Form ADV Part 2

Last Updated April 28, 2023

This brochure provides information about the qualifications and business practices of Freeman Capital Advisors,  LLC. If you have any questions about the contents of this brochure, please contact us at (336) 914-0888 or by  email at: The information in this brochure has not been approved or verified by  the United States Securities and Exchange Commission or by any state securities authority. Additional information about Freeman Capital Advisors, LLC is also available on the SEC’s website at Freeman Capital Advisors, LLC’s CRD number is: 300025.

2015  Ayrsley Town Blvd  Suite 202
Charlotte, NC 28273
(336) 914-0888

Registration as an investment adviser does not imply a certain level of skill or training.

Version Date 03-21-2023


Freeman Capital Advisors, LLC has the following material changes to report. Material changes relate to  Freeman Capital Advisors, LLC’s policies, practices or conflicts of interests. 

Please see the material changes since the most recent filing of Form ADV Part 2A, dated 03-25-2022. 

Freeman Capital Advisors, LLC no longer offers the Investing Plan Only service to clients. In addition, the  firm has removed the Foundation, Grind and Legacy plans. Please see Items 4 and 5 of this version of Form  ADV Part 2A for a description of services currently offered, and the fees and compensation associated with  available services.


Item 1: Cover Page 1
Item 2: Material Changes 2
Item 3: Table of Contents 3
Item 4: Advisory Business 4
Item 5: Fees and Compensation 7
Item 6: Performance-Based Fees and Side-By-Side Management 10
Item 7: Types of Clients 10
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss 10
Item 9: Disciplinary Information 13
Item 10: Other Financial Industry Activities and Affiliations 13
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 15
Item 12: Brokerage Practices 15
Item 13: Review of Accounts 18
Item 14: Client Referrals and Other Compensation 19
Item 15: Custody 19
Item 16: Investment Discretion 19
Item 17: Voting Client Securities (Proxy Voting) 20
Item 18: Financial Information 20


Capital Advisors, LLC (hereinafter “FCA”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in November 2018, and the principal owner is The Freeman Capital Management Holdings, Inc., of which Calvin Williams Jr. has majority ownership.


Investment Management Services & Financial Planning Services 

FCA offers ongoing Investment Management Services based on the individual goals, objectives, time horizon,  and risk tolerance of each client. FCA creates an Investment Policy Statement for each client, which outlines  the client’s current situation (income, tax levels, and risk tolerance levels). Investment Management Services  include, but are not limited to, the following: 

  • Investment strategy
  • Personal investment policy
  • Asset allocation
  • Asset selection
  • Risk tolerance
  • Regular investment management monitoring

FCA evaluates the current investments of each client with respect to their risk tolerance levels and time  horizon. FCA will require discretionary authority from clients in order to select securities and execute  transactions without permission from the client prior to each transaction. Risk tolerance levels are  documented in the Investment Policy Statement, which is given to each client. 

FCA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its  accounts and without consideration of FCA’s economic, investment or other financial interests. To meet its  fiduciary obligations, FCA attempts to avoid, among other things, investment or trading practices that  systematically advantage or disadvantage certain client investment managements, and accordingly, FCA’s  policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to  avoid favoring one client over another over time. It is FCA’s policy to allocate investment opportunities and  transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis  over time. 

Third-Party Managers (Outside Managers) 

FCA leverages the services of Third Party Managers, for portfolio management services. We assist Clients in  selecting an appropriate allocation model, and risk ensuring that the investment management strategy  implemented through the use of the Third Party manager is consistent with the client’s profile, investment  experience and risk tolerance. FCA periodically reviews the third party manager through the annual vendor  due diligence process. Our review process and analysis of outside managers is further discussed in Item 8 

of this Form ADV Part 2A. Additionally, FCA will meet with the Client on a periodic basis (no less than  annually), to discuss changes in their personal or financial situation, suitability, and any new or revised  restrictions to be applied to the account. Fees pertaining to this service are outlined in Item 5 of this  brochure. 

Elevate (Foundational Planning) 

This service includes access to a range of investment products and seamless execution of securities  transactions, as well as a one consultation call with a financial adviser per quarter, cash flow planning, debt  reduction planning, insurance needs analysis, investment planning services, retirement planning, employee  benefits review, and future education planning. Investment management services are managed with the  assistance of a Financial Planning professional. The adviser will create a personalized financial plan for the  client, communicate the plan to the client, and will provide ongoing support through monthly action steps  provided to the client. 

6-month Financial Planning Engagement  

FCA’s 6-month financial planning engagement is focused on establishing financial priorities, organizing their  financial lives, cash flow analysis, deciding on what savings or investment buckets to use, and an insurance  review. 

