View Document Text
Item 1 – Cover Page
Part 2A of Form ADV
Main Address
6141 Robinson Street
Jupiter, Florida 33458
Mailing Address
9450 SW Gemini Drive
PMB 68338
Beaverton, Oregon 97008-7105
Phone: (855) 540-0400
Fax: (855) 840-0401
Email: ron@freedomfamilyoffice.com
Website: www.freedomfamilyoffice.com
February 2026
This Brochure provides information about the qualifications and business practices of Freedom Family
Office, LLC. If you have any questions about the contents of this Brochure, please contact us using the
information listed above. The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Freedom Family Office, LLC (CRD# 310275) is a registered investment advisor with the SEC. Registration
of an investment advisor does not imply any certain level of skill or training.
Additional information about Freedom Family Office, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 1
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this brochure. We
will review and update, as needed, our brochure at least annually to make sure that it remains current.
The material changes in this brochure since the last annual updating amendment on April 29th, 2025, are
described below.
Item 4: Updated to reflect our assets under management as of December 31st, 2025
•
• We have added another custodian, Charles Schwab & Company, Inc.
Freedom Family Office has made additional non-material updates to other sections in this Brochure, so we
encourage each client to review the complete Brochure carefully and to call us with any questions you may have.
If you would like to receive a complete copy of our current brochure free of charge at any time, please contact us
at (855) 540-0400 or at ron@freedomfamilyoffice.com.
Additional information about Freedom Family Office, LLC and our investment adviser representatives is available
on the SEC’s website at https://adviserinfo.sec.gov/.
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 2
Table of Contents - Item 3
Contents
Material Changes - Item 2 ......................................................................................................................... 1
Table of Contents - Item 3 ........................................................................................................................ 2
Advisory Business - Item 4 ........................................................................................................................ 3
Fees and Compensation – Item 5 ............................................................................................................. 5
Performance-Based Fees and Side-By-Side Management - Item 6 .......................................................... 7
Types of Clients & Account Minimums - Item 7 ....................................................................................... 7
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8..................................................... 7
Disciplinary Information - Item 9 ............................................................................................................ 12
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 12
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 12
Brokerage Practices - Item 12 ................................................................................................................. 13
Review of Accounts - Item 13 ................................................................................................................. 15
Client Referrals and Other Compensation - Item 14 .............................................................................. 15
Custody - Item 15 .................................................................................................................................... 15
Investment Discretion - Item 16 ............................................................................................................. 16
Voting Client Securities - Item 17 ........................................................................................................... 16
Financial Information - Item 18 .............................................................................................................. 17
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 3
Advisory Business - Item 4
Freedom Family Office, LLC (hereinafter “FFO”) is a registered investment advisor based in south Florida. We are
a limited liability company, organized under the laws of the State of Florida. The Freedom Legacy Trust is the
principal owner of FFO.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of
our firm. Where required, such persons are properly registered as investment adviser representatives.
Currently, we offer the following investment advisory services, personalized for each individual client:
•
•
Family Office Services
Portfolio Management Services
Family Office Services
FFO provides family office services that are designed to help families coordinate their multiple forms of capital
using a holistic and collaborative team approach combining the many elements inherent to a successful life with
wealth. Our collective experiences support our belief that a dedicated team of independent and objective
professionals working in collaboration with each other in partnership with the family is the best way to serve
families of significant wealth. Such a relationship enhances FFO’s ability to advise families on the opportunities
and risks that their wealth presents, allowing families to make better, educated decisions.
Initially, FFO meets with the prospective client to obtain information about their overall situation. This
information is used to assist FFO in understanding a client’s needs and the scope of services that are most
appropriate for the client’s situation. The family office services FFO will provide will be specifically described in
the Family Office Services Agreement you enter into with our firm. Additional services beyond the scope of the
Family Office Services Agreement may be provided under separate agreement(s) and may include a separate fee
as mutually agreed to by FFO and the client.
Our family office services vary by family and occasionally within families, but may include the following:
•
•
•
•
•
•
•
Portfolio Management Services – Includes development of asset allocation, ongoing portfolio
management, and review, including selection and evaluation of investment managers. Further, we may
provide customized performance reporting at the portfolio level and at the manager or specific
investment level. Additional information about our portfolio management services is provided in the
portfolio management services section below.
Information Management and Coordination – We organize key information and the coordinate such
information with the family, the family’s accountant, attorney, insurance agents, and other key advisors.
Estate, Gift & Trust Planning – We provide explanations, summaries, and illustrations of existing and
proposed estate planning documents and strategies, including recommendations and education on
additional strategies, considerations for making updates periodically and further coordination with
family’s tax and legal advisor(s) to implement agreed upon strategies or updates.
