Overview
- Total Firm Assets
- $119 million
- Average High-Net-Worth Client Portfolio Size
- $2.7 million
Fee Structure
Primary Fee Schedule (ADV2A & 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.60% |
| $5,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $34,000 | 0.68% |
| $10 million | $49,000 | 0.49% |
| $50 million | $169,000 | 0.34% |
| $100 million | $319,000 | 0.32% |
Clients
- High-Net-Worth Share of Firm Assets
- 49.73%
- Number of High-Net-Worth Clients
- 22
- Total Client Accounts
- 95
- Discretionary Accounts
- 95
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 330875
Primary Brochure: ADV2A & 2B (2026-06-10)
View Document Text
D I S C L O S U R E B RO C HU R E
Item 1 Cover Page
F O R M AD V P A R T 2 A
Freedom Value Partners, LLC
Office Address:
10013 Falcon Valley Drive
Lenexa, KS 66220
Tel:
913-558-2054
Email:
bmcclain@freedomvaluepartners.com
Website:
www.freedomvaluepartners.com
June 2026
This brochure provides information about the qualifications and business
practices of Freedom Value Partners, LLC. Being registered as an investment
adviser does not imply a certain level of skill or training. If you have any questions
about the contents of this brochure, please contact us at 913-558-2054. The
information in this brochure has not been approved or verified by the United
A D D I T I ON A L I N F O R M A T IO N A B O U T FR E E D O M V A LUE
States Securities and Exchange Commission, or by any state securities authority.
PA R T N E R S , L L C ( C R D # 3 3 0 8 7 5 ) I S A V A I L A B L E O N T H E S E C ’ S
W EB SI T E A T HTTP://WWW.ADVISERINFO.SEC.GOV
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Freedom Value Partners, LLC has made the following material change since the last annual
amendment filing on February 13, 2026:
•
•
•
The firm has initiated the transition to federal registration with the U.S. Securities and
Exchange Commission.
The firm has updated its assets under management and advisement in Item 4.
The firm has disclosed the use of Schwab’s Prime Brokerage Services in Items 12 and 16.
ii
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 2: Material Changes .................................................................................................................... ii
Annual Update .................................................................................................................................................................... ii
Item 3: Table of Contents ................................................................................................................... iii
Material Changes since the Last Update ................................................................................................................... ii
Item 4: Advisory Business ................................................................................................................... 6
Firm Description ................................................................................................................................................................ 6
Types of Advisory Services ............................................................................................................................................ 6
Client Tailored Services and Client Imposed Restrictions ................................................................................ 7
Wrap Fee Programs .......................................................................................................................................................... 7
Client Assets Under Management ............................................................................................................................... 8
Item 5: Fees and Compensation ......................................................................................................... 8
Client Assets Under Advisement………………………………………………………………………………………………………...8
Method of Compensation and Fee Schedule ........................................................................................................... 8
Client Payment of Fees .................................................................................................................................................... 9
Additional Client Fees Charged .................................................................................................................................... 9
Prepayment of Client Fees ............................................................................................................................................. 9
Item 6: Performance-Based Fees and Side-by-Side Management ....................................... 10
External Compensation for the Sale of Securities to Clients ............................................................................ 9
Item 7: Types of Clients ..................................................................................................................... 10
Sharing of Capital Gains ............................................................................................................................................... 10
Description........................................................................................................................................................................ 10
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ............................... 10
Account Minimums ........................................................................................................................................................ 10
Methods of Analysis ...................................................................................................................................................... 10
Investment Strategy .......................................................................................................................................................10
Item 9: Disciplinary Information ................................................................................................... 13
Security Specific Material Risks .................................................................................................................................10
Criminal or Civil Actions .............................................................................................................................................. 13
Administrative Enforcement Proceedings ........................................................................................................... 13
Self- Regulatory Organization Enforcement Proceedings .............................................................................. 13
iii
Item 10: Other Financial Industry Activities and Affiliations ................................................ 13
Broker-Dealer or Representative Registration ...................................................................................................... 13
Futures or Commodity Registration .......................................................................................................................... 13
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ..................... 13
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................... 13
Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal
Trading…………………………………………………………………………………………………………………………...14
Code of Ethics Description ............................................................................................................................................. 14
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest ...... 14
Item 12: Brokerage Practices ............................................................................................................ 15
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ...... 14
Factors Used to Select Broker-Dealers for Client Transactions ...................................................................... 15
Item 13: Review of Accounts ............................................................................................................ 17
Aggregating Securities Transactions for Client Accounts ................................................................................. 17
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 17
Review of Client Accounts on Non-Periodic Basis ............................................................................................ 17
Item 14: Client Referrals and Other Compensation ................................................................. 18
Content of Client Provided Reports and Frequency ......................................................................................... 17
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 18
Item 15: Custody .................................................................................................................................. 18
Advisory Firm Payments for Client Referrals ..................................................................................................... 18
Item 16: Investment Discretion ...................................................................................................... 20
Account Statements ....................................................................................................................................................... 18
Item 17: Voting Client Securities .................................................................................................... 20
Discretionary Authority for Trading ....................................................................................................................... 20
Item 18: Financial Information ....................................................................................................... 21
Proxy Votes ....................................................................................................................................................................... 20
Balance Sheet ................................................................................................................................................................... 21
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 21
Item 19: Requirements for State Registered Advisors ........................................................... 21
Bankruptcy Petitions during the Past Ten Years ............................................................................................... 21
iii
Principal Executive Officers and Management Persons .................................................................................. 21
Outside Business Activities ........................................................................................................................................ 21
Performance Based Fee Description ....................................................................................................................... 21
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving
Management Persons ................................................................................................................................................... 21
Material Relationship Maintained by this Advisory Business or Management persons with
Kansas Specific Requirement .......................................................................................................... 22
Issuers of Securities ....................................................................................................................................................... 22
Brochure Supplement (Part 2B of Form ADV) ........................................................................... 23
Professional Liability Insurance ............................................................................................................................... 22
Principal Executive Officer – Billie McClain, CFA ............................................................................................... 24
Item 2 - Educational Background and Business Experience ......................................................................... 24
Item 3 - Disciplinary Information ............................................................................................................................ 24
Item 4 - Other Business Activities ............................................................................................................................ 25
Item 5 - Additional Compensation ........................................................................................................................... 25
Item 6 - Supervision ...................................................................................................................................................... 25
Brochure Supplement (Part 2B of Form ADV) ........................................................................... 27
Item 7 - Requirements for State-Registered Advisors ..................................................................................... 26
Principal Executive Officer – Vicki Hohenstein, CFA ........................................................................................ 28
Item 2 - Educational Background and Business Experience ......................................................................... 28
Item 3 - Disciplinary Information ............................................................................................................................ 28
Item 4 - Other Business Activities ............................................................................................................................ 29
Item 5 - Additional Compensation ........................................................................................................................... 29
Item 6 - Supervision ...................................................................................................................................................... 30
Item 7 - Requirements for State-Registered Advisors ..................................................................................... 30
iii
Item 4: Advisory Business
Firm Description
Types of Advisory Services
Freedom Value Partners, LLC (“Freedom Value Partners”) was founded in 2022 and became
registered to offer investment advisory services in 2024. Billie McClain and Vicki Hohenstein
are co-owners with a combined investment management experience of over 65 years.
