Description of Firm Brazos Capital, LLC d/b/a Brazos Capital is a registered investment adviser primarily based in Austin, Texas. We are organized as a limited liability company ("LLC") under the laws of the State of Texas. We have been providing investment advisory services since 2017. We are owned by Richard A. Funk.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to Brazos Capital and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
Portfolio Management Services We offer discretionary and non-discretionary portfolio management services generally exercised within the auspices of the below described programs. Irrespective of the program(s) selected, when you engage for portfolio management services, we will consult with you to discuss your financial circumstances and objectives and to assist you in determining (a) an appropriate set of financial goals, (b) a time horizon for your investments, and (c) your level of risk tolerance. Based on our evaluation of your financial situation, we will provide you with recommendations as to which of the below investment programs is most appropriate for management of your assets and as to which particular investments, asset allocation models, and/or underlying third party managed investment programs is suited for your unique investment profile. Our investment advice is tailored to meet our clients' needs and investment objectives.
Discretionary Account Management: Where you engage us on a discretionary basis, your advisory agreement with our firm shall authorize us to exercise discretionary authority over your account. By granting discretionary authority, you authorize our firm to implement our investment recommendations directly within your account, including the right to determine (1) which securities to buy and sell for your account; (2) when to buy and sell securities for your account; (3) the amount of securities to buy and sell for your account; and (4) the third party managers to be engaged for management of your assets; all without obtaining your prior consent or approval for each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm. Non-discretionary Account Management: Where you engage us on a non-discretionary basis, we must obtain your approval prior to executing any transactions in your account. You have an unrestricted right to decline to implement any advice or recommendations that are provided by our firm to you on a non-discretionary basis. Separately Managed Account Programs ("SMAs" or "SMA Programs"): In general, these accounts offer our clients the opportunity to select professional third party money managers ("TPMMs") to individually manage or provide portfolio recommendations to their account(s). The TPMMs made available through the below SMA Programs may include Raymond James & Associates, Inc., member New York Stock Exchange/SIPC ("RJA") and other third party investment management firms. Except where otherwise stated, the TPMMs made available through the SMA Programs set forth below are permitted on the platform based on RJA's familiarity with the TPMM and its underlying portfolio management personnel, the investment disciplines offered, portfolio construction and the overall belief that the participation of these TPMMs in the program will provide prospective clients access to high quality investment management firms.
Once selected, the TPMM(s) will invest the client's assets, typically on a discretionary basis, in accordance with their stated investment discipline(s) and strategy(ies) and without soliciting the client's consent prior to engaging in portfolio transactions. You will have the ability to impose 4 reasonable restrictions on the investments made in your SMA account, contribute or withdraw securities and/or cash from your SMA account, and/or to request the sale of individual securities for tax planning purposes (also called "tax harvesting") within your SMA account. Our role in connection with SMAs is to consult with you and select and adjust (or assist you in selecting and adjusting) the particular TPMM(s) to be engaged for management of the assets within your SMA account. In summary, these accounts are intended to provide our clients with flexibility in developing a customized portfolio diversified across multiple investment disciplines or one which is targeted to an individual or more concentrated investment discipline through the use of a diverse set of available TPMMs. A description of each SMA program account available through our firm is listed below. Please see the respective RJA Brochure for additional details concerning these programs.
Held Away Accounts: We use a platform provided by Pontera to manage held away assets such as defined contribution plan participant accounts, with discretion. The Pontera platform allows us to avoid being considered to have custody of Client funds since we do not have direct access to or direct use of Client log-in credentials to affect trades. We are not affiliated with Pontera in any way and receive no compensation from Pontera for using their platform. For certain 401k accounts, plan participants can authorize us to place trades using Pontera. Those clients who do not provide us with such authorization must place any trades in the 401k accounts themselves through their plan provider.
When deemed necessary, we will rebalance the account, taking into consideration client investment goals and risk tolerance, and any change in allocations.
Asset Allocation Services We offer asset allocation services that are tailored to meet our clients' needs and investment objectives. Once you have retained our firm for asset allocation services, we will gather information about your financial situation and objectives, and assist you in determining your investment goals, objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with recommendations as to how to allocate your investments among categories of assets. We will then review your account on a periodic basis. Where appropriate, we may provide you with recommendations to change your asset allocation in an effort to remain consistent with your stated financial objectives. You are free at all times to accept or reject any of our investment recommendations. You are solely responsible for implementing our recommendations. Unless you separately retain our services, we will not execute any transactions or changes in asset allocation on your behalf.
Financial Planning Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based

financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
5 You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Financial Consulting Services We offer financial consulting services that primarily involve advising clients on specific financial-related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation.
Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") such as Alkeon Capital Management, LLC, to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action appropriate.
Recommendation of Private Fund For certain qualified clients, Brazos Capital may recommend a subscription with Richmont Capital Partners VII, L.P. ("RCPVII" or "Rally"). The Rochon Family Office is the sponsor of RCPVII and the General Partner is the Rochon Trust, LLC. RCPVII is a treasury management alternative for short term fluctuating cash balance management. Rally is a proprietary artificial intelligence and machine learning algorithm that executes trades of highly liquid securities, mainly pairs currencies transactions. The objective of the Fund is preservation of capital. Most of the trading is executed through Praxis Digital Trading Group LLC (CR-2232) ("Praxis") which is registered as an Exempt Market-Maker and Registered Person with Cayman Islands Monetary Authority, (CIMA).
Brazos Capital is not affiliated in any way with the RCPVII, the Rochon Family Office, the Rochon Trust, LLC, or the third-party software provider and does not receive any commissions or compensation for referring clients to RCPVII. Brazos Capital may sometimes participate in performance fee sharing with Rally. Family Office and Wealth Planning Services We offer Family Office and Wealth Planning Services designed to help our clients organize their financial situation and plan for the successful transfer of wealth to the next generation in the most tax- advantaged manner. Such services generally include financial planning in the following areas:
•Private Portfolio Management
•Customized Lending Solutions and Private Banking Services
•Oversight and Management of Outside Assets and Investments
•Family Continuity
•Estate Planning and Trustee Oversight
•Integrated Tax and Financial Planning
•Lifestyle Management 6
•Family Philanthropy
•Risk Management
•Bill Paying Wrap Fee Program(s) We do not recommend any wrap fee programs. Types of Investments We offer advice on equity securities, corporate debt securities (other than commercial paper), municipal securities, REITs, mutual funds and ETFs, venture capital and private equity funds, and interests in partnerships including, but not limited to, those investing in real estate.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice to, because the assets increase our Assets Under Management and, in turn, our advisory fees. In contrast, we receive less, or no, compensation if assets remain in the current plan or are rolled over to another Company's plan in which you may participate.
Assets Under Management As of December 31, 2023, we manage approximately $126,166,685 in client assets on a discretionary basis. 7