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Part 2A of Form ADV: Firm Brochure
Alamo Advisors, LP
4114 Pond Hill
Suite 201
San Antonio, TX 78231
Telephone: (210) 404-2211
Fax: (210) 490-0331
March 14, 2025
This brochure provides information about the qualifications and business
practices of Alamo Advisors, LP. If you have any questions about the contents
of this brochure, please contact us at (210) 404-2211. The information in this
brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority.
Additional information about Alamo Advisors, LP also is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is
122290.
Registration with state regulatory authorities does not imply any level of skill or
training.
Item 2 Material Changes
We have the following material changes to report since the last annual update of this
brochure on 02/12/2024:
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Item 5 was updated to clarify our firm’s billing practices and frequency and how our
advisory fee is calculated. In addition, we have clarified our firm’s payment options for
direct debiting of advisory fees from client accounts and related accounts. We have
also disclosed our practices with respect to recommending investments, including
shares of mutual funds.
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Item 8 was updated to disclose that we do not encourage the use of margin by clients;
however, clients may choose to use margin at their own discretion at their qualified
custodian.
•
Item 12 was updated to disclose our procedures regarding reviewing third-party
managers’ trading practices to determine if they are striving to achieve best execution.
Also, we have expanded upon our directed brokerage arrangements with clients as
well as disclosed additional trading fees by RBC and the conflict of interest that
creates for our firm when we receive research or other ancillary services from RBC.
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Item 3 Table of Contents
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Cover Page
Investment Discretion
Item 1
Item 2 Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance‐Based Fees and Side‐By‐Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16
Item 17 Voting Client Securities
Item 18 Financial Information
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Brochure Supplement: Robert N. Johnson
Brochure Supplement: Daniel W. Peterson
Brochure Supplement: John J. Rizzo, Jr.
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Item 4 Advisory Business
Alamo Advisors, LP (“Alamo” or the “Firm”) is an SEC-registered investment adviser with its
principal place of business located in Texas. Alamo began conducting business in 2002.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities
controlling 25% or more of this company).
Robert Norman Johnson, Partner
Alamo offers the following advisory services to our clients:
INVESTMENT ADVISORY SERVICE
We offer advisory management services to our clients through our selection and monitoring of
third-party money managers programs.
Our firm provides the client with an asset allocation strategy developed through personal
discussions in which goals and objectives based on the client's particular circumstances are
established. This asset allocation strategy is drafted into the client's Investment Policy
Statement ("IPS").
Based on the client's individual circumstances and needs (as exhibited in the client's IPS) we
will then perform management searches of various unaffiliated registered investment advisers
to identify which registered investment adviser's portfolio management style is appropriate for
that client. Factors considered in making this determination include account size, risk
tolerance, the opinion of each client and the investment philosophy of the selected registered
investment adviser. Clients should refer to the selected registered investment adviser's Firm
Brochure or other disclosure document for a full description of the services offered. We are
available to meet with clients on a regular basis, or as determined by the client, to review the
account.
We monitor the performance of the selected registered investment adviser(s). If we determine
that a particular selected registered investment adviser(s) is not providing sufficient
management services to the client, or is not managing the client's portfolio in a manner
consistent with the client's IPS, we may suggest that the client contract with a different
registered investment adviser and/or program sponsor. Under this scenario, our firm assists the
client in selecting a new registered investment adviser and/or program. However, any move to
a new registered investment adviser and/or program is solely at the discretion of the client.
On a limited basis, our firm also provides non-continuous investment advisory services of client
funds based on the individual needs of the client. Through personal discussions in which
goals and objectives based on the client's particular circumstances are established, we develop
the client's personal investment policy. We create and manage a portfolio based on that policy.
During our data-gathering process, we determine the client’s individual objectives, time
horizons, risk tolerance, and liquidity needs. As appropriate, we may also review and discuss a
client’s prior investment history, as well as family composition and background.
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We oversee these advisory accounts on a non-discretionary basis. Account supervision is
guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income,
or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities,
or industry sectors.
Once the client's portfolio has been established, we review the portfolio quarterly and make
periodic recommendations to the client to rebalance the portfolio, based on the client's individual
needs.
Our investment recommendations are not limited to any specific product or service offered by
a broker-dealer or insurance company and will generally include advice regarding the
following securities:
Corporate debt securities (other than commercial paper)
Commercial paper
Certificates of deposit
Municipal securities
Mutual fund shares
United States governmental securities
Interests in partnerships investing in real estate
Interests in partnerships investing in oil and gas interests
Interests in partnerships investing in private equity arrangements
Because some types of investments involve certain additional degrees of risk, they will only
be recommended when consistent with the client's stated investment objectives, tolerance for
risk, liquidity and suitability.
ASSETS UNDER MANAGEMENT
As of December 31, 2024, we were managing $3,782,699,738 of client assets on a non-
discretionary basis. We do not manage client assets on a discretionary basis.
Item 5 Fees and Compensation
INVESTMENT ADVISORY SERVICE FEES
Alamo's fee for this service does not include the independent investment adviser's fee for that
entity's advisory/management services. The independent investment adviser's management
fee is disclosed in the independent investment adviser's Firm Brochure or other disclosure
document.