ASSET MANAGEMENT
Freedom Value Partners provides discretionary asset management services to advisory
Clients. Freedom Value Partners will offer Clients ongoing asset management services
through determining individual investment goals, time horizons, objectives, and risk
tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring,
and the overall investment program will be based on the above factors. The Client will
authorize Freedom Value Partners discretionary authority to execute selected investment
transactions as stated within the Investment Advisory Agreement.
As part of the recommendations provided, the Client may have a financial plan completed as
needed. This may include but is not limited to a review of all applicable topics such as Wills,
Estate Plans and Trusts, Investments, Taxes, Qualified Plans, Insurance, Retirement Income,
Social Security, and College Planning.
During the financial planning process or when requested by a Client, Freedom Value Partners
may review and provide consultations regarding non-managed assets or other Client-held
investments on a limited basis to establish a complete understanding of the Client’s financial
situation. These investment consulting services include the option of providing Clients with
portfolio reviews and investment recommendations for the non-managed Client accounts or
assets.
Freedom Value Partners' services for non-managed Client accounts and/or assets are limited
to providing investment consultation. The firm will not be listed with the qualified custodian
of any non-managed accounts or other Client-held investments as the advisor of record and
will not continuously supervise the specified non-managed Client accounts or assets nor
have any trading authority to instruct the qualified custodian or a broker-dealer to buy, sell,
liquidate, redeem, or transfer assets over the specified non-managed Client accounts or
assets. Clients are solely responsible for making investment decisions and/or implementing
any advice provided by Freedom Value Partners for the non-managed Client accounts or
assets, including placing trades with the qualified custodian.
The Client is under no obligation to act upon Freedom Value Partners’ financial planning and
consulting recommendations related to non-managed assets. If the Client elects to act on any
of the recommendations, the Client is under no obligation to affect the transaction through
Freedom Value Partners.
Financial planning and investment consulting are available to asset management Clients at
no additional cost to the Client.
ASSET ADVISEMENT SERVICES
not
On a limited basis, Freedom Value Partners may provide asset advisement services, which
includes on-going reviews, active monitoring, consulting and recommendations on Client
accounts or assets with regard to buying, selling, reinvesting, or holding securities, cash or
include investment
other investments; however our asset advisement services will
6
discretion or trading authority. Clients authorize the qualified custodian(s) of the specified
Client accounts or assets to provide Freedom Value Partners with online information
(viewing only) about accounts and investments listed under the specified Client accounts or
assets. This authority is limited to view-only access and does not give Freedom Value
Partners the authority to place trades on behalf of Clients or request a distribution or
withdrawal of funds from the specified Client accounts or assets.
not
Client Tailored Services and Client Imposed Restrictions
This service is appropriate for accounts that cannot be managed by our firm through Asset
Management services described in the preceding paragraphs. For example, Clients that have
accounts that cannot be moved to our preferred custodian may consider this service if they
would like us to provide reviews of the account. For these accounts, we are not “Investment
have trading authority on the Account. We will
Advisor” of record and therefore we do
not have any authority or ability to implement our recommendations. All final decisions to
accept or reject our advice and whether to implement our advice are the responsibility of the
Client. The Client will maintain the sole responsibility for implementing any recommended
transactions.
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Clients may impose, in
writing, restrictions on our investment advice and recommendations, including investing in
certain types of securities, specific investments and sectors to be excluded. Clients are
entitled to change these restrictions, special instructions, and limitations at any time by
giving written notice to Freedom Value Partners.
Clients are responsible for notifying us of any updates regarding their financial situation, risk
tolerance or investment objectives and whether they wish to impose or modify existing
investment restrictions; however, we will contact Clients at least annually to discuss any
changes or updates regarding their financial situation, risk tolerance or investment
objectives.
Wrap Fee Programs
It is important that Clients understand that we manage investments for other Clients and may
give them advice or take actions for them or for our personal accounts that is different from
the advice we provide to our Clients or actions taken for them. We are not obligated to buy,
sell, or recommend to Clients any security or other investment that we may buy, sell, or
recommend for any other Clients or for our own accounts. Conflicts may arise in the allocation
of investment opportunities among accounts that we manage. We strive to allocate investment
opportunities believed to be appropriate for Client accounts advised by our firm among such
accounts equitably and consistent with the best interests of all accounts involved. However,
there can be no assurance that a particular investment opportunity that comes to our attention
will be allocated in any particular manner. If we obtain material, non-public information about
a security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any Client or use it for any Client’s benefit.
Freedom Value Partners does not sponsor any wrap fee programs.
7
Client Assets Under Management
Freedom Value Partners has the following Client assets under management:
Discretionary Amounts:
Non-discretionary Amounts:
Date Calculated:
Client Assets Under Advisement
$119,149,107
$0
May 31, 2026
Freedom Value Partners has the following Client assets under advisement:
Non-Discretionary Amounts:
Date Calculated:
$2,604,231
May 31, 2026
Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT AND ADVISEMENT SERVICES
Fees charged for Asset Management and Advisement Services are based on the total assets
under management as follows:
Annual Fee
1.00%
0.60%
Monthly Fee
.0833%
.0500%
0.30%
.0250%
Assets Under Management
First $1,000,000 ($0-$1,000,000)
Your next $4,000,000
($1,000,000.01 - $5,000,000)
Subsequent amounts
($5,000,000.01+)
For example (based on monthly billing period)
This is a tiered/blended fee schedule, the asset management fee is calculated by applying
different rates to different portions of the portfolio. Freedom Value Partners may group
certain related Client accounts for the purposes of determining the annualized fee.
