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 2024 Page 6 of 23
• 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, 2023, we provided asset management services for 531 accounts, managing total
assets of $448,038,028. Approximately $441,054,034 of the assets we manage are discretionary and
$6,983,994 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 2024 Page 7 of 23
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 2024 Page 8 of 23
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 2024 Page 9 of 23
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 2024 Page 10 of 23
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 according to the tiered fee schedule below. This fee
may be negotiable based upon certain circumstances.
Cresta Advisors, Ltd. ADV Part 2A Appendix 1 March 2024 Page 11 of 23
Assets Advisory Fee
Below $25,000,000 0.15%
$25,000,000 - $50,000,000 0.12%
$50,000,000 - $100,000,000 0.09%
Over $100,000,000 0.06%
*All fees are negotiable.
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.
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.