Services Limited to Specific Types of Investments 

FCA generally limits its investment advice to mutual funds, real estate funds (including REITs), equities, ETFs,  and treasury inflation protected/inflation-linked bonds, although FCA primarily recommends equities and  ETFs. FCA may use other securities as well to help diversify investment management when applicable. 

Educational Seminars/Workshops 

FCA provides periodic educational seminars on an “as announced” basis for groups seeking general advice  on investments and other areas of personal finance. The content of these seminars will vary depending upon  the needs of the attendees. These seminars are purely educational in nature and do not involve the sale of  any investment products. Information presented will not be based on an individual person’s need, nor does  FCA provide individualized investment advice to attendees during these seminars.  

Subscription Services 

FCA offers newsletters to clients and the general public free of charge. 

Varying discounts and promotions are available. Changes in fees resulting from discounts and promotions  are notated in client agreements at the commencement of the engagement. 

C. Client Tailored Services and Client Imposed Restrictions

FCA offers the same suite of services to all of its clients. However, specific client investment strategies and  their implementation are dependent upon the client Investment Policy Statement which outlines each  client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions  in investing in certain securities or types of securities in accordance with their values or beliefs.

D. Wrap Fee Programs

A wrap fee program is an investment program where the investor pays one stated fee that includes  management fees, transaction costs, and certain other administrative fees. FCA does not participate in wrap  fee programs. 

E. Assets Under Management

FCA has the following assets under management:

Discretionary: $4,870,143
Date Calculated:
January 2022


Please note, unless a Client has received the firm’s Disclosure Brochure at least 48 hours prior to signing  the investment advisory contract, the investment advisory contract may be terminated by the Client within  five (5) business days of signing the contract without incurring any advisory fees. How we are paid  depends on the type of advisory service we are performing. Please review the fee and compensation  information below. 

A. Fee Schedule

Investment Management & Financial Planning fees 

The rates for the Investment Management & Financial Planning program are negotiable. Fees for the  Investment management portion of the Elevate service are 0.2% AUM*, and the fee is billed quarterly in  arrears, based on the average daily balance of the account throughout the month. The financial planning  portion of the service is billed monthly in advance, at a rate of $89.00 per month. 

*AUM Fees are withdrawn by Betterment for Advisors, and any portion of the fee that is due FCA   is remitted to the firm. 

6-month Financial Planning Engagement  

The fee for the 6-month Financial Planning engagement is $445, paid upfront by electronic funds  transfer. 

Since the work will commence immediately after payment, upon termination, no refunds will be  provided.

Hourly Financial Planning Consultations (Advice) 

FCA offers one-time hourly consultations for those that have short-term needs or need advice  regarding life events, at a fee of $199 per hour. In the event of early termination by the client, any fees  for the hours already worked will be due. Fees for this service may be paid by electronic funds  transfer or check. 

Educational Seminars/ Speaking engagements 

Seminars are offered to organizations and the public on a variety of financial topics. Fees range from free  to $5,000 per engagement. Half of the fees are due prior to the engagement, and the other half is to be  paid the day of, no later than the conclusion of the Seminar. The fee range is based on the content,  amount of research conducted, the number of hours of preparation needed, and the number of attendees.  In the event of inclement weather or flight cancellation, the Speaker shall make all reasonable attempts  to make alternative travel arrangements to arrive in time for the presentation. If travel proves  impossible, or the event is otherwise canceled, the Speaker's fee is waived, but the Client will still be  responsible for reimbursement of any non-refundable travel expenses already incurred. 

In the event that the Client decides to cancel or change the date of the event for any reason besides  weather or similar unforeseen causes, the Client will still be responsible for reimbursement of any non refundable travel expenses already incurred and will provide payment for 50% of the Speaker’s fee if the  cancellation occurs within 30 days of the event. In the event that the Speaker must cancel due to health  or similar unforeseen circumstances, the Speaker will make all attempts to find a reasonable alternative  engagement date and will absorb any incremental additional costs for obtaining alternative travel  arrangements. If an alternative date cannot be obtained, the Client will not be responsible for any travel  costs already incurred by the Speaker or any portion of the Speaker’s fee. 

B. Payment of Fees

Payment of Investment Management Fees 

Investment management fees are calculated based on the average daily balance of the account throughout  each quarter and applied to the above-listed fee schedule. Since ongoing asset management fees are paid in  arrears, no refund of these fees will be required upon termination of the account. 

Payment of Financial Planning Program Fees 

Payment of financial planning fees is executed on either a monthly or semi-annual basis. Monthly fees are  due in advance of each month. Should the client cancel during the first 30 days after initiating the service,  the financial planning work will continue throughout the remainder of the month, an invoice will be  generated and the remaining fee will be due immediately. Semi-Annual fees are due upfront and are non refundable upon cancellation.