:
Client with $2,500,000 under management would pay $1,583.00 on a monthly basis.
AUM/AUA
Monthly fee
Total
First $1,000,000
x 0.0833% =
$833.00
Next $1,500,000
x 0.0500% =
$750.00
Grand total for the month
$1,583.00
The annual fee is negotiable. Unless expressly excluded, Freedom Value Partners calculates
the advisory fee against all assets in the Client account including cash and equivalents. Fees
are billed monthly in advance (unless a different time period is agreed upon) based on the
amount of assets managed as of the close of business on the last business day of the previous
month.
Fees charged for our investment advisory services are negotiable, and the Adviser may, in its
discretion, offer fee discounts or waive advisory fees in whole or in part under certain
circumstances. Fee arrangements may vary based on a number of factors, including, but not
limited to: historical relationship, the nature and extent of the client’s relationship with the
8
investment adviser representative; the complexity of the client’s financial circumstances; the
composition of the client’s account (for example, individual securities versus mutual funds
or other pooled investment vehicles); the anticipated level of investment management and
ongoing advisory services required; the potential for additional assets or accounts to be
placed under management; the overall client relationship; and the total amount of assets
under management with the Adviser.
Client Payment of Fees
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. After the initial five (5) business days,
the agreement may be terminated by Freedom Value Partners with thirty (30) days written
notice to Client and by the Client at any time with written notice to Freedom Value Partners.
No fee adjustment will be made for account deposits and/or withdrawals during a billing
period. For accounts opened or closed mid-billing period, fees will be prorated based on the
days services are provided during the given period. All unpaid earned fees will be due to
Freedom Value Partners. Additionally, all unearned fees will be refunded to the Client. Client
shall be given thirty (30) days prior written notice of any increase in fees. Any increase in
fees will be acknowledged in writing by both parties before any increase in said fees occurs.
•
Fees for asset management services are:
•
Deducted from the Client account. The Client must consent in advance to direct
debiting of the investment account.
•
Deducted from an alternate non-qualified account managed by Freedom Value
Partners as directed by the Client.
Under special circumstances, Clients may be billed via invoice on a quarterly basis,
or at an interval mutually agreed upon.
Additional Client Fees Charged
Prepayment of Client Fees
Custodians may charge transaction fees and other related costs on the purchases or sales of
mutual funds, equities, bonds, options, and exchange-traded funds. Mutual funds, money
market funds, and exchange-traded funds also charge internal management fees, which are
disclosed in the fund’s prospectus. Freedom Value Partners does not receive any
compensation from these fees. All of these fees are in addition to the management fee you
pay to Freedom Value Partners. For more details on the brokerage practices, see Item 12 of
this brochure.
Freedom Value Partners does not require any prepayment of fees of more than $500 per
Client and six months or more in advance.
Investment management fees are billed monthly in advance unless a different time period is
agreed upon.
External Compensation for the Sale of Securities to Clients
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to Freedom Value Partners.
Freedom Value Partners does not receive any external compensation for the sale of securities
to Clients, nor do any of the investment advisor representatives of Freedom Value Partners.
9
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Freedom Value Partners does not use a performance-based fee structure because of the
conflict of interest. Performance based compensation may create an incentive for Freedom
Value Partners to recommend an investment that may carry a higher degree of risk to the
Client.
Item 7: Types of Clients
Description
Account Minimums
Freedom Value Partners generally provides investment advice to individuals, high net worth
individuals, trusts, estates, charitable organizations, corporations, or business entities. Client
relationships vary in scope and length of service.
Freedom Value Partners does not require a minimum to open or maintain an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Fundamental, bottom-up analysis- We strive to have a clear and in-depth understanding of
assets in which we invest. Our approach is focused on defining the upside potential as well
as the downside risk of investments under consideration.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market value will fail to reach expectations of perceived value.
Sources of information include annual reports, SEC filings, company press releases, financial
publications, research reports prepared by others, internet research, Morningstar mutual
fund and stock information, Valueline stock and industry information.
We do not use artificial intelligence applications for investment decisions. We will continue
to evaluate how artificial intelligence may help support information gathering and
investment research.
Investment Strategy
Investing in securities involves risk of loss that Clients should be prepared to bear. Past
performance is not a guarantee of future returns.
The investment strategy for a specific Client is based upon the objectives stated by the Client
during consultations. The Client may change these objectives at any time by providing
written notice to Freedom Value Partners. An Investment Policy Statement form that
documents their objectives and their desired investment strategy will be maintained in each
Client file.
Other strategies may include long-term purchases, short-term purchases, trading, and
Security Specific Material Risks
covered call option writing.
All investment programs have certain risks that are borne by the investor. Our investment
10
approach constantly keeps the risk of loss in mind. Investors face the following investment
• Market Risk
risks and should discuss these risks with Freedom Value Partners:
•
: The prices of securities in which Clients invest may decline in response to
certain events taking place around the world, including those directly involving the
companies whose securities are owned by a fund; conditions affecting the general
economy; overall market changes; local, regional or global political, social or economic
instability; and currency, interest rate and commodity price fluctuations. Investors
should have a long-term perspective and be able to tolerate potentially sharp declines in
Interest-rate Risk
market value.
•
: Fluctuations in interest rates may cause investment prices to fluctuate.
For example, when interest rates rise, yields on existing bonds become less attractive,
Inflation Risk
causing their market values to decline.
: When any type of inflation is present, a dollar today will buy more than a
• Currency Risk
dollar next year, because purchasing power is eroding at the rate of inflation.
: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
• Reinvestment Risk
exchange rate risk.
• Liquidity Risk
: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates
to fixed income securities.
• Management Risk:
: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties are
not.
• Equity Risk:
The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class
or fund are not realized in the expected time frame, the overall performance of the
Client’s portfolio may suffer.
• Fixed Income Risk:
Equity securities tend to be more volatile than other investment choices. The
value of an individual mutual fund or ETF can be more volatile than the market as a
whole. This volatility affects the value of the Client’s overall portfolio. Small- and mid-
cap companies are subject to additional risks. Smaller companies may experience greater
volatility, higher failure rates, more limited markets, product lines, financial resources,
and less management experience than larger companies. Smaller companies may also
have a lower trading volume, which may disproportionately affect their market price,
tending to make them fall more in response to selling pressure than is the case with larger
companies.
