us varies with the success and failure of our investment
investment
strategies, research, analysis, and determination of portfolio securities. If our
strategies do not produce the expected returns, the value of the investment may decrease.
• Use of Independent Managers Risk: As stated above, the Firm may select certain Independent
Managers to manage a portion of its clients’ assets. In these situations, the Firm continues to
conduct ongoing due diligence of such managers, but such recommendations rely to a great
extent on the Independent Managers’ ability to successfully implement their investment
strategies. In addition, the Firm generally may not have the ability to supervise the Independent
Managers on a day-to-day basis.
ITEM 9 - DISCIPLINARY INFORMATION
Patron Partners and our personnel seek to maintain the highest level of business professionalism,
integrity, and ethics. We are required to disclose the facts of any legal or disciplinary events that are
material to a client’s evaluation of our business or the integrity of our management. We do not have any
13
Patron Partners, LLC Disclosure Brochure
required disclosures to this Item.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Patron Partners is required to disclose any relationship or arrangement that is material to its advisory
business or to its clients with certain related persons.
Licensed Insurance Agents
Certain of the Firm’s Supervised Persons are licensed insurance agents and may offer certain insurance
products on a fully disclosed commissionable basis. A conflict of interest exists to the extent that the
Firm recommends the purchase of insurance products where its Supervised Persons may be entitled
to insurance commissions or other additional compensation. The Firm has procedures in place whereby
it seeks to ensure that all recommendations are made in its clients’ best interest regardless of any such
affiliations.
DPL Financial Partners, LLC
DPL Financial Partners, LLC (“DPL”) is a third-party provider of a platform of insurance consultancy services
to Clients with a current or future need for insurance products. DPL offers Patron a membership to its
platform for a fixed annual fee and, through its licensed insurance agents who are registered
representatives of The Leaders Group, Inc. (“The Leaders Group”), an unaffiliated SEC-registered broker
dealer and FINRA member, offers the Firm a variety of services relating to fee-based insurance products.
These services include, among others, providing the Firm with analyses of their current methodology for
evaluating client insurance needs, educating, and acting as a resource to members regarding insurance
products generally and specific insurance products owned by their clients or that their clients are
considering purchasing, and providing members access to and product marketing support regarding fee
based products that insurers have agreed to offer to Clients through DPL’s platform. For providing
platform services to the Firm, DPL receives service fees from the insurers that offer their fee-based
products through the platform. These service fees are based on the insurance premiums received by the
insurers.
DPL is licensed as an insurance producer in jurisdictions where required to perform the platform services.
Its representatives are also licensed as insurance producers, appointed as insurance agents of the insurers
offering their products through the platform, and registered representatives of The Leaders Group.
OneAscent Financial Services, LLC
Patron Partners maintains a business relationship with OneAscent Financial Services, LLC (“OAFS”), a
service platform for investment adviser representatives and registered investment advisers. OAFS is
an investment adviser registered with the United States Securities and Exchange Commission. OAFS
provides operations, compliance, trading, technology, and other related services. Clients should be
aware that this business relationship is a conflict of interest. Patron Partners pays a platform fee to
OAFS for services rendered, and the platform fee decreases and Patron Partners’ assets under
management placed on the OAFS platform increases.
14
Patron Partners, LLC Disclosure Brochure
Retirement Plan Accounts
The Firm may from time to time recommend the rollover to an IRA from an employer sponsored
retirement plan. This product will be recommended when it is deemed by the Firm to be in the best
interest of the client. It is understood that the Investment Advisor Representative will receive
management fee paid by me as indicated by the client agreement that will be signed when the account is
opened.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice that is in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
When recommending the rollover to an IRA from an employer sponsored retirement plan, you will be
provided with disclosure on the reasons why the transaction is in your best interested, it will be required
to be signed by both you and the advisor and will be maintained in your file.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Patron Partners believes that we owe clients the highest level of trust and fair dealing. As part of our
fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our personnel.
We have adopted a Code of Ethics that emphasizes the high standards of conduct that Patron Partners
seeks to observe. Our personnel are required to conduct themselves with integrity at all times and follow
the principles and policies detailed in our Code of Ethics.
Patron Partners’ Code of Ethics attempts to address specific conflicts of interest that either we have
identified or that could likely arise. Patron Partner’s personnel are required to follow clear guidelines
from the Code of Ethics in areas such as gifts and entertainment, other business activities, prohibitions of
15
Patron Partners, LLC Disclosure Brochure
insider trading, and adherence to applicable federal securities laws. Additionally, individuals who
formulate investment advice for clients, or who have access to nonpublic information regarding any
clients’ purchase or sale of securities, are subject to personal trading policies governed by the Code of
Ethics (see below).