Income Tax Planning – Includes planning for the minimization of tax liabilities, including asset location,
tax loss harvesting and gain minimization planning, charitable asset selection, facilitation of income tax
payments and coordination with family’s tax advisor(s).
Financial Planning – Includes planning related to cash flow analysis, capital sufficiency modeling, lifestyle
goals, credit usage, major asset purchases or liquidations, and significant life events.
Philanthropic Planning – Includes defining philanthropic goals, education on philanthropic vehicles and
strategies for maximizing the benefits of philanthropy across the family and the organizations they
choose to benefit.
Education – Includes both individual and group-based learning sessions around various planning, tax,
investment and other topics with an intention of growing not only the family’s financial capital, but non-
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 4
•
financial capital as well. These topics while commonly focused on younger generations are generally
available across all generations.
Family Meetings – Includes facilitation of family meetings often across multiple generations around
shared ownership, philanthropy, decision making or shared goals and objectives.
•
• Assistance with Trust Administration – Includes advice around trustee selection and ongoing guidance,
general understanding of trust purposes and provisions. Often, this involves education for grantors,
trustees, and beneficiaries on their respective roles and responsibilities.
Consolidated Reporting Services – Allows the family to customize how their assets are reported by
offering a view across multiple accounts or entities in a single statement and/or to segregate assets
within accounts. This service may include assets not generally managed by FFO such as closely-held
private family assets. This enables the family and their advisors to understand and monitor the total
family balance sheet and provide comprehensive and integrated advice from a vantage point inclusive
of the family’s entire wealth landscape. This may require an additional fee depending on the nature and
complexity of the non-managed assets being reported on. Any additional fees will be mutually agreed
to in advance.
•
•
• Asset Protection Planning and Review – Includes review and discussion of strategies that may avoid or
minimize a portion of a family’s balance sheet at risk. These strategies will be evaluated on the benefits
they may provide against the degree and likelihood of loss and the complexity and administration they
may require to achieve such protections.
Liability Risk Management Planning and Review – Includes advice on a combination of mitigation
strategies including the use of special purpose entities, trusts and/or various insurance tools. We will
review the family’s assets and liabilities to determine: location, titling and ownership structure. We will
review existing or proposed policies and, after receiving your permission, we may facilitate reviews with
unaffiliated third-party professionals.
Estate Tax Liquidity Planning and Review – Includes determination of estate tax liquidity needs and
determination of potential liquidity sources including asset liquidations and life insurance. We will review
existing or proposed policies and, after receiving your permission, we may facilitate reviews with
unaffiliated third-party professionals.
The advice we propose is designed to achieve the client’s desired goals which may require revision to meet
changing circumstances. Our recommendations are based on your situation from the information provided to the
firm. Families may choose to accept or reject our recommendations. We should be notified promptly of any
change to your situation, goals, objectives, or needs.
Portfolio Management Services
Our firm offers discretionary portfolio management services to our clients. Discretionary portfolio management
means we will make investment decisions and place buy or sell orders in your account without contacting you.
These decisions would be made based upon your stated investment objectives, which will be documented in a
written Investment Policy Statement. If you wish, you may limit our discretionary authority by, for example,
setting a limit on the type of securities that can be purchased for your account. Simply provide us with your
restrictions or guidelines in writing.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and help you decide how to allocate your investments. The information we gather will help us implement an asset
allocation strategy that will be specific to your goals, whether we are actively investing for you or simply providing
you with advice.
We can advise clients on various types of securities, such as exchange listed equities, over the counter equities,
foreign issues, American depository receipts, corporate debt securities, commercial paper, certificates of deposit,
municipal securities, investment company securities (including mutual funds and exchange traded funds), US
Government securities, options contracts on securities and/or commodities, private equity instruments, and
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 5
interests in partnership investing in real estate. Additionally, will provide advice on existing investments you may
hold at the inception of the advisory relationship or on other types of investments for which you ask advice.
If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous
basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your
financial circumstances, as guided by your Investment Policy Statement.
Wrap Fee Programs
We do not sponsor, manage, or participate in any wrap fee programs.
Assets Under Management
As of December 31, 2025, we manage approximately $162,140,871 in client assets on a discretionary basis and
approximately $0 in client assets on a non-discretionary basis.
Important Note: Information related to legal matters that is provided as part of our services is for informative
purposes only. Clients are instructed to contact their legal advisers for personalized advice.
Fees and Compensation – Item 5
Family Office Services Fees
For family office services, FFO charges an agreed-upon fixed fee that starts at $15,000. The fee will increase based
on the complexity of the client’s financial situation and needs. Family office service fees are negotiated with each
family office and can vary greatly based on the needs of each family. Prior to engaging FFO to provide family office
services, clients will be required to enter into a written agreement with our firm. This agreement will set forth the
terms and conditions of the engagement and will describe the scope of the services to be provided, the agreed
upon fixed fee, and the frequency of the payment. Fees are payable in accordance with a payment arrangement
that is clearly set forth in the agreement signed by the client and the firm. Invoices are available upon request.