The issuer of a fixed income security may not be able to make interest
and principal payments when due. Generally, the lower the credit rating of a security, the
greater the risk that the issuer will default on its obligation. If a rating agency gives a debt
security a lower rating, the value of the debt security will decline because investors will
demand a higher rate of return. As nominal interest rates rise, the value of fixed income
securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real
interest rate and an expected inflation rate.
11
Investment Companies Risk:
•
• Derivatives Risk:
When a Client invests in open-end mutual funds or ETFs, the
Client indirectly bears their proportionate share of any fees and expenses payable
directly by those funds. Therefore, the Client will incur higher expenses, which may be
duplicative. In addition, the Client’s overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an
underlying fund (such as the use of derivatives). ETFs are also subject to the following
risks: (i) an ETF’s shares may trade at a market price that is above or below their net
asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s
officials deem such action appropriate, the shares are de-listed from the exchange, or the
activation of market-wide “circuit breakers” (which are tied to large decreases in stock
prices) halts stock trading generally. Adviser has no control over the risks taken by the
underlying funds in which Client invests.
• Foreign Securities Risk:
Funds in a Client’s portfolio may use derivative instruments. The value
of these derivative instruments derives from the value of an underlying asset, currency,
or index. Investments by a fund in such underlying funds may involve the risk that the
value of the underlying fund’s derivatives may rise or fall more rapidly than other
investments, and the risk that an underlying fund may lose more than the amount that it
invested in the derivative instrument in the first place. Derivative instruments also
involve the risk that other parties to the derivative contract may fail to meet their
obligations, which could cause losses.
•
Funds in which Clients invest may invest in foreign securities.
Foreign securities are subject to additional risks not typically associated with
investments in domestic securities. These risks may include, among others, currency risk,
country risks (political, diplomatic, regional conflicts, terrorism, war, social and
economic instability, currency devaluations and policies that have the effect of limiting
or restricting foreign investment or the movement of assets), different trading practices,
less government supervision, less publicly available information, limited trading markets
and greater volatility. To the extent that underlying funds invest in issuers located in
emerging markets, the risk may be heightened by political changes, changes in taxation,
or currency controls that could adversely affect the values of these investments.
Emerging markets have been more volatile than the markets of developed countries with
more mature economies.
to purchasing power risk — the risk that your investment’s return will not keep up with
• Trading risk
inflation.
: Investing involves risk, including possible loss of principal. There is no
• Options Trading
assurance that the investment objective of any fund or investment will be achieved.
• Foreign Investment Risk
: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. Clients should be
aware that the use of options involves additional risks. The risks of covered call writing
include the potential for the market to rise sharply. In such case, the security may be
called away and the account will no longer hold the security. When purchasing options
there is the risk that the entire premium paid for the option can be lost if the option is not
exercised or otherwise sold prior to the option’s expiration date.
: Investments in foreign securities may be riskier than U.S.
investments because of factors such as, unstable international, political and economic
conditions, currency fluctuations, foreign controls on investment and currency exchange,
12
foreign governmental control of some issuers, potential confiscatory taxation or
nationalization of companies by foreign governments, withholding taxes, a lack of
adequate company information, less liquid and more volatile exchanges and/or markets,
ineffective or detrimental government regulation, varying accounting standards, political
or economic factors that may severely limit business activities, and legal systems or
market practices that may permit inequitable treatment of minority and/or non-
domestic investors. Investments in emerging markets may involve these and other
significant risks such as less mature economic structures and less developed and more
thinly-traded securities markets.
Item 9: Disciplinary Information
Criminal or Civil Actions
Administrative Enforcement Proceedings
Freedom Value Partners and its management have not been involved in any criminal or
civil action.
Self- Regulatory Organization Enforcement Proceedings
Freedom Value Partners and its management have not been involved in administrative
enforcement proceedings.
Freedom Value Partners and its management have not been involved in any self-regulatory
organizational enforcement proceedings.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Futures or Commodity Registration
Freedom Value Partners is not registered as a broker-dealer and no affiliated representatives
of Freedom Value Partners are registered representatives of a broker- dealer.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither Freedom Value Partners nor its affiliated representatives are registered or have an
application pending to register as a futures commission merchant, commodity pool operator,
or a commodity trading advisor.
not
not
and does
have a related person that is a municipal securities
Freedom Value Partners is
dealer, government securities dealer or broker, an investment company or other
pooled investment vehicle (including a mutual fund, closed-end investment company, unit
investment trust, private investment company or "hedge fund," and offshore fund), another
investment adviser or financial planner, a futures commission merchant, commodity pool
operator, or commodity trading advisor, a banking or thrift institution, an accountant or
accounting firm, a lawyer or law firm, an insurance company or agency, a pension consultant, a
real estate broker or dealer, and a sponsor or syndicator of limited partnerships.
Ms. Hohenstein is Director, Vice President, and Secretary/Treasurer of Cottonwood Flats,
Inc. She spends minimal time on this activity. This is not a conflict of interest as there will be
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
no crossover Clients.
Freedom Value Partners does not select or recommend other investment advisors.
13
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
independent
The affiliated persons (affiliated persons
contractors) of Freedom Value Partners have committed to a Code of Ethics (“Code”). The
purpose of our Code is to set forth standards of conduct expected of Freedom Value Partners
affiliated persons and addresses conflicts that may arise. The Code defines acceptable
behavior for affiliated persons of Freedom Value Partners. The Code reflects Freedom Value
Partners and its supervised persons’ responsibility to act in the best interest of their Client.
Freedom Value Partners and its supervised persons will not buy or sell securities for their
personal account(s) where their decision is derived, in whole or in part, by information
obtained as a result of employment or association with our firm unless the information is
also available to the investing public upon reasonable inquiry.
Freedom Value Partners’ policy prohibits any person from acting upon or otherwise
misusing non-public or inside information. No advisory representative or other affiliated
person, officer or director of Freedom Value Partners may recommend any transaction in a
security or its derivative to advisory Clients or engage in personal securities transactions for
a security or its derivatives if the advisory representative possesses material, non-public
information regarding the security.
Freedom Value Partners’ Code is based on the guiding principle that the interests of the
Client are our top priority. Freedom Value Partners’ officers, directors, advisors, and other
affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty
to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our
obligation to put the Client’s interests over the interests of either affiliated persons or the
company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or non-
public information regarding the portfolio holdings of any reportable fund, who are involved
in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Freedom Value Partners will provide a copy of the Code of Ethics to any Client or prospective
Client upon request.
Interest
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Freedom Value Partners and its affiliated persons do not recommend to Clients securities in
which we have a material financial interest.