Patron Partners will provide a complete copy of the Code of Ethics to any client or prospective client
upon request.
Personal Trading Practices
Patron Partners and our personnel may purchase or sell securities for themselves, regardless of whether
the transaction would be appropriate for a client’s account. Patron Partners and our personnel may
purchase or sell securities for themselves that we also recommend/utilize for clients. This includes
related securities (e.g., warrants, options, or other derivatives). This presents a potential conflict of
interest, as we have an incentive to take investment opportunities from clients for our own benefit,
favor our personal trades over client transactions when allocating trades, or use the information about
the transactions we intend to make for clients to our personal benefit by trading ahead of clients.
Our policies to address these conflicts include the following:
1. The client receives the opportunity to act on investment decisions/recommendations prior to
and in preference to accounts of your Patron Partner’s investment advisor representative (“IAR”).
2. The Firm prohibits trading in a manner that takes personal advantage of price movements caused
3.
by client transactions.
If your IAR wishes to purchase or sell the same security as he/she recommends or takes action to
purchase or sell fora client, he/she will not do so until the custodian fills the client’s order, if the
order cannot be aggregated with the client order. As a result of this policy, it is possible that
clients may receive a better or worse price than IAR for transactions in the same security on the
same day as a client.
4. The Firm requires our IARs to report personal securities transactions on at least a quarterly basis.
5. Conflicts of interest also may arise when Firm IARs become aware of limited offerings or IPOs,
including private placements or offerings of interests in limited partnerships or any thinly traded
securities, whether public or private. Given the inherent potential for conflict, limited offerings
and IPOs demand extreme care. IARs are required to obtain pre-approval from the Chief
Compliance Officer before trading in limited offerings and are prohibited from transacting in IPOs
for personal accounts.
6. Under certain limited circumstances, we make exceptions to the policies stated above. The Firm
will maintain records of these trades, including the reasons for any exceptions.
ITEM 12 - BROKERAGE PRACTICES
Patron Partners requires accounts that are not managed by third-party investment managers to be
established with the following custodian: Charles Schwab & Co, Inc (“Schwab”), member FINRA/SIPC.
Patron Partners engages the custodians to clear transactions and custody assets. The custodian provide
The Firm with services that assist us in managing and administering clients' accounts which include
software and other technology that (i ) provide access to client account data (such as trade confirmations
16
Patron Partners, LLC Disclosure Brochure
and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple
client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from
its clients' accounts; and (v) assist with certain back-office functions, recordkeeping and client reporting.
As part of the arrangement described above, the custodians also make certain research and brokerage
services available at no additional cost to our firm. These services include certain research and brokerage
services, including research services obtained by the custodians directly from independent research
companies, as selected by our Firm (within specific parameters). Research products and services provided
by the custodians to our firm may include research reports on recommendations or other information
about, particular companies or industries; economic surveys, data and analyses; financial publications;
portfolio evaluation services; financial database software services; computerized news and pricing services;
quotation equipment for use in running software used in investment decision-making; and other products
or services that provide lawful and appropriate assistance by the custodians to our firm in the
performance of our
investment decision-making responsibilities. The aforementioned research and
brokerage services are used by our firm to manage accounts. Without this arrangement, our firm might
be compelled to purchase the same or similar services at our own expense.
As a result of receiving the services discussed above, we have an incentive to continue to use or expand
the use of the custodians’ services. Our firm examined this conflict of interest when we chose to enter into
the relationship with the custodians and we have determined that the relationship is in the best interest of
our firm’s clients and satisfies our client obligations, including our duty to seek best execution.
The custodians charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged
for individual equity and debt securities transactions).
The custodians generally do not charge clients separately for custody services but are compensated by
account holders through commissions and other transaction-related or asset-based fees for securities
trades that are executed through the custodians or that settle into accounts at the custodians. The
custodians charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged
for individual equity and debt securities transactions). The custodians enable us to obtain many no-load
mutual funds without transaction charges and other no-load funds at nominal transaction charges. The
custodians’ commission rates are generally discounted from customary retail commission rates. However,
the commission and transaction fees charged by the custodians may be higher or lower than those
charged by other custodians and broker-dealers.
We may aggregate (combine) trades for ourselves or our associated persons with your trades, providing
that the following conditions are met:
1. Our policy for the aggregation of transactions shall be fully disclosed separately to our existing
clients (if any) and the broker-dealer(s) through which such transactions will be placed.