Our annual fee for our Investment Advisory Service is charged as a percentage of assets
under management, according to the following schedule:
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Assets Under Management
First $1,000,000 of assets
Next $2,000,000 of assets
Next $2,000,000 of assets
Next $5,000,000 of assets
Next $5,000,000 of assets
Additional assets over $15,000,000
Annual Fee
1.00%
0.75%
0.50%
0.35%
0.25%
0.20%
A minimum account size of $5,000,000 is required for Alamo’s advisory services. This
account size may be negotiable under certain circumstances. Alamo may group certain
related client accounts for the purpose of achieving the minimum account size and
determining the annualized fee.
Alamo’s advisory fees are billed in advance each quarter. The standard fee schedule above,
or if applicable a fee schedule different than above, shall be applied to a client’s account values
based on the particular calendar quarter end date. The fee is then divided by four and applied
evenly at a rate of ¼ (25%) for each calendar quarter.
The fee billing process relies on the use of Microsoft Excel to calculate the correct amount of
the quarterly fee for each client, and Microsoft Excel is also used to then generate the invoice
that is sent to the respective client.
The Firm will review the client’s particular fee arrangement as shown in the client’s fee
agreement. The client’s fee schedule will then be applied to the Microsoft Excel worksheet for
that particular client. Each quarter, the Firm will review each client’s fee arrangement to
confirm if there have been any changes in the particular client’s fee schedule. If there has
been a change in a client’s fee arrangement, as noted in updated fee agreement with the
client, then this updated fee schedule will be used for the next quarterly fee calculation. To
prevent errors, every calendar quarter at least two people from the Firm will review the client’s
fee agreement and the Microsoft Excel spreadsheet to confirm that the fees being used match
from the two sources.
The values used to calculate the fees will be the value as determined by the client’s custodian
as of each calendar quarter end statement.
For accounts that hold fixed income securities, the value of the accrued interest income will
be included in the client’s account value.
For accounts that hold private offerings, in many cases the current value of a private offering
will not be made available in a timely manner. For example, as of the end of calendar quarter
March 31, 2024, the most recent fair market value statement for a private offering may only be
September 30, 2023, or December 31, 2023. In these situations, the most readily available
quarter-end fair market value statement for such private offering will be used for purposes of
the Firm’s billing.
There are no adjustments made for fee purposes for deposits or withdrawals during each
calendar quarter.
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In each client agreement, the Firm has the right to begin charging pro-rated fees for the first
calendar quarter during which a client’s assets are received in a custodial account under the
oversight of the Firm. However, in practice, the Firm generally refrains from preparing a pro-
rated fee calculation for this first quarter that it oversees a client’s assets, and instead begins
to bill for the first calendar-end for which a client’s assets are held in accounts under the
oversight of the Firm.
The firm stops charging fees for the last full quarter that it provides investment advisory
services to a client.
Periodically, the Firm will consider various family related accounts together for purposes of
calculating and applying fee schedules to each client that allows for all family members the
ability to receive a discount to the Firm’s standard fee schedule. In this case, the fees are
calculated by adding the combined value of all family accounts, and then applying this value
to the Firm’s standard fee schedule. Once this calculation has been done, a pro-rated
calculation is done whereby each client’s account values are used to determine that client’s
share of the total fees that are owed.
In certain circumstances, the Firm will allow a client to use a cross-billing arrangement
whereby a client’s fees are deducted by an account in a different client name. In all cases,
the accounts are part of a family group of related accounts. This structure is primarily utilized
for tax planning reasons with certain clients.
The Firm will allow its fees to be debited from a client’s margin account only when the margin
has been previously approved by the client.
The Firm’s investment advisory service fees are billed in advance of each calendar quarter.
The Firm will prepare a new client fee agreement each time there is a change in the client’s
fee arrangement. This generally happens when a client’s fee is reduced due to the combining
of related family accounts for combined fee calculation purposes.
The Firm does not make any recommendations to clients with regard to non-managed assets
that are held in a client’s account. The Firm does not provide any investment advice on these
assets, nor does the Firm bill on such assets. The decision to buy, hold, or sell these assets
must be made by the client based on research that the client has performed on their own.
GENERAL INFORMATION
Fee Adjustments. In some instances, Alamo may provide clients with additional non-
advisory services, including tax preparation services. These services may be provided for a
single, combined fee including advisory and non-advisory services. To the extent that non-
advisory services are provided for a combined fee, Alamo will negotiate with the client an
adjustment to the standard fee schedule described above to reflect the additional services.
Certain services, such as one-time tax preparation, may be provided without a fee adjustment.
Limited Negotiability of Advisory Fees: Although Alamo has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a
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client-by-client basis. Client facts, circumstances and needs are considered in determining
the fee schedule. These include the complexity of the client, assets to be placed under
management, anticipated future additional assets; related accounts; portfolio style, account
composition, reports, among other factors. The specific annual fee schedule is identified in
the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum
account size requirements and determining the annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family members
and friends of associated persons of our firm.