Services beyond the scope of the family office services agreement will be billed at a rate of $500/hour.
Either party may terminate the family office services agreement by written notice to the other. All prepaid,
unearned fees will be promptly refunded to the client.
Portfolio Management Services Fees
FFO charges an annual fee of up to 1.50% of the market value of the assets under management for portfolio
management services. These fees are based on factors such as the amount of assets, range of investments, and
complexity of the client’s financial circumstances, among others.
Below is our standard fee schedule; however, it is negotiable. Since this fee is agreed upon with each client, the
exact fee paid by the client will be clearly stated in the advisory agreement signed by FFO and the client. We
generally impose a minimum monthly fee of $1,000, which may be waived or discounted at our discretion.
• Amounts up to $5,000,000 billed at 1.25% per annum.
• Amounts from $5,000,001 to $10,000,000 billed I.00% per annum.
• Amounts from $10,000,001 to $20,000,000 billed 0.75% per annum.
• Amounts from $20,000,001 to $50,000,000 billed 0.60% per annum.
• Amounts above $50,000,001 billed 0.50% per annum.
Investment management fees are payable monthly, in arrears. An average of the daily balance in the client’s
account throughout the billing period is used to determine the market value of the assets upon which the advisory
fee is based. Generally, the custodian holding the client’s account will deduct FFO’s fees and any other custodial
fees directly from a designated account to facilitate billing provided the client has given written authorization.
The qualified custodian will send an account statement at least quarterly. This statement will detail all account
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 6
activity. In limited circumstances, at the sole discretion of FFO, we may agree to invoice you directly for our
advisory fee or we may negotiate other fee payment arrangements.
At the inception of services, the first pay period’s fees will be calculated on a pro-rata basis. The wealth agreement
between the client and FFO will continue in effect until either party terminates the agreement in accordance with
the terms of the agreement. FFO’s annual fee will be pro-rated through the date of termination. Refunds are not
applicable because fees are payable in arrears.
Important Notes Regarding Billing
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise
agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of
assets under management for purposes of calculating the firm’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events (there being no guarantee that such
anticipated market conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts
could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could
exceed the interest paid by the client’s cash or cash equivalent positions.
Billing on Margin: Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including
margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory
fee. Clients should note that this practice will increase total assets under management used to calculate advisory
fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest
in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the
firm and its Associated Persons strive to uphold their fiduciary duty of fair dealing with clients. Clients are free to
restrict the use of margin by our firm. However, clients should note that any restriction on the use of margin may
negatively impact an account’s performance in a rising market.
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, the firm will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including but not limited to investment
performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial
circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may
be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary
nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will
continue to apply during these periods, and there can be no assurance that investment decisions made by the
firm will be profitable or equal any specific performance level(s).
Additional Fees and Expenses
Our fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other related costs and
expenses. You are responsible for brokerage costs incurred. However, FFO will not receive any portion of the
commissions, fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage
arrangements and transaction costs.
Fees are negotiable based on the amount of assets under management, complexity of client goals and objectives,
and level of services rendered. As described above, the fees are charged as described and are not based on a
share of capital gains of the funds of any advisory client.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result, the Associated Person
servicing your account may charge more or less for the same service than another Associated Person of our firm.
Further, our annual investment management fee may be higher than that charged by other investment advisors
offering similar services/programs.
All fees paid to FFO for investment advisory services are separate and distinct from the fees and expenses charged
to shareholders by mutual funds or exchange traded funds. These fees and expenses are described in each fund's
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 7
prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee.
If the fund also imposes sales charges, you may pay an initial or deferred sales charge.
A client could invest in a mutual fund directly, without the services of FFO. In this case, the client would not receive
the services provided by FFO, which are designed, among other things, to assist the client in determining which
mutual fund or funds are most appropriate to their financial condition and objectives. Accordingly, clients should
review the fees charged by the funds and the fees charged by FFO to fully understand the total amount of fees
charged and to evaluate the cost of advisory services being provided.
We do not represent, warrant, or imply that the services or methods of analysis employed by us can or will predict
future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections
or declines.
Performance-Based Fees and Side-By-Side Management - Item 6
Fees are not based on a share of the capital gains or capital appreciation of managed securities. FFO does not use
a performance-based fee structure nor “side-by-side” management because of the conflict of interest.
Performance based compensation may create an incentive for FFO to recommend an investment that may carry
a higher degree of risk to the Client.