2. We will not aggregate transactions unless we believe that aggregation is consistent with our duty
to seek the best execution (which includes the duty to seek best price) for you and is consistent
with the terms of our investment advisory agreement with you for which trades are being
17
Patron Partners, LLC Disclosure Brochure
aggregated.
3. No advisory client will be favored over any other client; each client that participates in an
aggregated order will participate at the average share price for all our transactions in a given
security on a given business day, with transaction costs based on each client’s participation in the
transaction.
4. We will prepare a procedure specifying how to allocate the order among those clients.
5.
If the aggregated order is filled in its entirety, it will be allocated among clients in accordance
with the allocation statement; if the order is partially filled, it will be allocated pro-rata based on
the allocation statement.
6. Our books and records will separately reflect, for each client account, the orders of which
aggregated, the securities held by, and bought for that account.
7. We will receive no additional compensation or remuneration of any kind as a result of the
8.
proposed aggregation. and
Individual advice and treatment will be accorded to each advisory client.
As a matter of policy and practice, we do not utilize research, research-related products and other
services obtained from broker-dealers, or third parties, on a soft dollar commission basis other than
what is described above.
Factors Considered in Recommending Custodians
We consider several factors in recommending custodians to a client. Factors that we consider when
recommending custodians may include financial strength, reputation, execution, pricing, reporting,
research, and service. We will also take into consideration the availability of the products and services
received or offered (detailed above) by the custodians.
Directed Brokerage Transactions
Patron Partners does not allow clients to direct brokerage to a specific broker-dealer. For an individual
third-party money manager’s policy on directed brokerage transactions, you must refer to Item 12 –
Brokerage Practices of that managers form ADV 2A brochure.
Special Considerations for ERISA Clients
A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a
specific broker or dealer in order to obtain goods or services on behalf of the plan. Such direction is
permitted provided that the goods and services provided are reasonable expenses of the plan incurred
in the ordinary course of its business for which it otherwise would be obligated and empowered to pay.
ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the
exclusive benefit of the plan. Consequently, we will request that plan sponsors who directs plan
brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit
of the plan.
Trade Errors
We have implemented procedures designed to prevent trade errors; however, trade errors in client
accounts cannot always be avoided. Consistent with our fiduciary duty, it is our policy to correct trade
errors in a manner that is in the best interest of the client. In cases where the client causes the trade
18
Patron Partners, LLC Disclosure Brochure
error, the client will be responsible for any loss resulting from the correction. Depending on the specific
circumstances of the trade error, the client may not be able to receive any gains generated as a result of
the error correction. In all situations where the client does not cause the trade error, the client will be
made whole, and we will absorb any loss resulting from the trade error if the error was caused by the
Firm. If the error is caused by the Custodian, the Custodian will be responsible for covering all trade
error costs. If an investment gain results from the correcting trade, the gain will be donated to charity.
We will never benefit or profit from trade errors.
ITEM 13 - REVIEW OF ACCOUNTS
Account Reviews & Reporting
Managed Accounts Reviews
Patron Partners manages portfolios on a continuous basis and generally review all positions in client
accounts on a regular basis, but no less than annually. We generally offer account reviews to clients
annually. Clients may choose to receive reviews in person, by telephone, or via e-mail. Firm IARs conduct
reviews based on a variety of factors. These factors include, but are not limited to, stated investment
objectives, economic environment, outlook for the securities markets, and the merits of the securities in
the accounts.
In addition, we may conduct a special review of an account based on, but not limited to, the following:
1. A change in the client’s investment objectives, guidelines and/or financial situation.
2. Changes in diversification.
3. Tax considerations; or
4. Material cash deposits or withdrawals.
Third-Party Accounts
Investment Adviser Representatives periodically review third party money managers’ reports provided to
the client, but no less often than on a semi-annual basis. Our Investment Adviser Representatives contact
clients from time to time, as agreed to with the client, in order to review their financial situation and
objectives; communicate information to third party money managers as warranted; and assist the client
in understanding and evaluating the services provided by the third party money manager. The client is
expected to notify us of any changes in his/her financial situation, investment objectives, or account
restrictions that could affect their account. The client may also directly contact the third-party money
manager managing the account or sponsoring the program. Clients who utilize third party money
managers should review the third-party money manager’s Form ADV Part 2 Item 13 – Review of Accounts
regarding account reviews, types of written reports provided and frequency of such reports.