Termination of the Advisory Relationship: A client agreement may be canceled at any
time, by either party, for any reason upon receipt of 30 days written notice. As disclosed above,
certain fees are paid in advance of services provided. Upon termination of any account,
any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement
of fees, we will pro rate the reimbursement according to the number of days remaining in the
billing period. A client also has the right to terminate an agreement without penalty within five
(5) business days after entering into the agreement.
Mutual Fund Fees: All fees paid to Alamo for investment advisory services are separate and
distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders.
These fees and expenses are described in each fund's prospectus. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest
in a mutual fund directly, without our services. In that case, the client would not receive the
services provided by our firm which are designed, among other things, to assist the client
in determining which mutual fund or funds are most appropriate to each client's financial
condition and objectives. Accordingly, the client should review both the fees charged by the
funds and our fees to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the advisory services being provided.
As a matter of policy and as a fiduciary to our clients, The Firm acts in the best interests of
clients when recommending investments, including shares of mutual funds. Absent
compelling reasons to the contrary and in keeping with each client’s best interests, The Firm
will generally seek to recommend the lowest overall cost share class of mutual funds
available to clients under the circumstances and to disclose all conflicts of interest arising in
the selection of mutual fund share classes.
The overall lowest cost share class of a mutual fund available to clients may sometimes include
a trade fee, currently $15, by the client’s custodian, primarily RBC Capital Markets. Although the
Firm does not receive any 12b-1 fees from any mutual funds, the imposition of a trade fee by the
client’s custodian could be viewed as conflict of interest by the Firm, since the client’s custodian
could provide research or other ancillary services to the Firm. The Firm confirms that it never
takes into account any services received by the client’s custodian in recommending a particular
mutual fund. All mutual fund recommendations are made based solely on the best interests of
the client, taking into account historical fund performance, correlation with other funds that are, or
will be in, the client’s portfolio, and direct fund expense ratios.
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Wrap Fee Programs and Separately Managed Account Fees: Clients participating in
separately managed account programs may be charged various program fees in addition to the
advisory fee charged by our firm. Such fees may include the investment advisory fees of the
independent advisers, which may be charged as part of a wrap fee arrangement. In a wrap
fee arrangement, clients pay a single fee for advisory, brokerage and custodial services. Client’s
portfolio transactions may be executed without commission charge in a wrap fee arrangement.
In evaluating such an arrangement, the client should also consider that, depending upon the
level of the wrap fee charged by the broker -dealer, the amount of portfolio activity in the
client’s account, and other factors, the wrap fee may or may not exceed the aggregate
cost of such services if they were to be provided separately. We will review with clients any
separate program fees that may be charged to clients.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible
for the fees and expenses charged by custodians and imposed by broker dealers, including,
but not limited to, any transaction charges imposed by a broker dealer with which an
independent investment manager effects transactions for the client's account(s). Please refer
to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are
subject to Alamo's minimum account requirements and advisory fees in effect at the time the
client entered into the advisory relationship. Therefore, our firm's minimum account
requirements will differ among clients.
ERISA Accounts: Alamo is deemed to be a fiduciary to advisory clients that are employee
benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement
Income Security Act ("ERISA"), and regulations under the Internal Revenue Code of
1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations
under ERISA and the Internal Revenue Code that include among other things, restrictions
concerning certain forms of compensation. To avoid engaging in prohibited transactions,
Alamo may only charge fees for investment advice about products for which our firm and/or our
related persons do not receive any commissions or 12b-1 fees, or conversely, investment
advice about products for which our firm and/or our related persons receive commissions or
12b-1 fees, however, only when such fees are used to offset Alamo's advisory fees.
Advisory Fees in General: Clients should note that similar advisory services may (or may
not) be available from other registered (or unregistered) investment advisers for similar or lower
fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of
fees in excess of $1,200 more than six months in advance of services rendered.
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Item 6 Performance‐Based Fees and Side‐By‐Side Management
Alamo does not charge performance-based fees.
Item 7 Types of Clients
Alamo provides advisory services to the following types of clients:
High net worth individuals
Charitable organizations
As previously disclosed in Item 5, our firm has established certain minimum account
requirements, based on the nature of the service(s) being provided. For a more detailed
understanding of those requirements, please review the disclosures provided in each applicable
service.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager
of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an
ability to invest over a period of time and in different economic conditions. We also look at the
underlying assets in a mutual fund or ETF in an attempt to determine if there is significant
overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also
monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated
investment strategy. For some fund screening, Alamo receives services from RogersCasey
(“RC”) and other due diligence service providers. RC and these service providers produce,
through its own due diligence, approved lists of funds and managers, which it provides to
Alamo. Alamo will also conduct its own due diligence of funds and managers.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not
be able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund or ETF, managers of different funds held by the client may purchase
the same security, increasing the risk to the client if that security were to fall in value. There is
also a risk that a manager may deviate from the stated investment mandate or strategy of the
fund or ETF, which could make the holding(s) less suitable for the client’s portfolio.
Third-Party Money Manager Analysis. We examine the experience, expertise, investment
philosophies, and past performance of independent third-party investment managers in an
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attempt to determine if that manager has demonstrated an ability to invest over a period of
time and in different economic conditions. We monitor the manager’s underlying holdings,
strategies, concentrations and leverage as part of our overall periodic risk assessment.