Types of Clients & Account Minimums - Item 7
We generally offer investment advisory services to individuals, pension and profit sharing plans and participants,
trusts, estates, charitable organizations, corporations, and other business entities.
FFO requires a minimum account size of $1,000,000 for advisory accounts. However, from time-to-time, in its sole
discretion, FFO may accept smaller accounts based on various criteria, such as anticipated future assets, related
accounts, and other factors.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
We may use one or more of the following methods of analysis and/or investment strategies when providing
investment advice to you:
• Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience and
expertise of the company’s management, and the outlook for the company’s industry. The resulting data
is used to measure the true value of the company’s stock compared to the current market value. The
primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may
not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities
prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
performance.
• Technical Analysis – technical analysis is a technique that relies on the assumption that current market
data (such as charts of price, volume, and open interest) can help predict future market trends, at least
in the short term. It assumes that market psychology influences trading and can predict when stocks will
rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
domestic and foreign market trading activity, including various industry and sector trading statistics
within such markets. Technical trading models, through mathematical algorithms, attempt to identify
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 8
when markets are likely to increase or decrease and identify appropriate entry and exit points. The
primary risk of technical trading models is that historical trends and past performance cannot predict
future trends, and there is no assurance that the mathematical algorithms employed are designed
properly, updated with new data, and can accurately predict future market, industry, and sector
performance.
We may use one or more of the following investment strategies when advising you on investments:
• Long Term Purchases – securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
strategy generally assumes the financial markets will go up in the long-term which may not be the case.
There is also the risk that the segment of the market that you are invested in or perhaps just your
particular investment will go down over time even if the overall financial markets advance. Purchasing
investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized
in the short-term in other investments.
• Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively
short period of time, generally less than one year, to take advantage of the securities' short-term price
fluctuations. Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short-term which may be very difficult and will incur a disproportionately
higher amount of transaction costs compared to long-term trading. There are many factors that can
affect financial market performance in the short-term (such as short-term interest rate changes, cyclical
earnings announcements, etc.) but may have a smaller impact over longer periods of times.
•
Trading – securities are sold within 30 days. The principal type of risk associated with trading is market
risk. There can be no assurance that a specific investment will achieve its investment objectives and past
performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments
may also be affected by changes in exchange control regulation, tax laws, withholding taxes,
international, political and economic developments, and government, economic or monetary policies.
Additionally, trading is speculative. Market movements are difficult to predict and are influenced by,
among other things, government trade, fiscal, monetary and exchange control programs and policies;
changing supply and demand relationships; national and international political and economic events;
changes in interest rates; and the inherent volatility of the marketplace. In addition, governments from
time to time intervene, directly and by regulation, in certain markets, often with the intent to influence
prices directly. The effects of governmental intervention may be particularly significant at certain times
in the financial instrument markets and such intervention (as well as other factors) may cause these
markets to move rapidly.
• Option Writing – an option is the right either to buy or sell a specified amount or value of a particular
underlying investment instrument at a fixed price (i.e. the “exercise price”) by exercising the option
before its specified expiration date. Options giving you the right to buy are called “call” options. Options
giving you the right to sell are called “put” options. When trading options on behalf of a client, we
generally use covered options. Covered options involve options trading when you own the underlying
instrument on which the option is based. Investments in options contracts have the risk of losing value
in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of
a single contract to control many shares of an underlying stock. This leverage can compound gains or
losses.
• Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow
on securities already in their custodial account. Interest is charged on any borrowed funds for the period
of time that the loan is outstanding. When you purchase securities, you may pay for the securities in full
or you may borrow part of the purchase price from your broker/dealer. If you intend to borrow funds in
connection with your account, you will be required to open a margin account, which will be carried by
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 9
the broker/dealer of your account. The securities purchased in such an account are the broker/dealer’s
collateral for its loan to you. If the securities in a margin account decline in value, the value of the
collateral supporting this loan also declines, and, as a result, a brokerage firm is required to take action,
such as issue a margin call and/or sell securities or other assets in your accounts, in order to maintain
necessary level of equity in the account. It is important that you fully understand the risks involved in
trading securities on margin, which are applicable to any margin account that you may maintain,
including any Margin Account that may be established as a part of our advisory services and held by your
broker/dealer. These risks include the following:
•
•
•
•
•
•
You can lose more funds than you deposit in your margin account
The broker/dealer can force the sale of securities or other assets in your account
The broker/dealer can sell your securities or other assets without contacting you
You may not be able to choose which securities or other assets in your margin account are
liquidated or sold to meet a margin call
The broker/dealer may move securities held in your cash account to your margin account and
pledge the transferred securities
You may not be entitled to an extension of time on a margin call
Investing in securities involves risk of loss that clients should be prepared to bear.