Interest
Freedom Value Partners and its affiliated persons may buy or sell securities that are also
held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client
transactions, affiliated persons are required to disclose all reportable securities transactions
as well as provide Freedom Value Partners with copies of their brokerage statements.
The Chief Compliance Officer of Freedom Value Partners is Billie McClain. She reviews all
trades of the affiliated persons each quarter. The personal trading reviews ensure that the
14
personal trading of affiliated persons does not affect the markets and that Clients of the firm
receive preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Freedom Value Partners will recommend the use of a particular broker-dealer based on their
duty to seek best execution for the Client, meaning they have an obligation to obtain the most
favorable terms for a Client under the circumstances. The determination of what may
constitute best execution and price in the execution of a securities transaction by a broker
involves a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with which the
transaction is affected, the ability to effect the transaction where a large block is involved,
the operational facilities of the broker-dealer, products and services offered, reputation and
integrity, ability to maintain confidentiality, the value of an ongoing relationship with such
broker and the financial strength and stability of the broker. Freedom Value Partners will
select appropriate brokers based on a number of factors including but not limited to their
relatively low transaction fees and reporting ability. Freedom Value Partners relies on its
broker to provide its execution services at the best prices available. Lower fees for
comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by Freedom Value Partners. Freedom
Value Partners does not receive any portion of the trading fees.
• Research and Other Soft Dollar Benefits
Freedom Value Partners will recommend the use of Charles Schwab & Co., Inc. (“Schwab”), a
FINRA-registered broker-dealer, Member SIPC, to maintain custody of Clients’ assets and to effect
trades for their accounts. Freedom Value Partners is independently owned and operated and not
affiliated with Schwab.
The Securities and Exchange Commission defines soft dollar practices as arrangement
under which products or services other than execution services are obtained by
Freedom Value Partners from or through a broker-dealer in exchange for directing
Client transactions to the broker-dealer. Although Freedom Value Partners has no
formal soft dollar arrangements, Freedom Value Partners receive products, research
and/or other services from custodians or broker-dealers connected to Client
transactions or “soft dollar benefits.” As permitted by Section 28(e) of the Securities
Exchange Act of 1934, Freedom Value Partners receives economic benefits as a result
of commissions generated from securities transactions by the custodian or broker-
dealer from the accounts of Freedom Value Partners. Freedom Value Partners
receives the economic benefits without having to pay for the research, products, or
services. Freedom Value Partners cannot ensure that a particular Client will benefit
from soft dollars or the Client’s transactions paid for the soft dollar benefits. Freedom
Value Partners does not seek to proportionately allocate benefits to Client accounts
to any soft dollar benefits generated by the accounts.
A conflict of interest exists when Freedom Value Partners receives soft dollars which
could result in higher commissions charged to Clients. This conflict is mitigated by the
fact that Freedom Value Partners has a fiduciary responsibility to act in the best
interest of its Clients and the services received are beneficial to all Clients.
Schwab provides Freedom Value Partners with access to its institutional trading and
15
custody services, which are typically not available to Schwab retail investors. These
services generally are available to independent investment advisors on an unsolicited
basis, at no charge to them so long as a total of at least $10 million of the advisor’s
Clients’ assets are maintained at Schwab Institutional. These services are not
contingent upon Freedom Value Partners committing to Schwab any specific amount
of business (assets in custody or trading commissions). Schwab’s brokerage services
include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional
investors or would require significantly higher minimum initial investment.
Schwab Institutional also makes available to Freedom Value Partners other products
and services that benefit Freedom Value Partners but may not directly benefit Clients’
accounts. Many of these products and services may be used to service all or some
substantial number of Freedom Value Partners’ accounts, including accounts not
maintained at Schwab.
Schwab’s products and services that assist Freedom Value Partners in managing and
administering Clients’ accounts include software and other technology that (i) provides
access to Client account data (such as trade confirmations and account statements); (ii)
facilitate trade execution and allocate aggregated trade orders for multiple Client
accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment
of Freedom Value Partners’ fees from some of its accounts; and (v) assist with back-
office functions, recordkeeping and Client reporting.
Schwab Institutional also offers other services intended to help Freedom Value
Partners manage and further develop its business enterprise. These services may
include: (i) compliance, legal and business consulting; (ii) publications and conferences
on practice management and business succession; and (iii) access to employee benefits
providers, human capital consultants, and insurance providers. Schwab Institutional
may discount or waive fees it would otherwise charge for some of these services or pay
all or part of the fees of a third-party providing these services to Freedom Value
Partners. Schwab Institutional may also provide other benefits such as educational
events or occasional business entertainment of Freedom Value Partners’ personnel.
While as a fiduciary, Freedom Value Partners endeavors to act in its Clients’ best
interests, Freedom Value Partners’ recommendation that Clients maintain their assets
in accounts at Schwab may take into account availability of some of the foregoing
products and services and other arrangements not solely on the nature of cost or
quality of custody and brokerage services provided by Schwab, which may create a
conflict of interest.
Through its relationship with Schwab, Freedom Value Partners may also use the
Schwab Prime Brokerage Service. Prime Brokerage is a service allowing Freedom
Value Partners to place trades with other broker/dealers without the need to have
individual accounts with the other broker/dealers. The use of Prime Brokerage
allows Freedom Value Partners greater flexibility to access more fixed income
products and the ability to access new issue bonds. Prime Brokerage Service is
beneficial because it allows Freedom Value Partners to place trades through several
executing broker/dealers, yet receive centralized custody, clearing and settlement,
recordkeeping, and other services from one source, Schwab. The decision by Freedom
Value Partners to use an executing broker/dealer will depend on the executing
broker’s respective expertise and costs. All assets will be kept in a Schwab account,
16
• Brokerage for Client Referrals
with all confirmations and statements generated by Schwab.
• Directed Brokerage
Freedom Value Partners does not receive Client referrals from any custodian or third
party in exchange for using that broker-dealer or third party.
Clients who direct brokerage outside our recommendation may be unable to achieve
the most favorable execution of Client transactions as Client directed brokerage may
cost Clients more money. For example, in a directed brokerage account, you may pay
higher brokerage commissions because we may not be able to aggregate orders to
reduce transaction costs, or you may receive less favorable prices.
Aggregating Securities Transactions for Client Accounts
We consider Client accounts that are held outside of our recommended custodian to
be under our “advisement service.”