Financial Consultation Service
Financial consultation clients do not receive reviews of their written plans unless they take action to
schedule a financial consultation with us or separately contract with us fora post-financial plan meeting
or update to their initial written financial plan. The type of reporting is agreed upon by Patron Partners
and the client on a case-by-case basis. We do not provide ongoing services to financial consultation clients
19
Patron Partners, LLC Disclosure Brochure
but are willing to meet with such clients upon their request to discuss updates to their plans or changes
in their circumstances. The clients IAR provides the financial consultation services to the client. In cases
when we have been contracted to conduct ongoing financial consultation services, the Investment Adviser
Representatives will conduct reviews as agreed upon with the client.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Brokerage Support Products and Services
We receive an economic benefit from the brokers used for transactions in client accounts in the form of
the support products and services they make available to us and other independent firms whose clients
maintain their accounts at the broker. These products and services, how they benefit us, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices). We do not base particular
investment advice, such as buying particular securities for our clients, on the availability of the brokers’
products and services to us.
Outside Compensation
The Firm may provide compensation to third-party solicitors for client referrals. In the event a client is
introduced to the Firm by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a
referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such
referral fee is paid solely from the Firm’s investment management fee and does not result in any additional
charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the solicitor is
required to provide the client with the Firm’s written brochure(s) and a copy of a solicitor’s disclosure
statement containing the terms and conditions of the solicitation arrangement. Any affiliated solicitor of
the Firm is required to disclose the nature of his or her relationship to prospective clients at the time of
the solicitation and will provide all prospective clients with a copy of the Firm’s written brochure(s) at the
time of the solicitation.
Firm IARs may refer clients to unaffiliated professionals for specific needs, such as mortgage brokerage,
real estate sales, estate planning, legal, and/or tax/accounting. In turn, these professionals may refer
clients to our IARs for investment management needs. We do not have any arrangements with individuals
or companies that we refer clients to, and we do not receive any compensation for these referrals.
However, it could be concluded that our IARs are receiving an indirect economic benefit from this practice,
as the relationships are mutually beneficial. For example, there could be an incentive for us to
recommend services of firms who refer clients to the Firm.
Our IARs only refer clients to professionals we believe are competent and qualified in their field, but it is
ultimately the client’s responsibility to evaluate the provider, and it is solely the client’s decision whether
to engage a recommended firm. Clients are under no obligation to purchase any products or services
through these professionals, and our IARs have no control over the services provided by another firm.
Clients who chose to engage these professionals will sign a separate agreement with the other firm. Fees
charged by the other firm are separate from and in addition to fees charged by the Firm.
If the client desires, our IARs will work with these professionals or the client’s other advisers (such as an
accountant, attorney, or other investment adviser) to help ensure that the provider understands the
20
Patron Partners, LLC Disclosure Brochure
client’s investments and to coordinate services for the client. We do not share information with an
unaffiliated professional unless first authorized by the client.
Third Party Money Manager
Our IARs may work with third party money managers or advisors to service client accounts. They may
receive ongoing compensation in relation to these arrangements, of which details are fully disclosed to
the clients at the time of account opening. See also Item 5 – Third-Party Accounts and Item 10 – Third-
Party Managers.
Other Financial Institutions
Patron Partners has established agreements to provide consulting services to other financial institutions
regarding business development or investment advisory services provided to clients. If the consultation
being provided is specific to services provided to the client account, the specifics of this arrangement,
including the compensation paid to the Firm will be fully disclosed to clients in their signed agreements.
ITEM 15 - CUSTODY
Patron Partners has limited custody of some of our clients’ funds or securities when the clients authorize
us to deduct our management fees directly from the client’s account. A qualified custodian (generally a
broker-dealer, bank, trust company, or other financial institution) holds clients’ funds and securities.
Clients will receive statements directly from their qualified custodian at least quarterly. The statements
will reflect the client’s funds and securities held with the qualified custodian as well as any transactions
that occurred in the account, including the deduction of our fee.
Clients should carefully review the account statements they receive from the qualified custodian. When
clients receive statements from Patron Partners as well as from the qualified custodian, they should
compare these two reports carefully. Clients with any questions about their statements should contact
us at the address or phone number on the cover of this brochure. Clients who do not receive a statement
from their qualified custodian at least quarterly should also notify us.
Third-Party Standing Letters of Authorization (“SLOA”)
Our firm is deemed to have custody of clients’ funds or securities when clients have standing
authorizations with their custodian to move money from a client’s account to a third-party (“SLOA”) and,
under that SLOA, it authorizes us to designate the amount or timing of transfers with the custodian.
The SEC has set forth a set of standards intended to protect client assets in such situations, which we
follow.