Additionally, as part of our due-diligence process, we survey the manager’s compliance and
business enterprise risks. For some third-party manager screening, Alamo receives services
from RC and other due diligence service providers. RC and these service providers produce,
through its own due diligence, approved lists of funds and managers, which it provides to
Alamo. Alamo will also conduct its own due diligence of funds and managers.
A risk of investing with a third-party manager who has been successful in the past is that he/she
may not be able to replicate that success in the future. In addition, as we do not control
the underlying investments in a third-party manager’s portfolio, there is also a risk that a
manager may deviate from the stated investment mandate or strategy of the portfolio, making
it a less suitable investment for our clients. Moreover, as we do not control the manager’s daily
business and compliance operations, we may be unaware of the lack of internal controls
necessary to prevent business, regulatory or reputational deficiencies.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that
the companies whose securities we purchase and sell, the rating agencies that review these
securities, and other publicly-available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies)
are appropriate to the needs of the client and consistent with the client's investment objectives,
risk tolerance, and time horizons, among other considerations:
Long-term purchases. We recommend the purchase of securities with the idea that the
client will hold them in the client's account for a year or longer. Typically we recommend this
strategy so that a client may gain exposure to a particular asset class over time, regardless of
the current projection for this class.
Margin. The Firm does not encourage the use of margin by clients. Clients may choose
however, at their own discretion, to use margin at their qualified custodian firm for short term
borrowing purposes, as opposed to obtaining traditional third party bank lending.
The Firm does not believe that it has a conflict of interest when a client chooses to use
margin for short term borrowing purposes since the negative margin value will reduce the
value of the client’s assets that are subject to an investment advisory fee by the Firm, just as
the value would be reduced if the client were to sell securities and take a distribution from
their account for the same value. However, if there is a perceived conflict of interest, as
stated above, the Firm does not encourage the use of margin by clients, so any decision to
use margin will be made solely by the client.
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Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
In addition to the investment advisory services described in Item 4 of this Brochure, Alamo
provides accounting and tax preparation services for a separate and distinct fee.
recommendations. The
These non-advisory activities present a potential conflict of interest, to the extent that Alamo’s
principals and employees may receive additional compensation as a result of recommending
additional accounting, tax preparation and consulting services to advisory clients. Certain
management personnel and employees of Alamo are licensed and practicing Certified Public
Accountants and provide the above-mentioned accounting and tax preparation services.
Clients, however, are not under any obligation to engage these individuals when considering
implementation of any or all
implementation of advisory
recommendations is solely at the discretion of the client. While Alamo and these individuals
endeavor at all times to put the interest of the clients first as part of our fiduciary duty, clients
should be aware that the receipt of additional compensation itself creates a conflict of interest,
and may affect the judgment of these individuals when making recommendations. Alamo
takes the following steps to address this conflict:
• we disclose to clients the existence of all material conflicts of interest, including
the potential for our firm and our employees to earn compensation from advisory
clients in addition to our firm's advisory fees;
• we disclose to clients that they are not obligated to utilize the consulting services
from our employees or affiliated companies;
• we collect, maintain and document accurate, complete and relevant client
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background
information, including the client’s financial goals, objectives and risk
tolerance;
• our firm's management conducts regular reviews of each client account to verify
that all recommendations made to a client are suitable to the client’s
needs and circumstances;
• we require that our employees seek prior approval of any outside employment
activity so that we may ensure that any conflicts of interests in such activities are
properly addressed;
• we periodically monitor these outside employment activities to verify that any
conflicts of interest continue to be properly addressed by our firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including
the need for having a reasonable and independent basis for the investment
advice provided to clients.
Daniel W. Peterson, a member of our firm's management, is also an attorney licensed to
practice law in the state of Texas. However, he does not currently provide direct legal
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services to any client in that capacity and will not act in this capacity for any advisory client of
Alamo.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Our firm has adopted a Code of conduct that we require of our securities laws.
Ethics which sets forth high ethical standards of business employees, including compliance
with applicable federal
Alamo and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and
have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the
general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as initial and annual securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics also requires
the prior approval of any acquisition of securities in a limited offering (e.g., private placement)
or an initial public offering. Our code also provides for oversight, enforcement and
recordkeeping provisions.
Alamo's Code of Ethics further includes the firm's policy prohibiting the use of material non-
public information. While we do not believe that we have any particular access to non-public
information, all employees are reminded that such information may not be used in a personal
or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You
may request a copy by email sent to danp@alamoadvisors.com, or by calling us at (210) 404-
2211.
Alamo and individuals associated with our firm are prohibited from engaging in principal
transactions. Alamo and individuals associated with our firm are also prohibited from
engaging in agency cross transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities
and interests of our employees will not interfere with (i) making decisions in the best interest
of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal
accounts securities identical to or different from those recommended to our clients. In
addition, any related person(s) may have an interest or position in a certain security(ies)
which may also be recommended to a client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any
security prior to a transaction(s) being implemented for an advisory account, thereby preventing
such employee(s) from benefiting from transactions placed on behalf of advisory accounts.