The investment advice provided along with the strategies suggested by FFO will vary depending on each client’s
specific financial situation and goals. This brief statement does not disclose all of the risks and other significant
aspects of investing in financial markets. In light of the risks, you should fully understand the nature of the
contractual relationship(s) into which you are entering into and the extent of your exposure to risk. Certain
investment strategies may not be suitable for many members of the public. You should carefully consider whether
the strategies employed would be appropriate for you considering your experience, objectives, financial resources
and other relevant circumstances.
Recommendation of Particular Types of Securities: As disclosed under the “Advisory Business” section in this
Brochure, we provide advice on various types of securities. We do not necessarily recommend one particular type
of security over another since each client has different needs and different tolerance for risk. Each type of security
has its own unique set of risks associated with it and it would not be possible to list here all the specific risks of
every type of investment. Even within the same type of investment, risks can vary widely. However, in very
general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks,
including complete possible loss of principal plus other losses and may not be suitable for many members of the
public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect
against market losses. Different market instruments carry different types and degrees of risk, and you should
familiarize yourself with the risks involved in the particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment objectives and
past performance should not be seen as a guide to future returns. The value of investments and the income
derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also
be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and
economic developments, and governmental economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may
fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their
prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may
not make required interest payments. An issuer suffering an adverse change in its financial condition could lower
the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 10
a security may also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality
debt securities are more susceptible to these problems and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control
regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value,
the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are
determined by supply and demand in the currency exchange markets, the international balance of payments,
governmental intervention, speculation, and other economic and political conditions. If the currency in which a
security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a
decline in the exchange rate of the currency would adversely affect the value of the security.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares of stocks by
an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the
stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the
investment may incur a loss.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective investment
systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments,
other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the
fund's investments in accordance with the fund's investment objective. While mutual funds generally provide
diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant
degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different
types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition,
while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds
do charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): ETFs are a type of index fund bought and sold
on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities
they are designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have
management fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices
may not correlate perfectly with changes in the underlying reference units; and (ii) the risk of possible trading halts
due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make
trading in the ETF inadvisable.
Risks Associated with Investing in Private Placement Offerings and Private Funds: Private investment funds are
not registered with the Securities and Exchange Commission and may not be registered with any other regulatory
authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers
are subject. There may be little public information available about their investments and performance. Moreover,
as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could
be difficult for a client to sell its shares of a private investment company at an advantageous price and time. Since
shares of private investment companies are not publicly traded, from time to time it may be difficult to establish
a fair value for the client’s investment in these companies.
Risks Associated with Alternative Investments: Non-traded REITs, business development companies, limited
partnerships, and direct alternatives are subject to various risks such as liquidity and property devaluation based
on adverse economic and real estate market conditions and may not be suitable for all investors. A prospectus
that discloses all risks, fees and expenses may be obtained from your advisor. Read the prospectus carefully before
investing. This is not a solicitation or offering which can only be made in conjunction with a copy of the prospectus.
Investors considering an investment strategy utilizing alternative investments should understand that alternative
investments are generally considered speculative in nature and may involve a high degree of risk, particularly if
concentrating investments in one or few alternatives investments.
Risks Associated with Investing in Options: Transactions in options carry a high degree of risk. A relatively small
market movement will have a proportionately larger impact, which may work for or against the investor. The
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 11
placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because
market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option
generally entails considerably greater risk than purchasing options. Although the premium received by the seller
is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of
the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire
or deliver the underlying investment. If the option is "covered" by the seller holding a corresponding position in
the underlying investment or a future on another option, the risk may be reduced.
Risks Associated with Investing in Inverse and Leveraged Funds: Leveraged mutual funds and ETFs generally seek
to deliver multiples of the daily performance of the index or benchmark that they track. Inverse mutual funds and
ETFs generally seek to deliver the opposite of the daily performance of the index or benchmark that they track.
Inverse funds often are marketed as a way for investors to profit from, or at least hedge their exposure to,
downward-moving markets. Some Inverse funds are both inverse and leveraged, meaning that they seek a return
that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged
and inverse funds use a range of investment strategies, including swaps, futures contracts, and other derivative
instruments. Leveraged, inverse, and leveraged inverse funds are more volatile and riskier than traditional funds
due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed funds, which may amplify gains and losses.