By working with the qualified custodian, the Firm has in place seven provisions set forth by the SEC to assist
in mitigating risk. The below must be followed to clients with third-party SLOAs:
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
21
Patron Partners, LLC Disclosure Brochure
2.
3.
4.
5.
6.
7.
account number at a custodian to which the transfer should be directed.
The client authorizes the Firm, 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.
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.
The client can terminate or change the instruction to the client’s qualified custodian.
The Firm 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.
The Firm maintains records showing that the third party is not a related party of Firm or located
at the same address as the Firm.
The client’s qualified custodian sends the client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
As stated earlier in this section, account statements reflecting all activity on the account(s), are delivered
directly from the qualified custodian to each client or the client’s independent representative, at least
quarterly. You should carefully review those statements and are urged to compare the statements against
reports received from us. When you have questions about your account statements, you should contact us,
your Advisor or the qualified custodian preparing the statement.
ITEM 16 - INVESTMENT DISCRETION
Patron Partners accepts discretionary and non-discretionary authority over client accounts. If an IAR is
acting in a discretionary capacity, the IAR may place trades within a client account without pre-approval
from the client. If an IAR is acting in a non-discretionary capacity, the IAR must receive pre-approval from
the client to place trades in the account.
When working with third party managers, we may recommend certain third-party money managers to
clients and then it is up to the client to approve our recommendations. The third-party investment
adviser chosen by the client is responsible for all investment decisions made in the client’s account(s).
Generally, clients who utilize a third-party money manager will sign agreements directly with the third-
party manager. It is important to note that we do not offer advice on any specific securities or other
investments in connection with this service. Clients can find more information about the discretionary
authority granted to third party managers in Item 16 – Investment Discretion of each manager’s Form ADV
disclosure brochure.
ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
In regard to SEC Rule 206(4)-6 under the Advisers Act, Patron Partners accepts or has the authority to vote
client securities on a limited basis where clients have delegated the responsibility of voting proxies to the
Firm in order to utilize a third-party proxy voting service.
22
Patron Partners, LLC Disclosure Brochure
Unless you have delegated this responsibility to us, the Firm will not vote proxies for you. You are
responsible for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned in your Account are voted and voting or causing such proxies to be so voted and (2) making all
elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other similar type
events pertaining to your Assets. Please contact us if you would like to receive a copy of our Proxy Voting
Guidelines.
The Firm has retained a third-party proxy voting service (“Proxy Voting Administrator”) to assist in the
implementation of certain proxy voting-related functions for those clients who have delegated
responsibility to the Firm including: providing research on proxy matters; providing technology to facilitate
the sharing of research and discussions related to proxy votes; voting proxies in accordance with the Firm’s
Proxy Voting Guidelines; handling certain administrative and reporting items; maintaining records of
proxy statements received in connection with proxy votes and provide copies/analyses upon request. The
Firm has established a Proxy Voting Committee (“Proxy Committee”) that is responsible for overseeing
the proxy voting process, addressing any conflicts of interest that may arise and ensuring that the voting
process is implemented in conformance with these policies and procedures.
Clients who have not delegated the responsibility of voting proxies to the Firm may call us if they have questions
about a particular solicitation. We will not be deemed to have proxy voting authority solely as a result
of providing advice or information about a particular proxy vote to a client. Clients will receive their
proxies or other solicitations directly from their custodian or a transfer agent.
In addition, third-party money managers recommended by our firm may vote proxies for clients.
Therefore, except in the event a third-party money manager votes proxies, clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially
owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets.
Therefore (except for proxies that may be voted by a third-party money manager), our firm and/or you
shall instruct your qualified custodian to forward to you copies of all proxies and shareholder
communications relating to your investment assets.
Mutual Funds
The investment adviser that manages the assets of a registered investment company (i.e., mutual fund)
generally votes proxies issued on securities held by the mutual fund.
Class Actions
Patron Partners does not instruct or give advice to clients on whether or not to participate as a member
of class action lawsuits and will not automatically file claims on the client’s behalf. However, if a client
notifies us that they wish to participate in a class action, we will provide the client with any transaction
information pertaining to the client’s account needed for the client to file a proof of claim in a class action.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain financial
information or disclosures about the firm’s financial condition. Patron Partners does not require the
23
Patron Partners, LLC Disclosure Brochure
prepayment of more than $1,200 in fees per client, six months or more in advance, does not have or
foresee any financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients, and has not been the subject of a bankruptcy proceeding.
24
Patron Partners, LLC Disclosure Brochure