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We may aggregate our employee trades with client transactions where possible and when
compliant with our duty to seek best execution for our clients. In these instances, participating
clients will receive an average share price and transaction costs will be shared equally and on
a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we
will allocate all purchases pro-rata, with each account paying the average price. Our
employee accounts will be excluded in the pro-rata allocation.
As these situations represent actual or potential conflicts of interest to our clients, we have
established the following policies and procedures for implementing our firm’s Code of Ethics,
to ensure our firm complies with its regulatory obligations and provides our clients and potential
clients with full and fair disclosure of such conflicts of interest:
1. No principal or employee of our firm may put his or her own interest above the interest
of an advisory client.
2. No principal or employee of our firm may buy or sell securities for their personal
portfolio(s) where their decision is a result of information received as a result of his or
her employment unless the information is also available to the investing public.
3. It is the expressed policy of our firm that no person employed by us may purchase or sell
any security prior to a transaction(s) being implemented for an advisory account. This
prevents such employees from benefiting from transactions placed on behalf of
advisory accounts.
4. Our firm requires prior approval for any IPO or private placement investments by
related persons of the firm.
5. We have established procedures for the maintenance of all required books and
records.
6. Clients can decline to implement any advice rendered.
7. All of our principals and employees must act in accordance with all applicable Federal
and State regulations governing registered investment advisory practices.
8. We require delivery and acknowledgement of the Code of Ethics by each supervised
person of our firm.
9. We have established policies requiring the reporting of Code of Ethics violations to our
senior management.
10. Any individual who violates any of the above restrictions may be subject to termination.
Item 12 Brokerage Practices
Alamo does not have discretionary authority to select broker dealers on behalf of advisory
clients. However, Alamo introduces investment advisory clients to RBC Advisor Services, a
division of RBC Capital Markets, LLC (collectively "RBC"), member NYSE/FINRA/SIPC and
recommends that clients open brokerage accounts with RBC. In recommending RBC, Alamo
considers (1) its reputation or skill in providing best execution of customer orders, operational
efficiency and reliability, and reputation for integrity and efficiency; (2) the reasonableness of
the levels of commissions, fees and other charges imposed for its services; (3) its ability and
willingness to conform to certain operating and other conditions necessary for providing
services to advisory clients; and (4) the quality of any products, research or services received
by Alamo from RBC.
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Through RBC, clients may buy and sell mutual funds and maintain prime brokerage accounts
through which selected investment managers may trade securities on a client's behalf. While
Alamo recommends that all third-party managers who have brokerage discretion are
expected to achieve best execution, a d v i s o r y clients should review the disclosure
documents of t h e s e recommended investment managers regarding the brokerage
practices of such managers. To determine that these third-party managers are striving to
achieve best-execution, Alamo will periodically review the trading activity of these third-party
managers to determine if they are trading with, or away from, RBC, and also ask the manager
to provide reports of the average commissions that they are being charged to the clients’
trades. If the commission rate being charged to a client’s account is greater than could be
achieved by trading with RBC, then the third-party manager will be asked to provide additional
explanation for their trading away (from RBC) policy.
Alamo's recommendation of RBC also takes into consideration Alamo's use of RBC for
support services. In conjunction with RBC, a brokerage fee schedule has been negotiated on
behalf of clients that Alamo believes is favorable to clients. The fee schedule will be disclosed
to advisory clients prior to opening any RBC account and entering into agreements regarding
such accounts. Because Alamo does not have the discretion to select broker dealers for client
transactions executed by third-party money managers, it should be understood that Alamo will
not have authority to negotiate commissions among various brokers, and Alamo is relying on,
and encouraging, these third-party money managers to achieve best execution at all times. In
addition, a disparity in commission charges may exist between the commissions charged to
other clients. The fees charged by RBC may be higher than those which could otherwise be
found by other executing brokers, in which case Alamo has negotiated on behalf of its clients a
$0 trade away fee for any trades executed by its third-party money managers, even when the
trade is settled back through RBC. The fee schedule contemplates that RBC will charge clients
who maintain some third-party managed accounts an asset-based fee on the assets maintained
in the account. This fee is generally imposed on certain third-party managed accounts which
incur high volume trading activity, for which all trading is completed away from RBC.
Currently, RBC does not impose any fee for the custody of mutual fund assets or cash
balances. RBC may however, impose charges for "excessive turnover" of mutual funds, and/or
may collect a 12b-1 fee directly from the sponsor of certain mutual funds available for purchase
and sale by clients. Although Alamo does not receive 12b-1 fees from any mutual funds, the
imposition of a trade fee by RBC, or the receipt of 12b-1 fees by RBC could be viewed as conflict
of interest by Alamo, since RBC could provide research or other ancillary services to Alamo.
Alamo confirms that it never takes into account any services received by RBC in recommending
a particular mutual fund. All mutual fund recommendations are made based solely on the best
interests of the client, taking into account historical fund performance, correlation with other funds
that are, or will be in, the client’s portfolio, and direct fund expense ratios.