Most leveraged funds are typically designed to achieve their desired exposure on a daily (in a few cases, monthly)
basis, and reset their leverage daily. A "single day" is measured from the time the leveraged fund calculates its
net asset value ("NAV") to the time of the leveraged fund's next NAV calculation. The return of the leveraged fund
for periods longer than a single day will be the result of each day's returns compounded over the period. Due to
the effect of this mathematical compounding, their performance over longer periods of time can differ
significantly from the performance (or inverse performance) of their underlying index or benchmark during the
same period of time. For periods longer than a single day, the leveraged fund will lose money when the level of
the Index is flat, and the leveraged fund may lose money even if the level of the Index rises. Longer holding
periods, higher index volatility, and greater leverage all exacerbate the impact of compounding on an investor's
returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged fund's return
as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged
inverse funds for longer periods of time increases their risk due to the effects of compounding and the inherent
difficulty in market timing. Leveraged funds are riskier than similarly benchmarked funds that do not use leverage.
Non-traditional funds are highly volatile and not suitable for all investors. They provide the potential for significant
losses.
Risks Associated with Investing in Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs since the ETF
is designed to offer downside protection for a specified period of time. These ETFs are modeled after options-
based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are designed to safeguard
against market downturns by employing complex options strategies. Buffer ETFs typically charge higher
management fees that are considerably more than the index funds whose performance they attempt to track.
Additionally, because buffer funds own options, they do not receive dividends from their equity holdings. Both
factors result in the underperformance of the Buffer ETF compared to the index they attempt to track. Clients
should carefully read the prospectus for a buffer ETF to fully understand the cost structures, risks, and features
of these complex products.
Cybersecurity Risk. FFO and its service providers may be subject to operational and information security risks
resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained
online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or
various other forms of cybersecurity breaches. Cybersecurity attacks affecting FFO and its service providers may
adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the
release of private information about Clients, impede trading, subject FFO to regulatory fines or financial losses,
and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in
which Clients may invest in, qualified custodians, governmental and other regulatory authorities, exchange and
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 12
other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately
cause them to incur losses, including for example: financial losses, cost and reputational damages, and loss from
damage or interruption of systems. Although FFO has established its systems to reduce the risk of these incidents
from coming to fruition, there is no guarantee that these efforts will always be successful, especially considering
that FFO does not directly control the cybersecurity measures and policies employed by third party service
providers.
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks
involved in an investment with FFO.
Disciplinary Information - Item 9
FFO and its management have not been involved in any criminal or civil actions, administrative or self-regulatory
enforcement proceedings, nor any legal or disciplinary events that are material to a Client’s or prospective Client’s
evaluation of FFO or the integrity of its management.
Other Financial Industry Activities or Affiliations - Item 10
Registration as a Broker-Dealer or Broker-Dealer Representative
Neither FFO nor its management persons are registered as a broker-dealer or broker-dealer representative.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor
Neither FFO nor its management persons are registered as futures commission merchant, commodity pool
operator, or a commodity trading advisor.
Relationships Material to this Advisory Business and Possible Conflicts of Interest
Insurance Services
Certain Executive officers and other Associated Persons of FFO are licensed as independent insurance agents.
These persons will earn commission-based compensation for selling insurance products, including insurance
products they sell to clients of FFO. Insurance commissions earned by these persons are separate and in addition
to FFO’s advisory fees. This practice presents a conflict of interest because persons providing investment advice
on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for
the purpose of generating commissions rather than solely based on your needs. Clients of our firm are under no
obligation, contractually or otherwise, to purchase insurance products through any person or entity affiliated
with our firm.
Selection of Other Advisors or Managers
FFO does not utilize nor select other advisors.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Code of Ethics
FFO has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The Code focuses
primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The
Code includes FFO’s policies and procedures developed to protect client’s interests in relation to the following
topics:
▪
The duty at all times to place the interests of clients first;
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 13
▪
▪
▪
▪
The requirement that all personal securities transactions be conducted in such a manner as to be
consistent with the Code;
The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
The fiduciary principle that information concerning the identity of security holdings and financial
circumstances of clients is confidential; and
The principle that independence in the investment decision-making process is paramount.
A copy of FFO’s Code of Ethics is available upon request to our firm at (855) 540-0400 or by email at
ron@freedomfamilyoffice.com.
Recommendations Involving Material Financial Interests
FFO anticipates, in appropriate circumstances and consistent with Clients investment objectives, FFO may
recommend the purchase of securities in which our affiliates, directly or indirectly, have a material financial
interest. FFO’s employees, directors, and partners often invest in these same securities. It is important to note
that investment by employees, partners, and directors do not influence pricing. Nevertheless, these relationships
pose a conflict of interest.
