Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of California and has been in business as an investment adviser since 2015. Our firm is owned
50% by Isidro Z. Miramontes and 50% by Ariana Mangum-Miramontes where both act in the capacity
of Co-Manager with each other for various business purposes.
Our firm sponsors and offers a wrap fee program, which allows clients to pay a single fee for
investment advisory services and associated custodial transaction costs. Transaction fees will be paid
by our firm. Because our firm absorbs client transaction fees, an incentive exists to limit trading
activities in client accounts.
Our recommended custodian, Charles Schwab & Co., Inc. (“Schwab”), does not charge transaction fees
for U.S. listed equities and exchange traded funds. Since we pay the transaction fees charged by the
custodian to clients participating in our wrap fee program, this presents a conflict of interest because
we are incentivized to recommend equities and exchange traded funds over other types of securities
in order to reduce our costs.
Our Wrap Advisory Services
Wrap Comprehensive Portfolio Management:
As part of our Wrap Comprehensive Portfolio Management service clients will be provided asset
management and financial planning or consulting services. This service is designed to assist clients
in meeting their financial goals through the use of a financial plan or consultation. Our firm conducts
client meetings to understand their current financial situation, existing resources, financial goals, and
tolerance for risk. Based on what is learned, an investment approach is presented to the client,
consisting of individual stocks, bonds, ETFs, and mutual funds. Once the appropriate portfolio has
been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced
based upon the client’s individual needs, stated goals and objectives. Upon client request, our firm
provides a summary of observations and recommendations for the planning or consulting aspects of
this service.
Fee Schedule
Account Value Annual Management Fee
First $750,000 1.50%
Additional amount over $750,000 1.15%
For billing purposes, MC bills each account individually. Annualized fees are billed on a pro-rata
basis monthly in arrears based on the value of the account(s) on the last day of the month. Our
firm does not offer direct billing as an option. Further, it is important to note that our firm will
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 Miramontes Capital, LLC
assess advisory fees on cash and cash equivalents held in client accounts. As part of this process,
the client is made aware of the following:
a) The client’s independent custodian sends statements at least quarterly showing the
market values for each security included in the Assets and all account disbursements,
including the amount of the advisory fees paid to our firm;
b) Clients will provide authorization permitting our firm to be directly paid by these terms.
Our firm will send an invoice directly to the custodian; and
c) If our firm sends a copy of our invoice to the client, legend urging the comparison of
information provided in our statement with those from the qualified custodian will be
included.
Other Types of Fees & Expenses:
In addition to our advisory fees above, clients may also pay holdings charges imposed by the chosen
custodian for certain investments, charges imposed directly by a mutual fund, index fund, or
exchange traded fund, which shall be disclosed in the fund’s prospectus (i.e., fund management fees,
initial or deferred sales charges, mutual fund sales loads, surrender charges, variable annuity fees,
IRA and qualified retirement plan fees, and other fund expenses), mark-ups and mark-downs,
spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and
other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a
portion of these fees.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis,
Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. Our firm provides
clients with a summary of their financial situation, and observations for financial planning
engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming
that all the information and documents requested from the client are provided promptly, plans or
consultations are typically completed within six (6) months of the client signing a contract with our
firm.
The client is under no obligation to act upon the investment adviser’s recommendation. If the client
elects to act on our recommendations, the client is under no obligation to effect the transaction
through us.
Our firm charges on an hourly or flat fee basis for financial planning and consulting services. The total
estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our
ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 Miramontes Capital, LLC
engagement with the client. The maximum hourly fee to be charged will not exceed $500. Flat fees
range up to $15,000. Our firm requires a retainer of fifty-percent (50%) of the ultimate financial
planning or consulting fee at the time of signing. The remainder of the fee will be directly billed to
the client and due within thirty (30) days of a financial plan being delivered or consultation rendered.
Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6
(six) months.
Termination & Refunds
Either party may terminate the advisory agreement signed with our firm for Comprehensive
Portfolio Management services in writing at any time. Upon notice of termination our firm will
process a pro-rata refund of the unearned portion of the advisory fees charged in advance at the
beginning of the quarter.
Financial Planning & Consulting clients may terminate their agreement at any time before the
delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work
performed by us up to the point of termination shall be calculated at the hourly fee currently in effect.
Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our
firm.
Commissionable Securities Sales
Representatives of our firm are registered representatives of Balanced Security Planning, Inc. an
affiliated broker dealer, as well as American Trust Investment Services, Inc. members FINRA/SIPC.
As such they are able to accept compensation for the sale of securities or other investment products,
including distribution or service (“trail”) fees from the sale of mutual funds. Clients should be aware
that the practice of accepting commissions for the sale of securities presents a conflict of interest and
gives our firm and/or our representatives an incentive to recommend investment products based on
the compensation received. Our firm generally addresses commissionable sales conflicts that arise
when explaining to clients these sales create an incentive to recommend based on the compensation
to be earned and/or when recommending commissionable mutual funds, explaining that “no-load”
funds are also available. Our firm does not prohibit clients from purchasing recommended
investment products through other unaffiliated broker dealers, brokers or agents.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Comprehensive Portfolio Management
clients. General investment advice will be offered to our Financial Planning & Consulting and
Retirement Plan Consulting clients.
Each Comprehensive Portfolio Management client has the opportunity to place reasonable restrictions
on the types of investments to be held in the portfolio. Restrictions on investments in certain securities
or types of securities may not be possible due to the level of difficulty this would entail in managing
the account.
Wrap Fee Program Recommendations
Our firm only offers our Comprehensive Portfolio Management service on a Wrap Fee basis. We do
not recommend or offer the wrap program services of other providers.
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Regulatory Assets under Management
As of December 31, 2022, our firm manages $166,948,815 on a non-discretionary basis and
$13,056,874 on a discretionary basis for a total of $180,005,689 in Assets Under Management.