Alamo does not normally negotiate fees and brokerage agreements with other broker dealers
on behalf of clients. Should a client wish to select a separate broker dealer other than RBC,
Alamo will provide a review of the broker's services to the client if requested. Such review
may consider the same factors described above for RBC.
Clients seeking assistance in selecting a custodian other than RBC may be provided with the
15
name of a custodian with which an institutional rate agreement exists. In recommending
custodians, Alamo takes into account the custodian's (1) reputation for efficiency, soundness
and integrity; (2) the reasonableness of the custodian's fees and charges for services generally;
and (3) the custodian's ability and willingness to conform to certain operating conditions
established by Alamo for the conduct of various services to advisory clients.
Assessments of broker dealers and custodians are based on published reports and other
sources deemed to be reliable and, in certain cases, on inquiries made by or on behalf of
Alamo. Alamo does not, however, make any independent inquiry into the correctness or
accuracy of the information it obtains in these ways. If requested by a client, Alamo will evaluate
the reasonableness of particular commission rates, fees or other expenses charged to a client
by a particular broker dealer or custodian, whether recommended by Alamo or not.
Item 13 Review of Accounts
INVESTMENT ADVISORY SERVICE
REVIEWS: These client accounts should refer to the independent registered investment
adviser’s Firm Brochure (or other disclosure document used in lieu of the brochure) for
information regarding the nature and frequency of reviews provided by that independent
registered investment adviser.
Alamo will provide reviews on a quarterly basis. These accounts are reviewed by Robert N. Johnson,
Limited Partner, and Daniel W. Peterson, Limited Partner. Reviews are intended to assess the
effect on the client, if any, of significant changes in the national or global economy, in the market,
or in the legal environment (e.g., with respect to federal and state tax laws), and to revisit the
client's personal circumstances. In addition, a review is performed of the client's quarterly
performance report and the client's IPS, including particularly details of the client's
circumstances and investment restrictions. Any of the foregoing factors may lead to changes in
the client's asset allocation target and additional fund or manager recommendations by Alamo.
REPORTS: These clients should refer to the independent registered investment adviser’s
Firm Brochure (or other disclosure document used in lieu of the brochure) for information
regarding the nature and frequency of reports provided by that independent registered
investment adviser.
Alamo will provide these client accounts with performance reports demonstrating benchmark
comparisons and investment holdings on a quarterly basis.
Item 14 Client Referrals and Other Compensation
It is Alamo's policy not to engage solicitors or to pay related or non-related persons for referring
potential clients to our firm.
OTHER COMPENSATION
As described above in Item 12, Alamo recommends clients utilize the services of RBC and
16
other broker dealers for prime brokerage services. Alamo may receive various services from
these prime brokers, including, but not limited to, direct access to real- time account values,
balances and positions, electronic download of trades, reporting, direct debiting of fees and
research.
Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure
that our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required to
send to the client a statement showing all transactions within the account during the reporting
period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy of the
calculation, among other things. Clients should contact us directly if they believe that there
may be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, we
also send account statements directly to our clients on a quarterly basis. We urge our clients
to carefully compare the information provided on these statements to ensure that all account
transactions, holdings and values are correct and current.
17
Item 16 Investment Discretion
As previously disclosed in Item 4 of this brochure, our firm does not provide discretionary
asset management services; we manage client assets only on a non-discretionary basis.
Therefore, we will obtain the client's approval before executing transactions in the client's
account.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although
our firm may provide investment advisory services relative to client investment assets,
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. Clients are
responsible for instructing each custodian of the assets, to forward to the client copies of
all proxies and shareholder communications relating to the client’s investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact
us with questions at our principal place of business.
Item 18 Financial Information
We are also required to disclose any financial condition that is reasonable likely to impair
our ability to meet our contractual obligations. Alamo has no additional financial
circumstances to report.
Under no circumstances do we require or solicit payment of fees in excess of $1,200
per client more than six months in advance of services rendered. Therefore, we are not
required to include a financial statement.
Alamo has not been the subject of a bankruptcy petition at any time during the past ten
years.
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PART 2B OF FORM ADV: BROCHURE SUPPLEMENT
Robert N. Johnson, CPA, CFP®, CIMA®
Alamo Advisors, LP
4114 Pond Hill
Suite 201
San Antonio, TX 78231
Telephone: (210) 404-2211
bobj@alamoadvisors.com
02/12/2024
This brochure supplement provides information about Robert N. Johnson that supplements
our brochure. You should have received a copy of that brochure. Please contact Robert
Johnson, Chief Compliance Officer, if you did not receive our firm’s brochure or if you
have any questions about the contents of this supplement.
Additional information about Robert N. Johnson is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known
as a CRD number. The CRD number for Robert N. Johnson is 4525810.
19
Educational Background and Business Experience
Item 2
Robert Norman Johnson
Year of Birth: 1967
Formal Education after High School: 1989; Southwest Texas State University, Bachelors in
Accounting; 1990; Texas A&M University, Masters in Taxation.