Freedom Value Partners is authorized in its discretion to aggregate purchases and sales and
other transactions made for the account with purchases and sales and transactions in the
same securities for other Clients of Freedom Value Partners. All Clients participating in the
aggregated order shall receive an average share price with all other transaction costs shared
on a pro-rated basis. If aggregation is not allowed or infeasible and individual transactions
occur (e.g., withdrawal or liquidation requests, odd-lot trades, etc.) an account may
potentially be assessed higher costs or less favorable prices than those where aggregation
has occurred.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed quarterly by the managing partners of Freedom Value
Partners, Vicki Hohenstein and Billie McClain. Account reviews are performed more
frequently when market conditions dictate. 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.
Review of Client Accounts on Non-Periodic Basis
Financial plans generated are updated as requested by the Client. Freedom Value Partners
suggests updating at least annually.
Content of Client Provided Reports and Frequency
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Clients receive written account statements monthly for managed accounts. Account
statements are issued by Freedom Value Partners’ custodian. Client receives confirmations
of each transaction in account from custodian, as well as the monthly statement.
Performance reports will be provided by Freedom Value Partners upon request to Clients
with assets under management.
17
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Advisory Firm Payments for Client Referrals
Freedom Value Partners receives additional economic benefits from external sources as
described above in Item 12.
Freedom Value Partners does not compensate for Client referrals.
Item 15: Custody
Account Statements
Custody, as it applies to investment advisors, has been defined by regulators as having access
or control over Client funds and/or securities. In other words, custody is not limited to
physically holding Client funds and securities. If an investment adviser has the ability to access
or control Client funds or securities, the investment adviser is deemed to have custody and
must ensure proper procedures are implemented.
Freedom Value Partners is deemed to have custody of Client funds and securities whenever the
firm is given the authority to have fees deducted directly from Client accounts. For accounts in
which Freedom Value Partners is deemed to have custody, we have established procedures to
ensure all Client funds and securities are held at a qualified custodian in a separate account for
each Client under that Client’s name. Clients or an independent representative of the Client,
direct in writing, the establishment of all accounts and, therefore, are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained.
Account statements are delivered directly from the qualified custodian to each Client or the
Client’s independent representative at least quarterly. Clients are urged to carefully compare
the account statements received directly from their custodians to any documentation or
reports prepared by Freedom Value Partners. When Clients have questions about their account
statements, they should contact Freedom Value Partners or the qualified custodian preparing
the statement.
Upon authorization from Clients, Freedom Value Partners can affect asset/fund transfers from
Client accounts to one or more third parties designated, in writing, by the Client without
obtaining written Client consent for each separate, individual transaction, as long as the Client
has provided us with written authorization to do so. Such written authorization is known as a
Standing Letter of Authorization ("SLOA"). An adviser with authority to conduct such third
party asset/fund transfers has access to the Client's assets, and therefore has custody of the
Client's assets in any related accounts.
The State of Kansas does not require a surprise audit for firms with custody. Freedom Value
Partners follows the safekeeping requirements in K.A.R. 81-14-9(b)(1) by:
A.
Providing Notice to the Administrator on Form ADV that the firm has or will have
custody.
B.
Maintaining Client funds and securities in a separate account for each Client under that
Client’s name, or in accounts that contain only funds and securities of the firm’s Clients
under the name of the firm as agent or trustee for each Client.
18
C.
If the firm opens an account with a qualified custodian on behalf of its Client, either under
the Client’s name or the firm’s name as agent, the firm will notify the Client in writing of
the qualified custodian’s name, address, and the manner in which the funds or securities
are maintained. The notice to the Client will be given promptly when the account is
opened and following any changes to the information.
D.
The firm will ensure that if a qualified custodian maintains the accounts containing funds
or securities, the qualified custodian sends account statements to each Client for whom
the adviser has custody of funds or securities. The firm must have a reasonable basis for
believing that the qualified custodian sends account statements at least quarterly to each
of the adviser’s Clients for whom the custodian maintains funds or securities and that the
account statement sets forth all transactions in the account during the period and
identifies the amount of funds and amount of each security in the account at the end of
the period.
Based on an SEC no-action letter, we do not have to obtain a surprise annual audit, if we
otherwise would be required to by reason of having custody, as long as we meet the
following criteria:
1. The Client provides a written, signed instruction to the qualified custodian that includes
the third party's name and address or account number at a custodian;
2. The Client authorizes us, in writing, to direct transfers to the third party either on a
specified schedule or from time to time;
3. The Client's qualified custodian verifies the authorization (e.g., signature review) and
provides a transfer of funds notice to Client promptly after each transfer;
4. The Client can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at
the same address as us; and
7. The Client's qualified custodian sends Client, in writing, an initial notice confirming the
instruction and an annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria. It should be noted that authorization to
trade in client accounts is not deemed by regulators to be custody.
Due to Freedom Value Partners’ authority to initiate disbursements, checks or transfers from
a client’s account to a third party, the firm will report on Form ADV Part 1A, Item 9.A that it
has custody of client funds and securities. Moreover, we will disclose the number of clients
and value of client funds for which we have custody due to possible third-party transfer
authorizations.
19
Item 16: Investment Discretion
Discretionary Authority for Trading
Freedom Value Partners generally manages securities accounts on behalf of Clients on a
discretionary basis. For these accounts, Freedom Value Partners has the authority 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. Freedom Value Partners’ discretionary
authority is stated within the Investment Advisory Agreement.
When providing investment advisement services, we will not have any authority and
therefore no responsibility or ability to implement our recommendations. The Client has the
sole responsibility for determining whether to implement our investment recommendations
on such and then implementing the changes to their account.
Freedom Value Partners allows Clients to place certain restrictions, as outlined in the Client’s
Investment Policy Statement or similar document. These restrictions must be provided to
Freedom Value Partners in writing.
The Client approves the custodian to be used and the commission rates paid to the custodian.
Freedom Value Partners does not receive any portion of the transaction fees or commissions
paid by the Client to the custodian.
Freedom Value Partners may elect to purchase bonds through bond broker/dealers in order
to obtain a better price for the client, and then have the bonds delivered into the client's
brokerage account. This practice is conducted through the Schwab Prime Brokerage Service.
This is the only case in which Freedom Value Partners selects a broker/dealer to be used
without specific client consent. Schwab charges the client a Prime Brokerage Service Fee per
order entered at an executing broker/dealer by Freedom Value Partners. The Prime
Brokerage Service Fee will be charged to the client’s account. Freedom Value Partners’
clients must execute the Schwab Brokerage Account Agreement - Prime Brokerage
Amendment form before Freedom Value Partners can execute trades at broker/dealers
other than Schwab that settle in the client’s Schwab account.
