A. Introduction:
Anderson Growth Partners, LLC (“AGP”), an Alabama limited liability company, was formed
by Clyde B. Anderson in 1998 to serve as the manager of a series of separate investment funds
and co-investment vehicles structured as limited partnerships (each, an “Anderson Entity”).
These Anderson Entities were formed to facilitate pooled investments by members of the
Anderson family, their friends and business partners in (a) relatively liquid funds such as hedge
funds that generally hold public equities as investments (collectively, “Hedge Funds”), (b)
relatively illiquid funds such as private equity funds (collectively, “Private Equity Funds”) and c)
relatively illiquid funds invested directly in specific portfolio companies (collectively, “Direct
Investments”). The Hedge Funds, Private Equity Funds and Direct Investments collectively are
referred to as “Anderson Entity” or “Anderson Entities” in this Disclosure Brochure. Mr.
Anderson serves as the Managing Member and is the majority owner of AGP. There are no other
owners who own more than 10% of the company.
B. Advisory Services:
AGP provides investment supervisory services, defined as giving continuous advice to a client or
making investments for a client based on the individual needs of each client, i.e., each Anderson
Entity. On a regular basis, AGP meets with various investment firms, private companies and
individuals who are promoting investments in Hedge Funds, Private Equity Funds and Direct
Investments. AGP makes a determination as to which of these proposed investments might be
suitable for the various members of the Anderson family, their friends and business partners
(collectively, “Potential Investors”), and then meets individually to establish a pre-existing
relationship with the Potential Investors all of whom AGP has determined are sophisticated
accredited and qualified investors. The decision as to which Anderson Entity to invest in is an
individual decision made by pre-qualified Potential Investors.
If Potential Investors approve investing in one of the Anderson Entities, and are willing to
collectively commit enough capital to meet any applicable minimum investment requirements,
then AGP forms an Anderson Entity to make and hold the investment. Once the Anderson Entity
is formed, then AGP manages the portfolio of investments in the Anderson Entity on a
discretionary basis by sourcing investments in accordance with the investment mandates
described in the offering memorandum.
In 2023, AGP added a division named Anderson Wealth Management (AWM), which provides
wealth management services to clients. The services offered include advisory services of the
client’s portfolio of investment securities, financial planning, tax and estate planning and
reporting to retail investors. Each client
of AWM has a separate investment management account
(“SMA”) agreement with AWM to provide these wealth management services to the client.
AWM also develops an Investment Policy Statement (IPS) in consultation with each client when
they open their account. The IPS outlines the client’s financial situation, investment goals and
objectives which is used by AWM to select appropriate portfolio investments for each client.
SMA clients may impose reasonable account investment restrictions on their account that are
reassessed annually during a review of their account and IPS to determine if there have been any
changes. AWM monitors each client’s portfolio of investments over the course of the
relationship based on their IPS on an ongoing basis as part of our standard advisory service.
AWM’s advisory services are provided on a discretionary basis, which means AWM can buy
and sell investments in each client’s account without the client’s pre-approval for each
transaction. Each client signs an SMA agreement giving AWM that authority. Also, each client
authorizes that AWM may select, retain or discontinue use of an (discretionary or non-
discretionary) independent third-party investment sub-Advisor (“Independent Manager”), subject
to AGP supervisory oversight.
AWM advisory services can include recommendations to rollover client’s or prospective client’s
retirement plans, such as a defined benefit plan, defined contribution plans, health savings plans,
educational savings plans and individual retirement accounts (“IRA”), into another retirement
account or IRA, managed by AGP where we earn a fee. When we make rollover
recommendations to manage a retirement account, we are a fiduciary under Title I of the
Employee Retirement Income Security Act (“ERISA”) and the Internal Revenue Code (“IRC”),
which governs retirement accounts. As such, we operate under a special standard of care to
provide prudent advice requiring us to act in your best interest and not put our interests ahead of
yours, charge no more than a “reasonable fee”, as defined under ERISA, and not make any false
or misleading statements. We are required to give you basic information about our conflicts of
interests, such as when we make rollover recommendations this allows us to earn an additional
fee that is in our interest and disclose other conflicts of interest in the way we make money, as
more fully described in under Item 10 of this Brochure.
C. Client assets under management
As of December 31, 2023, AGP managed client assets totaling approximately $843,258,236. The
client’s assets are invested in a total of forty-one separate Public Funds, Private Funds and Direct
Investments totaling $820,252,211 and SMA accounts totaling $23,006,025All of the client
assets are managed on a discretionary basis by AGP.