Business Background:
01/1990 to 06/2002; Senior Manager and Accountant; Ernst & Young LLP
07/2002 to Present; Limited Partner and Chief Compliance Officer, Alamo Advisors, LP
CERTIFIED FINANCIAL PLANNER™ (CFP®):
Robert Johnson is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”) and is a CERTIFIED FINANCIAL PLANNER™
professional or a CFP® professional. Minimum Qualifications to be a CFP® professional:
Bachelor’s degree or higher from an accredited college or university and complete CFP Board-
approved coursework at a college or university through a CFP Board Registered Program. Candidates
complete studies on over 100 topics, including stocks, bonds, taxes, insurance, retirement planning
and estate planning. In addition to passing the CFP® Certification Exam, candidates must also
complete qualifying work experience and agree to be bound by the CFP Board’s Code of Ethics and
Standards of Conduct, which sets forth the ethical and practice standards for CFP® professionals.
To remain certified, certificants must commit to complying with the CFP Board’s Code and
Standards and complete 30 hours of continuing education every two years.
Certified Public Accountant (CPA®):
Mr. Johnson is a Certified Public Accountant licensed by the Texas State Board of Public
Accountancy. In order to become a CPA in the United States, the candidate must sit for and pass the
Uniform Certified Public Accountant Examination. Eligibility to sit for the CPA Exam is determined
by individual State Boards of Accountancy. Typically the requirement is a U.S. Bachelor’s degree
which includes a minimum number of qualifying credit hours in accounting and business
administration with an additional 1 year study. CPAs are required to take continuing education
courses in order to renew their license. Requirements vary by state. The vast majority of states
require 120 hours of CPE every 3 years with a minimum of 20 hours per calendar year.
Certified Investment Management Analyst® (CIMA®):
Mr. Johnson is also a Certified Investment Management Analyst. The CIMA® designation is
awarded by the Investments & Wealth Institute. Candidates must have three years of financial
services experience, complete CIMA courses, and pass the CIMA Certification Exam. CIMA
designees must complete 40 hours of continuing education every two years.
20
Item 3 Disciplinary Information
Mr. Johnson does not have any history of disciplinary events.
Item 4 Other Business Activities
In addition to investment advisory services, Mr. Johnson provides accounting, tax preparation, and
consulting services through Alamo Advisors, LP. These non investment-related activities present a
potential conflict of interest, to the extent that Alamo’s principals and employees may receive
additional compensation as a result of recommending additional accounting, tax preparation, and
consulting services to investment advisory clients. Clients, however, are not under any obligation to
engage Alamo Advisors, LP or Mr. Johnson when considering implementation of advisory
recommendations. The implementation of any or all recommendations is solely at the discretion of
the client. Please see Item 10 of our Firm Brochure (Part 2A of Form ADV) for more information
on conflicts of interest and the steps we take to address conflicts.
Item 5 Additional Compensation
Mr. Johnson does not receive any additional compensation from third parties for providing
investment advice to the firm’s clients.
Item 6
Supervision
Robert Johnson, Limited Partner and Chief Compliance Officer, together with Daniel Peterson,
Limited Partner, is responsible for the supervision and monitoring of investment advice offered to
advisory clients of Alamo Advisors, LP, review all employee personal securities transactions on a
quarterly basis, oversee all material investment policy changes, and conduct periodic testing to
ensure that client objectives and mandates are being met. Mr. Johnson and Mr. Peterson can be
reached at (210) 404-2211.
21
PART 2B OF FORM ADV: BROCHURE SUPPLEMENT
Daniel W. Peterson, CPA, CFP®
Alamo Advisors, LP
4114 Pond Hill
Suite 201
San Antonio, TX 78231
Telephone: (210) 404-2211
danp@alamoadvisors.com
02/12/2024
This brochure supplement provides information about Daniel W. Peterson that supplements
our brochure. You should have received a copy of that brochure. Please contact Robert
Johnson, Chief Compliance Officer, if you did not receive our firm’s brochure or if you
have any questions about the contents of this supplement.
Additional information about Daniel W. Peterson is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known
as a CRD number. The CRD number for Daniel W. Peterson is 4527851.
22
Educational Background and Business Experience
Item 2
Daniel William Peterson
Year of Birth: 1974
Formal Education after High School: 1995; Howard Payne University, B.S. in Business
Administration; 1998; St. Mary’s School of Law, J.D.
Business Background:
06/1995 to 06/2002; Manager and Accountant; Ernst & Young LLP
07/2002 to Present; Limited Partner, Alamo Advisors, LP
CERTIFIED FINANCIAL PLANNER™ (CFP®):
Daniel Peterson is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”) and is a CERTIFIED FINANCIAL PLANNER™
professional or a CFP® professional. *Minimum Qualifications to be a CFP® professional:
Bachelor’s degree or higher from an accredited college or university and complete CFP Board-
approved coursework at a college or university through a CFP Board Registered Program. Candidates
complete studies on over 100 topics, including stocks, bonds, taxes, insurance, retirement planning
and estate planning. In addition to passing the CFP® Certification Exam, candidates must also
complete qualifying work experience and agree to be bound by the CFP Board’s Code of Ethics and
Standards of Conduct, which sets forth the ethical and practice standards for CFP® professionals.
To remain certified, certificants must commit to complying with the CFP Board’s Code and
Standards and complete 30 hours of continuing education every two years.