Item 17: Voting Client Securities
Proxy Votes
Freedom Value Partners will vote proxies on behalf of a Client if, in its investment agreement
with Freedom Value Partners, the Client has delegated to Freedom Value Partners the
authority to vote proxies on its behalf. Freedom Value Partners has adopted and
implemented policies and procedures (“Proxy Voting Procedures”) to ensure that, where it
has voting authority, proxy matters are handled in the best interest of the Clients, in
accordance with Freedom Value Partners’ fiduciary duties. Clients may elect to cast their
own vote for select proxies and are required to notify Freedom Value Partners in writing in
a timely manner.
Freedom Value Partners has adopted procedures to implement the firm's policy and
conducts reviews to monitor and ensure the firm's policy is observed, implemented
properly, and amended or updated, as appropriate. These policies and procedures, which are
maintained in a separate document available upon request, include but are not limited to,
the following:
•
•
General Policies
Disclosure to Third Parties
20
•
•
•
Proxy Voting Designee
Conflicts of Interest
Recordkeeping and Disclosure
Clients can obtain information about how their securities were voted by Freedom Value
Partners by contacting Freedom Value Partners.
Item 18: Financial Information
Balance Sheet
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
A balance sheet is not required to be provided to Clients because Freedom Value Partners
does not serve as a custodian for Client funds or securities and Freedom Value Partners does
not require prepayment of fees of more than $1,200 per Client and six months or more in
advance.
Commitments to Clients
Freedom Value Partners has no condition that is reasonably likely to impair our ability to
Bankruptcy Petitions during the Past Ten Years
meet contractual commitments to our Clients.
Freedom Value Partners has not had any bankruptcy petitions in the last ten years.
Item 19: Requirements for State Registered Advisors
Principal Executive Officers and Management Persons
Outside Business Activities
The education and business background for all management and supervised persons can be
found in the Part 2B of this Brochure.
Performance Based Fee Description
The outside business activities for all management and supervised persons can be found in
the Part 2B of this Brochure.
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving
Neither Freedom Value Partners nor its management receive performance based fees.
Please see Item 6 of the ADV 2A for more information.
Management Persons
Neither Freedom Value Partners nor its management have been involved in any of the
following:
1.
An award or otherwise been found liable in an arbitration claim alleging damages in
excess of $2,500, involving any of the following:
a.
b.
c.
d.
e.
An investment or an investment-related business or activity.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
2.
An award or otherwise been found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
a.
An investment or an investment-related business or activity.
21
Material Relationship Maintained by this Advisory Business or Management persons
b.
c.
d.
e.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
with Issuers of Securities
There are no material relationships with issuers of securities to disclose.
Kansas Specific Requirement
Professional Liability Insurance
Freedom Value Partners carries professional liability insurance coverage for its investment
advisory services. In the event that a Client or prospective Client in the State of Kansas
requests proof of professional liability insurance coverage, Freedom Value Partners will
provide a copy of the insurance agreement that is in effect within thirty (30) days.
22
S U P E R V I S E D P E R S O N B RO C HU RE
Item 1 Cover Page
F O R M AD V P A R T 2 B
Billie McClain, CFA
Freedom Value Partners, LLC
Office Address:
10013 Falcon Valley Drive
Lenexa, KS 66220
Tel:
913-558-2054
Email:
bmcclain@freedomvaluepartners.com
Website:
www.freedomvaluepartners.com
June 2026
This brochure supplement provides information about Billie McClain and
supplements the Freedom Value Partners, LLC brochure. You should have received a
copy of that brochure. Please contact Billie McClain if you did not receive the
brochure or if you have any questions about the contents of this supplement.
A D D I T I ON A L I N F O R M A T I O N A B O U T B IL L IE M C C L A IN ( C R D
# 5 9 9 5 1 7 3 ) I S A V A I L A B L E O N T H E S E C ’ S W EB S I T E AT
HTTP://WWW.ADVISERINFO.SEC.GOV
23
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Billie McClain, CFA
•
Item 2 - Educational Background and Business Experience
Year of birth: 1976
•
Educational Background:
University of Kansas; Bachelor of Science – Business Administration Finance; 1999
•
Business Experience:
•
Freedom Value Partners, LLC.; Investment Advisor Representative/Chief Compliance
Officer; 04/2024-Present
•
Freedom Value Partners, LLC.; Founder and Managing Member; 05/2022-Present
•
Freedom Wealth Advisors, LLC; Investment Advisor Representative/Senior
VP/Portfolio Manager; 05/2022-08/2024
•
Tower Wealth Managers; Investment Advisor Representative; 11/2011-12/2021
Country Club Trust Company; Senior Vice President-Portfolio Manager; 9/2011-
05/2022
Professional Certifications
Billie McClain has earned certifications and credentials that are required to be explained in
further detail.
•
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by
the CFA Institute. CFA certification requirements:
•
•
•
•
Item 3 - Disciplinary Information
Hold a bachelor’s degree from an accredited institution or have equivalent
educational or work experience.
Successful completion of all three exam levels of the CFA Program.
Have 48 months of acceptable professional work experience in the investment
decision-making process.
Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
Agree to adhere to and sign the Member’s Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
A.
Ms. McClain has never been involved in a criminal or civil action in a domestic, foreign,
or military court of competent jurisdiction for which she:
a.
Was convicted of or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business,
fraud, false statement or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses.
b.
Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements, or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses.
24
c.
Was found to have been involved in a violation of an investment-related statute
or regulation; or
d.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B.
Ms. McClain never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which she:
a.
Was found to have caused an investment-related business to lose its authorization to
do business, or the subject of an order by the agency or authority.
b.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority.
a.
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C.
Ms. McClain has never been the subject of a self-regulatory organization (SRO)
proceeding in which she:
a.
Was found to have caused an investment-related business to lose its authorization
to do business; or
b.
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D.
Item 4 - Other Business Activities
Ms. McClain has not been involved in any other hearing or formal adjudication in which
a professional attainment, designation, or license of the supervised person was revoked
or suspended because of a violation of rules relating to professional conduct.
Billie McClain receives no additional compensation for providing advisory services other than
Item 5 - Additional Compensation
advisory fees described in Item 5 of the firm’s Disclosure Brochure.