This conflict is mitigated by disclosures, procedures and FFO’s fiduciary obligation to place the best interest of the
Client first. In addition, FFO’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm
and/or personal holdings of its supervised persons. These reviews ensure that the personal trading of interested
persons does not disadvantage Clients of FFO. Moreover, FFO has adopted additional procedures such as limited
personal trading to certain windows in order to remove appearances of frontrunning or other unethical trading
methods. Lastly, Clients are under no obligation to invest in such partnerships.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
FFO and its supervised persons may invest in the same securities (or related securities, e.g., warrants, options or
futures) that FFO or a supervised person recommends to Clients. In order to mitigate conflicts of interest, such as
frontrunning, FFO’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm and/or
personal holdings of its supervised persons. These reviews are help ensure that the personal trading of supervised
persons does not disadvantage Clients of FFO.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts
of Interest
FFO and its supervised persons may recommend securities, or buy or sell securities for Clients accounts, at or
about the same time, that they also buy or sell the same securities in their own account(s). In order to mitigate
conflicts of interest, such as frontrunning, FFO’s Chief Compliance Officer, or their designee, will no less than
quarterly, review firm and/or personal holdings of its supervised persons. These reviews ensure that the personal
trading of supervised persons does not disadvantage Clients of FFO.
Brokerage Practices - Item 12
FFO recommends that you establish brokerage accounts with LPL Financial LLC (“LPL”) or Charles Schwab & Co.,
Inc. (“Schwab”), which are registered broker-dealers and members of SIPC, to maintain custody of assets and to
effect trades. Factors which FFO considers in recommending LPL or Schwab to Clients include their respective
financial strength, reputation, execution, pricing, research and service. LPL and Schwab enable FFO to obtain
many mutual funds without transaction charges and other securities at nominal transaction charges. The
commissions and/or transaction fees charged by LPL or Schwab may be higher or lower than those charged by
other Financial Institutions.
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 14
Broker-dealers charge account holders transaction related fees for securities trades. They provide FFO assistance
in managing and administering Clients’ accounts. These include access to Client account data, facilitate trade
execution, provide research, and facilitate payment of FFO management fees from its Clients’ accounts,
recordkeeping, and Client reporting.
In choosing a broker-dealer or negotiating commission rates, we are not obligated to seek competitive bids or the
lowest commission cost to you; but we determine that the commission rate charged is reasonable based on the
quality of custodial services available to our Clients. As a fiduciary, FFO endeavors to act in your best interest.
The commissions paid by FFO’s Clients comply with FFO’s duty to obtain “best execution.” Clients may pay
commissions that are higher than another qualified Financial Institution might charge to effect the same
transaction where FFO determines that the commissions are reasonable in relation to the value of the brokerage
and research services received. In seeking best execution, the determinative factor is not the lowest possible
cost, but whether the transaction represents the best qualitative execution, taking into consideration the full
range of a Financial Institution’s services, including among others, the value of research provided, execution
capability, commission rates, and responsiveness. FFO seeks competitive rates but may not necessarily obtain
the lowest possible commission rates for Client transactions.
Research and Soft Dollar Benefits
FFO receives soft dollar benefits from the broker-dealer such as research (or other products or services). Since
FFO generally does not have to pay for these products or services, FFO has an incentive to recommend a broker-
dealer based on FFO’s interest in receiving the research or other products or services, rather than the Client’s
interest in receiving the most favorable execution. FFO uses these benefits to service all Client accounts.
Custodians provide FFO with access to its institutional trading and custody services, which are typically not
available to retail investors. Services include brokerage, custody, research, and access to mutual funds and other
investments that are otherwise generally available only to institutional investors or require a significantly higher
minimum initial investment.
Custodians also provide FFO other services intended to help us manage and further develop our business
enterprise. These services may include consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance, and marketing.
This conflict is mitigated by disclosures, procedures and FFO’s fiduciary obligation to place the best interest of our
Client first.
Brokerage for Client Referrals
FFO does not receive Client referrals from the custodian in exchange for using the broker-dealer.
Directed Brokerage
FFO does not generally accept directed brokerage arrangements (when a Client requires that account transactions
be effected through a specific broker-dealer). However, FFO does allow for Client directed brokerage in certain
situations. Such situations may affect FFO’s ability to negotiate commissions with the resulting inability to obtain
volume discounts or best execution for Client directed accounts in some transactions. Therefore, a Client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on
transactions for the account than would otherwise be the case should the Client elect to trade through the broker-
dealer FFO recommends.
Aggregation Trading for Multiple Client Accounts
While individual Client advice is provided to each account, Client trades can be executed as a block trade. The
executing broker will be informed that the trades are for the account of FFO’s Clients and not for FFO itself. No
advisory account within the block trade will be favored over any other advisory account, and thus, each account
will participate in an aggregated order at the average share price and receive the same commission rate. The
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 15
aggregation should, on average, reduce slightly the costs of execution. We will not aggregate a Client’s order if in
a particular instance we believe that aggregation would cause the Client’s cost of execution to be increased. The
broker dealer will be notified of the amount of each trade for each account. FFO and/or its Associated Persons
may participate in block trades with Clients, and may also participate on a pro rata basis for partial fills, but only
after the determination has been made that Clients will receive fair and equitable treatment.
