Emanay Firm Brochure

October 2026 · Emanay Inc. (dba Emanay Advisors), 1221 Brickell Avenue, Suite 900, Miami, Florida 33131 · legal@emanay.io

This brochure describes Emanay’s business, fees and conflicts of interest. Emanay Inc. is not registered as an investment adviser with the SEC or any state, and is not a registered broker-dealer. This brochure follows the structure of an adviser brochure for clarity only; it is not a Form ADV filing.

1. Cover and material changes

This is the first version of this brochure. Future versions will summarise material changes since the last version here.

2. Services by division

• Emanay Advisors (Emanay Inc.): sell-side, buy-side and roll-up transaction advisory; the client relationship and engagement letter for all divisions.
• Emanay Capital: structuring and arranging debt and equity financing, and structuring investment vehicles; no offers of securities through our content.
• Emanay Accounting: bookkeeping, accounting, financial reporting and tax coordination for each entity a client owns, consolidated to the client’s office.
• Emanay Realty: licensed Florida real estate brokerage, including business brokerage, under its own brokerage agreements.
• Emanay Technologies: technology, systems and AI implementation.
• Emanay Ventures: building and operating portfolio companies.
• E-2 Program: coordinating business and investment services for E-2 treaty-investor applicants, alongside their own immigration counsel.

3. Fees and compensation

Your engagement letter with Emanay Inc. governs fees. Fee types: retainers and monthly fees; time-based fees; fixed project fees; success or transaction fees payable at closing; deposits applied against fees as the engagement letter states; and third-party costs re-billed at cost. AI usage tied to your engagement may appear as a technology line. Divisions are paid by Emanay Inc. for their work on your engagement; you pay only Emanay Inc. (except brokerage commissions earned by Emanay Realty). See the Fee Schedule (Part 19).

4. Types of clients

Business owners and founders; individual and family investors and their family offices; companies and their boards; investors applying under the E-2 treaty-investor program; and partners in our network.

5. Methods of analysis and risk of loss

We analyse businesses, properties and transactions using financial statements, projections, market comparables, diligence findings and lender criteria. Every acquisition, capital raise and venture carries risk, including the loss of all money invested. Projections may not be achieved; markets, interest rates, lenders and counterparties may change; small and private businesses are illiquid and may depend on a few people or customers; and immigration outcomes are decided by government authorities. Past results do not predict future results.

6. Disciplinary information

None.

7. Other activities and affiliations

Emanay Inc. is owned by Emanay Holdings LLC, which also owns Emanay Accounting, Emanay Capital, Emanay Technologies, Emanay Ventures and Emanay Realty. Emanay Ventures owns or holds interests in operating companies. We work with a network of partners, lenders, professionals and creators. When we recommend an affiliate or a partner, we have an interest in that recommendation; we disclose it, and you are free to use other providers.

8. Code of ethics

Everyone who works with us must: keep client information confidential and separate; disclose conflicts of interest before acting; not trade on or use confidential client information for personal benefit; disclose any personal interest in a business, property or transaction we are working on, and not deal in it without written approval; and follow the Community Standards and Acceptable Use Policy. A copy is available on request.

9. Referrals and other compensation

Associates may receive a share of the fees on engagements they originate, facilitate or help close. Referral partners and creators may receive a referral fee or other benefit when someone they introduce engages us. These arrangements are set in signed agreements, disclosed to the client, and do not change the fees in the client’s engagement letter.

10. Custody

Emanay does not hold client securities. Client payments to Emanay are processed through our payment processor, Stripe and, where a transaction requires it, deposits or closing funds are held by an independent escrow agent or title company. We do not have authority to withdraw client funds except as a client authorises in writing for payment of our invoices.

11. Financial information

Emanay does not require prepayment of fees more than six months in advance, and is not aware of any financial condition likely to impair its ability to meet its commitments to clients.