Ms. McClain does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is disclosed in
Item 6 - Supervision
Item 5 of Part 2A.
Ms. McClain is the Chief Compliance Officer of Freedom Value Partners. The Managing
Partners are responsible for all supervision and monitoring of investment advice offered to
Clients. She will adhere to the policies and procedures as described in the firm’s Compliance
Manual. She can be reached at bmcclain@freedomvaluepartners.com or 913-558-2054.
25
Item 7 - Requirements for State-Registered Advisors
A.
Ms. McClain has not been involved in any of the following:
1.
An award or otherwise been found liable in an arbitration claim alleging damages in
excess of $2,500 involving any of the following:
i.
ii.
iii.
iv.
v.
An investment or an investment-related business or activity.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
2.
An award or otherwise been found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
i.
ii.
iii.
iv.
v.
An investment or an investment-related business or activity.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
B.
Ms. McClain has never been the subject of a bankruptcy petition.
26
S U P E R V I S E D P E R S O N B RO C HU RE
Item 1 Cover Page
F O R M AD V P A R T 2 B
Vicki Hohenstein, CFA
Freedom Value Partners, LLC
Office Address:
10013 Falcon Valley Drive
Lenexa, KS 66220
Tel:
402-707-5099
Email:
vhohenstein@freedomvaluepartners.com
Website:
www.freedomvaluepartners.com
June 2026
This brochure supplement provides information about Vicki Hohenstein and
supplements the Freedom Value Partners, LLC brochure. You should have received a
copy of that brochure. Please contact Vicki Hohenstein if you did not receive the
brochure or if you have any questions about the contents of this supplement.
A D D I T I ON A L I N F O R M A T I O N A B O U T V IC K I H OH E N S T E IN
( C R D # 8 6 6 9 3 3 ) I S A V A I L A B L E O N T H E S E C ’ S W E B SI T E A T
HTTP://WWW.ADVISERINFO.SEC.GOV
27
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Vicki Hohenstein, CFA
•
Item 2 - Educational Background and Business Experience
Year of birth: 1955
•
Educational Background:
•
University of Nebraska – Omaha; Master of Business Administration – Finance; 1983
University of Nebraska – Lincoln; Bachelor of Science – Business Administration
Accounting; 1978
•
Business Experience:
•
Freedom Value Partners, LLC.; Investment Advisor Representative; 04/2024-Present
•
Cottonwood Flats, Inc; Director and Secretary/Vice President/Treasurer; 12/2023-
Present
•
Freedom Value Partners, LLC.; Founder and Managing Member; 05/2022-Present
•
Freedom Wealth Advisors, LLC; Investment Advisor Representative; 05/2022-
08/2024
•
Tower Wealth Managers; Investment Advisor Representative; 04/2008-12/2021
Country Club Trust Company; Senior Vice President – Portfolio Manager; 11/2007-
05/2022
Professional Certifications
Vicki Hohenstein has earned certifications and credentials that are required to be explained
in further detail.
•
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded by
the CFA Institute. CFA certification requirements:
•
•
•
•
Item 3 - Disciplinary Information
Hold a bachelor’s degree from an accredited institution or have equivalent
educational or work experience.
Successful completion of all three exam levels of the CFA Program.
Have 48 months of acceptable professional work experience in the investment
decision-making process.
Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
Agree to adhere to and sign the Member's Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
A.
Ms. Hohenstein has never been involved in a criminal or civil action in a domestic, foreign,
or military court of competent jurisdiction for which she:
a.
Was convicted of or pled guilty or nolo contender (“no contest”) to (a) any felony;
(b) misdemeanor that involved investments or an investment-related business, fraud,
false statement, or omissions, wrongful taking of property, bribery, perjury,
counterfeiting, or extortion; or (c) a conspiracy to commit any of these offenses.
28
b.
Is the named subject of a pending criminal proceeding that involves an investment-
related business, fraud, false statements, or omissions, wrongful taking of property,
bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of
these offenses.
c.
Was found to have been involved in a violation of an investment-related statute or
regulation; or
d.
Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related activity,
or from violating any investment-related statute, rule, or order?
B.
Ms. Hohenstein never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which she:
a.
Was found to have caused an investment-related business to lose its authorization to
do business, or the subject of an order by the agency or authority.
b.
Was found to have been involved in a violation of an investment-related statute or
regulation or was the subject of an order by the agency or authority.
a.
(a)denying, suspending or revoking the authorization of the supervised person to
act in an investment-related business; (b) barring or suspending his association
with an investment-related business; (c) otherwise significantly limiting his
investment-related activities; or (d) imposing a civil money penalty of more than
$2,500 on him.
C.
Ms. Hohenstein has never been the subject of a self-regulatory organization (SRO)
proceeding in which she:
a.
Was found to have caused an investment-related business to lose its authorization
to do business; or
b.
Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D.
Item 4 - Other Business Activities
Ms. Hohenstein has not been involved in any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional conduct.
Item 5 - Additional Compensation
Ms. Hohenstein is Director, Vice President, and Secretary/Treasurer of Cottonwood Flats,
Inc. She spends minimal time on this activity. This is not a conflict of interest as there will be
no crossover Clients.
Ms. Hohenstein does not receive any performance-based fees and does not receive any
additional compensation for performing advisory services other than what is disclosed in
Item 5 of Part 2A.
29
Item 6 - Supervision
Item 7 - Requirements for State-Registered Advisors
Billie McClain is the Chief Compliance Officer of Freedom Value Partners. Billie McClain
reviews Vicki Hohenstein’s work through Client account reviews and quarterly personal
transaction reports, as well as face-to-face and phone interactions. Billie McClain can be
reached at bmcclain@freedomvaluepartners.com or 913-558-2054.
A.
Ms. Hohenstein has not been involved in any of the following:
1.
An award or otherwise been found liable in an arbitration claim alleging damages in
excess of $2,500 involving any of the following:
i.
ii.
iii.
iv.
v.
An investment or an investment-related business or activity.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
2.
An award or otherwise been found liable in a civil, self-regulatory organization, or
administrative proceeding involving any of the following:
i.
ii.
iii.
iv.
v.
An investment or an investment-related business or activity.
Fraud, false statement(s), or omissions.
Theft, embezzlement or other wrongful taking of property.
Bribery, forgery, counterfeiting, or extortion.
Dishonest, unfair, or unethical practices.
B.
Ms. Hohenstein has never been the subject of a bankruptcy petition.
4930-7877-1891, v. 4
30