Review of Accounts - Item 13
Frequency and Nature of Periodic Review and Who Makes Those Reviews
FFO monitors client account holdings on a continuous basis and conducts formal account reviews at least annually.
Accounts are reviewed by the Associated Person assigned to the account. Reviews of Client accounts include, but
are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment
time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an
opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Reviews may be
conducted in person, over the phone, or via internet-based video conference call services, such as ZOOM.
Financial plans are updated as requested by the Client and pursuant to a new or amended agreement, FFO
suggests updating at least annually.
Factors That Will Trigger a Non-Periodic Review of Client Accounts
Additional reviews may be offered in certain circumstances. Triggering factors that may stimulate additional
reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation
or investment objectives, or upon client request.
Content and Frequency of Regular Reports
Clients will receive statements directly from their account custodian(s) at least quarterly. FFO may also provide
performance reports on an as needed basis. Clients are strongly encouraged to compare the reports provided by
FFO with the custodial statements.
Client Referrals and Other Compensation - Item 14
FFO may enter into agreements with individuals and organizations, which may be affiliated or unaffiliated with
FFO, that refer Clients to FFO in exchange for compensation. All such agreements will be in writing and comply
with the requirements of Federal or State regulation. If a Client is introduced to FFO by a solicitor, FFO may pay
that solicitor a fee. While the specific terms of each agreement may differ, generally, the compensation will be a
flat fee per referral, or a percentage of the introduced capital. Any such fee shall be paid solely from FFO’s
investment management fee and shall not result in any additional charge to the Client.
Each prospective Client who is referred to FFO under such an arrangement will receive a separate written
disclosure document disclosing the nature of the relationship between the solicitor and FFO.
Custody - Item 15
All assets are held at qualified custodians, which means the custodians provide account statements directly to
Clients at least quarterly. Clients are urged to compare the account statements received directly from their
custodians to any documentation or reports prepared by FFO.
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 16
FFO is deemed to have limited custody because advisory fees are directly deducted from Client’s accounts by the
custodian on behalf of FFO. FFO will obtain written authorization from Client to allow for such deductions.
FFO also has limited custody due to having standing letters of authorization (“SLOA”) to direct third party
payments. FFO will meet the following seven conditions when a SLOA has been established with a Client to be
exempted from the annual audit requirement:
1. The Client provides instructions to the qualified custodian, in writing, that includes the Client’s
signature, the third party’s name, and either the third party’s address or the third party’s
account number at a custodian to which the transfer will be directed.
2. The Client authorizes the investment advisor, in writing, either on the qualified custodian’s form
or separately, to direct transfers to the third party either on a specified schedule or from time
to time.
3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a
signature review or other method to verify the Client’s authorization, and provides a transfer of
funds notice to the Client promptly after each transfer.
4. The Client has the ability to terminate or change the instruction to the Client’s qualified
custodian.
5. The investment advisor has no authority or ability to designate or change the identity of the
third party, the address, or any other information about the third party contained in the Client’s
instruction.
6. The investment advisor maintains records showing that the third party is not a related party of
the investment advisor or located at the same address as the investment advisor.
7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
FFO is not affiliated with the custodian. The custodian does not supervise FFO, its employees or activities.
Investment Discretion - Item 16
FFO offers Portfolio Management Services on a discretionary basis. Client will authorize FFO discretionary
authority, via the Advisory Agreement, to determine, without obtaining specific Client consent, the securities to
be bought or sold, and the amount of the securities to be bought or sold.
FFO allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar
document. These restrictions must be provided to FFO in writing.
The Client approves the custodian to be used and the commission rates paid to the custodian. FFO does not
receive any portion of the transaction fees or commissions paid by the Client to the custodian.
Voting Client Securities - Item 17
Clients will receive proxy voting information directly from the issuer and/or custodian of the security. Clients will
not receive any such proxy voting material from FFO. When assistance on voting proxies is requested by the Client,
FFO will provide recommendations to the Client. However, FFO will not have authority to vote proxies on behalf
of the Client. If in the future FFO obtains authority to vote proxies, this Brochure will be appropriately amended.
Clients may contact FFO at (855) 540-0400 or by emailing ron@freedomfamilyoffice.com.
Freedom Family Office, LLC
Form ADV Part 2 Brochure
Page 17
Financial Information - Item 18
Balance Sheet
FFO does not require nor solicit prepayment of more than $1,200 in fees per Client, six months or more in
advance.
Financial Condition
FFO nor its management persons have any financial conditions that are likely to reasonably impair its ability to
meet contractual commitments to Clients.
Bankruptcy Petitions in Previous Years
FFO has not been the subject of a bankruptcy petition in the last ten years.