Regulation Best Interest Disclosure

American Capital Partners, LLC Form CRS

Capacity in Which We Are Acting

American Capital Partners, LLC (“ACP”) is registered with the Securities and Exchange Commission as a broker-dealer and is also a member of FINRA and SIPC (Securities Investor Protection Corporation). Partners Capital Services, Inc. (“PCS”), an affiliated investment adviser, is registered with the SEC.

When a Financial Professional is acting in their broker-dealer capacity, they are providing recommendations for transactions in securities and may receive transaction-based compensation (commissions).

When a Financial Professional is acting in their investment adviser capacity through PCS, they are providing fiduciary advisory services, typically for a fee based on assets under management (AUM) or other agreed-upon arrangements. In this capacity, the representative is required to act in your best interest at all times.

Some of our Financial Professionals are dually registered with ACP and PCS and may act in either capacity depending on the service provided. It is important for clients to understand the differences in services, compensation, and standard of care depending on whether advice is provided in a broker-dealer or investment adviser capacity.

Material Fees and Costs That Apply To Your Accounts

A retail investor will pay transaction-based commissions to ACP on their investment transactions. Commissions will vary by product and transaction size. Other fees that you may be charged on specific investment products that you may purchase include private placement fees and commissions paid for annuity contracts, life insurance, and other service fees.

In addition to our transaction fees, clients are also responsible for the fees and expenses that may be charged by custodians/clearing firms and by the investments themselves, including, but not limited to: custodian fees, IRA custody fees, account maintenance fees, fees related to mutual funds, and other transactional and product-level fees. Clients will find additional information on trade confirmations, account statements, and prospectuses. Please see the attached Fee Schedule for a full listing of fees.

Example: Fee Impact on a $50,000 Account

                     Activity                      Fee
                     Annual Account Fee                             $80
                     Domestic Wire                             $35
                     Duplicate Statement                             $2.50
                                             Total                             $117.50

This example is illustrative only and does not include all potential transaction fees. Actual fees will vary based on account activity, investment products selected, and other factors. See attached Fee Schedule for a complete listing of all fees.

The Type and Scope of Services We Provide

ACP offers brokerage services only. The principal services offered are the buying and selling of individual stocks, bonds, mutual funds, annuities, and private placements. Financial Professionals offer recommendations as well as executing unsolicited transactions. You, the investor, make the ultimate decision regarding the purchase or sale of investments. Periodic reviews of your accounts are done, but it is recommended that investors monitor their accounts. Additional information may be found in the account opening agreement or other account opening-related documents.

Requirements to Open or Maintain an Account

  1. Account Opening Requirements

To open an account with ACP, clients must:

  1. Provide Required Information
    • Personal information (name, address, date of birth, Social Security number)
    • Financial information (income, net worth, assets, liabilities)
    • Investment objectives, time horizon, and risk tolerance
  2. Execute Required Agreements
    • Account opening agreement
    • Risk disclosure documents
    • Product-specific agreements (e.g., annuities, private placements)
  3. Funding Requirements
    • Accounts must be funded according to minimum initial deposit requirements
    • Funding can occur via check, electronic transfer, or other approved methods
  1. Account Maintenance Requirements
  • ACP generally does not impose strict account size limitations.
  • Smaller accounts may incur maintenance fees, as detailed in the attached Fee Schedule.
  • Clients must maintain sufficient funds or assets to cover transactions and fees.
  • ACP reserves the right to close accounts if required regulatory information is missing, accounts are inactive for extended periods, or fees cannot be collected.
  • Clients must promptly update any information that could affect suitability or regulatory compliance.
  1. Transparency and Client Responsibility
  • All fees will be clearly disclosed on trade confirmations and account statements.
  • Clients are encouraged to review fees regularly to understand the total cost of maintaining and transacting in their accounts.
  • ACP maintains policies to mitigate conflicts, including supervisory review of fees and transactions, disclosure of all material conflicts, and suitability assessments for each recommendation.
  • Please see the attached Fee Schedule for a complete listing of all account and transaction fees.

Limitations on the Securities or Investment Strategies We Offer

Our investment recommendations are not limited to any specific product or service offered by a broker-dealer, insurance company, or other product companies.

Basis for Our Recommendations

Recommendations are presented to you based on your investment objectives and risk tolerance. Our Financial Professionals work with clients to determine the investments that meet the clients’ goals and desires. We ask that you provide information on your investment profile, which includes your age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, and any other information that you feel is relevant in connection with the recommendations that you would like to be provided.

Risks Associated With Recommendations

While the stock market or a specific investment may increase and clients’ accounts could enjoy a gain, it is also possible that the stock market or a specific investment may decrease and clients’ accounts could suffer a loss. It is important that clients understand that all investment activities involve a degree of risks, including the possible risk of loss of their entire investment, as well as the gains earned thereon. Securities investments are not guaranteed and you may lose money on your investments. Investing in securities involves a high risk of loss that clients should be prepared to bear. We ask that you work with us to help us understand your tolerance for risk.

Conflicts Of Interest

ACP’s Financial Professionals are compensated by receiving a percentage of the product sales commission you are charged. This creates a conflict in that there is an incentive to conduct more transactions to generate more commission. Some of ACP’s associated persons are also licensed as insurance brokers that would earn additional commission if a client was to purchase insurance through them. In addition, some private placement products are managed by a related firm that will earn additional fees on their management of the investments. These conflicts are fully disclosed in the individual private placement memorandums. ACP is also a market maker and from time to time may make a market in a particular security. ACP could make money trading that security to and from customers.