Certified Public Accountant (CPA):
Mr. Peterson is a Certified Public Accountant licensed by the Texas State Board of Public
Accountancy. In order to become a CPA in the United States, the candidate must sit for and pass the
Uniform Certified Public Accountant Examination. Eligibility to sit for the CPA Exam is determined
by individual State Boards of Accountancy. Typically the requirement is a U.S. Bachelor’s degree
which includes a minimum number of qualifying credit hours in accounting and business
administration with an additional 1 year study. CPAs are required to take continuing education
courses in order to renew their license. Requirements vary by state. The vast majority of states
require 120 hours of CPE every 3 years with a minimum of 20 hours per calendar year.
Item 3 Disciplinary Information
Mr. Peterson does not have any history of disciplinary events.
23
Item 4 Other Business Activities
Mr. Peterson is also an attorney licensed to practice law in the state of Texas. However, Mr.
Peterson does not currently provide direct legal services to any client in that capacity and will not
act in this capacity for any advisory client of Alamo. Mr. Peterson does not spend any of his time
on this activity.
Item 5 Additional Compensation
Mr. Peterson does not receive any additional compensation from third parties for providing
investment advice to the firm’s clients.
Item 6 Supervision
Robert Johnson, Limited Partner and Chief Compliance Officer, together with Daniel Peterson,
Limited Partner, is responsible for the supervision and monitoring of investment advice offered to
advisory clients of Alamo Advisors, LP, review all employee personal securities transactions on a
quarterly basis, oversee all material investment policy changes, and conduct periodic testing to
ensure that client objectives and mandates are being met. Mr. Johnson and Mr. Peterson can be
reached at (210) 404-2211.
24
PART 2B OF FORM ADV: BROCHURE SUPPLEMENT
John J. Rizzo, Jr., CPA, CFP®
Alamo Advisors, LP
4114 Pond Hill
Suite 201
San Antonio, TX 78231
Telephone: (210) 404-2211
jrizzo@alamoadvisors.com
02/12/2024
This brochure supplement provides information about John Rizzo that supplements our
brochure. You should have received a copy of that brochure. Please contact Robert Johnson,
Chief Compliance Officer, if you did not receive our firm’s brochure or if you have any
questions about the contents of this supplement.
information about John Rizzo
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known
as a CRD number. The CRD number for John Rizzo is 5367579.
25
Educational Background and Business Experience
Item 2
John Joseph Rizzo, Jr.
Year of Birth: 1964
Formal Education after High School: 1986; University of Texas at Austin, Bachelors in
Accounting; 1988; St. Mary’s University, San Antonio, Masters in Business Administration.
Business Background:
•
Limited Partner, Alamo Advisors, LP, 01/2023 – Present; Investment Adviser
Representative, 05/2007 – Present
•
Principal, John J. Rizzo, Jr., CPA PC, 08/1997 – 01/2023
CERTIFIED FINANCIAL PLANNER™ (CFP®):
John Rizzo is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”) and is a CERTIFIED FINANCIAL PLANNER™
professional or a CFP® professional. *Minimum Qualifications to be a CFP® professional:
Bachelor’s degree or higher from an accredited college or university and complete CFP Board-
approved coursework at a college or university through a CFP Board Registered Program.
Candidates complete studies on over 100 topics, including stocks, bonds, taxes, insurance,
retirement planning and estate planning. In addition to passing the CFP® Certification Exam,
candidates must also complete qualifying work experience and agree to be bound by the CFP
Board’s Code of Ethics and Standards of Conduct, which sets forth the ethical and practice standards
for CFP® professionals. To remain certified, certificants must commit to complying with the CFP
Board’s Code and Standards and complete 30 hours of continuing education every two years.
Certified Public Accountant (CPA):
John Rizzo is a Certified Public Accountant licensed by the Texas State Board of Public
Accountancy. In order to become a CPA in the United States, the candidate must sit for and pass
the Uniform Certified Public Accountant Examination. Eligibility to sit for the CPA Exam is
determined by individual State Boards of Accountancy. Typically the requirement is a U.S.
Bachelor’s degree which includes a minimum number of qualifying credit hours in accounting and
business administration with an additional 1 year study. CPAs are required to take continuing
education courses in order to renew their license. Requirements vary by state. The vast majority
of states require 120 hours of CPE every 3 years with a minimum of 20 hours per calendar year.
Item 3 Disciplinary Information
Mr. Rizzo does not have any history of disciplinary events.
Item 4 Other Business Activities
Mr. Rizzo is not engaged in any other business activities.
26
Item 5 Additional Compensation
Mr. Rizzo does not receive any additional compensation from third parties for providing
investment advice to the firm’s clients.
Item 6 Supervision
Robert Johnson, Limited Partner and Chief Compliance Officer, together with Daniel Peterson,
Limited Partner, is responsible for the supervision and monitoring of investment advice offered to
advisory clients of Alamo Advisors, LP, review all employee personal securities transactions on a
quarterly basis, oversee all material investment policy changes, and conduct periodic testing to
ensure that client objectives and mandates are being met. Mr. Johnson and Mr. Peterson can be
reached at (210) 404-2211.
27