C. Client Responsibility for Third Party Fees

Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund  fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by FCA.  Please see Item 12 of this brochure regarding broker-dealer/custodian. 

D. Prepayment of Fees

FCA collects fees for investment management in arrears, as indicated above. Fees for the Financial Planning  Program are paid in advance. Fixed fees for the Financial Planning Program will not be refunded. Clients  continue to have access until the end of the month in which services are terminated, as such no refund of fees  will be due. 

D. Outside Compensation for the Sale of Securities to Clients

Neither FCA nor its supervised persons accept any compensation for the sale of investment products,  including asset-based sales charges or service fees from the sale of mutual funds. 

FCA does not accept performance-based fees or other fees based on a share of capital gains on or capital  appreciation of the assets of a client. 

FCA generally provides advisory services to Individuals. There is no account minimum for any of FCA’s  services. 

Methods of Analysis 

FCA’s methods of analysis include Fundamental analysis, Modern investment management theory, and  Quantitative analysis. 

Fundamental analysis involves the analysis of financial statements, the general financial health of 

companies, and/or the analysis of management or competitive advantages. 

Modern investment management theory is a theory of investment that attempts to maximize investment  management expected to return for a given amount of investment management risk, or equivalently minimize  risk for a given level of expected return, each by carefully choosing the proportions of a various asset. 

The quantitative analysis deals with measurable factors as distinguished from qualitative considerations  such as the character of management or the state of employee morale, such as the value of assets, the cost of  capital, historical projections of sales, and so on. 

Investment Strategies 

FCA manages different investment strategies, using algorithms, which employ a variety of investment  methods relying on technical and fundamental analysis and leveraging the many proprietary pieces of  investment technology that we have built. All of our programs are a blend of an absolute return allocation  made up of a rotating mix of FCA strategies across equity, income, diversified, and alternative asset classes.  Strategy holdings change at the discretion of FCA’s Investment Management Team, depending on global asset  class strength.  

For some financial goals and investment managements, FCA recommendations to clients will shift over time,  with the recommended allocation gradually shifting as the term of the goal approaches. 

When clients deposit to or withdraw money from their FCA account, they are requesting that FCA purchase or  sell available assets within their account in amounts that reflect their desired allocation. Similarly, when  clients and/or their Advisors adjust a client’s allocation, Freeman Capital Advisors will buy and sell Funds to  approach the desired allocation. 

Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 

Methods of Analysis 

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 will fail to reach expectations of perceived  value. 

Modern investment management theory assumes that investors are risk averse, meaning that given two  investment managements that offer the same expected return, investors will prefer the less risky one. Thus,  an investor will take on increased risk only if compensated by higher expected returns. Conversely, an  investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for  all investors, but different investors will evaluate the trade-off differently based on individual risk aversion  characteristics. The implication is that a rational investor will not invest in investment management if a  second investment management exists with a more favorable risk-expected return profile – i.e., if for that  level of risk an alternative investment management exists which has better expected returns. 

Quantitative analysis Investment strategies using quantitative models may perform differently than  expected as a result of, among other things, the factors used in the models, the weight placed on each factor,  changes from the factors’ historical trends, and technical issues in the construction and implementation of the  models.

Investment Strategies 

FCA uses algorithms to advise clients and manage their accounts. These algorithms are developed, overseen,  and monitored by FCA’s investment advisory personnel. When clients sign up for a FCA account, an algorithm,  developed by FCA investment advisory personnel, determines FCA’s recommended allocation based on inputs  from the client. Algorithms also generate advice regarding other investment decisions, including but not  

limited to allocation selection, savings and withdrawal rates, automatic rebalancing, account type selection,  and the amount of cash FCA recommends that retail clients maintain in the bank account they have linked to  their FCA account. When clients make deposits or withdrawals from their accounts or donate shares, an  algorithm determines the specific securities to trade based on a client’s allocation and other directions that  they have provided to FCA. Further details on each of these services, including the operation of the underlying  algorithms, are available on FCA website FCA may modify periodically these algorithms, or a computer  system’s code or underlying assumptions, and these changes may have unintended consequences. Additional  information regarding relevant considerations for Clients considering an automated digital investment  advisory program (sometimes referred to as a “robo advisor”) is contained in the Investor Bulletin from the  Securities and Exchange Commission available at bulletins/ib_robo-advisers.html. 

Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long term investment strategy can expose clients to various types of risk that will typically surface at various  intervals during the time the client owns the investments. These risks include but are not limited to inflation  (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. 

Short term trading risks include liquidity, economic stability, and inflation, in addition to the long-term  trading risks listed above. Frequent trading can affect investment performance, particularly through  increased brokerage and other transaction costs and taxes. 

Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 

Clients should be aware that there is a material risk of loss using any investment strategy. The investment  types listed below (leaving aside Treasury Inflation-Protected/Inflation-Linked Bonds) are not guaranteed  or insured by the FDIC or any other government agency. 

Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money  investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of  bond “fixed income” nature (lower risk) or stock “equity” nature. 

Equity investment generally refers to buying shares of stocks in return for receiving a future payment of  dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate  in response to specific situations for each company, industry conditions and the general economic  environments. 

Exchange-Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks.  Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding  bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity,  conflicts of interest and the possibility of inadequate regulatory compliance.


Real estate funds (including REITs) face several kinds of risks that are inherent in the real estate sector,  which historically has experienced significant fluctuations and cycles in performance. Revenues and cash  flows may be adversely affected by changes in local real estate market conditions due to changes in national  or local economic conditions or changes in local property market characteristics; competition from other  properties offering the same or similar services; changes in interest rates and in the state of the debt and  equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other  operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning  laws; the impact of present or future environmental legislation and compliance with environmental laws. 

Use of Outside Managers: We may refer Clients to third-party investment advisers ("outside managers").  Our analysis of outside managers involves the examination of the experience, expertise, investment  philosophies, and past performance of the outside managers in an attempt to determine if that manager has  demonstrated an ability to invest over a period of time and in different economic conditions. We monitor  the manager's underlying holdings, strategies, concentrations, and leverage as part of our overall periodic  risk assessment. Additionally, as part of our due diligence process, we survey the manager's compliance  and business enterprise risks. A risk of investing with an outside manager who has been successful in the  past is that he or she may not be able to replicate that success in the future. In addition, as we do not  control the underlying investments in an outside manager's portfolio. There is also a risk that a manager  may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable  investment for our Clients. Moreover, as we do not control the manager's daily business and compliance  operations, we may be unaware of the lack of internal controls necessary to prevent business, regulatory or  reputational deficiencies. 

Past performance is not indicative of future results. Investing in securities involves a risk of loss  that you, as a client, should be prepared to bear. 

There are no criminal or civil actions to report. 

There are no administrative proceedings to report. 

There are no self-regulatory organization proceedings to report.


Neither FCA nor its representatives are registered as, or have pending applications to become, a  broker/dealer or a representative of a broker/dealer. 

Neither FCA nor its representatives are registered as or have pending applications to become either a Futures  Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person  of the foregoing entities. 

Richard Taborda is an investment adviser representative with another firm, LBT Wealth Management, where  he provides financial coaching, financial planning and investment management for a fee. However, Richard  does not offer clients of FCA advice or products from this activity. Freeman Capital Advisors, LLC always acts  in the best interest of the client. Clients are in no way required to utilize the services of any representative  of Freeman Capital Advisors, LLC in such individual's outside capacity. 

Richard Taborda is a licensed insurance agent and provides insurance related services and products for a  commission through both LBT Insurance Services and Freeman Capital Insurance Group. From time to time,  he will offer clients advice or products from this activity. Clients should be aware that these services pay a  commission and involve a possible conflict of interest, as commissionable products can conflict with the  fiduciary duties of a registered investment adviser. Freeman Capital Advisors, LLC always acts in the best  interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no  way required to implement the plan through any representative of Freeman Capital Advisors, LLC in their  capacity as a licensed insurance agent. 

Calvin F. Williams Jr. is also CEO of Freeman Capital Insurance Group. Although he does not operate as a  licensed insurance agent, clients should be aware that his ownership in the insurance agency may involve  possible conflicts of interest, as commissionable products can conflict with the fiduciary duties of a registered  investment adviser. Freeman Capital Advisors, LLC always acts in the best interest of the client; including in  the sale of commissionable products to advisory clients. Clients are in no way required to purchase insurance  products offered through Freeman Capital Insurance Group, or through any representative of Freeman  Capital Advisors, LLC in their capacity as a licensed insurance agent.


As referenced in Item 4 of this brochure, FCA recommends Clients to Outside Managers to manage their  accounts. In the event that we recommend an Outside Manager, please note that we do not share in their  advisory fee. Our fee is separate and in addition to their compensation (as noted in Item 5) and will be  described to you prior to engagement. You are not obligated, contractually or otherwise, to use the services  of any Outside Manager we recommend. Additionally, FCA will only recommend an Outside Manager who is  properly licensed or registered as an investment adviser. 

FCA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider  Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest,  Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance  with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations,  Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. FCA's Code  of Ethics is available free upon request to any client or prospective client. 

FCA does not recommend that clients buy or sell any security in which a related person to FCA or FCA has a  material financial interest. 

From time to time, representatives of FCA may buy or sell securities for themselves that they also recommend  to clients. This may provide an opportunity for representatives of FCA to buy or sell the same securities  before or after recommending the same securities to clients resulting in representatives profiting off the  recommendations they provide to clients. Such transactions may create a conflict of interest. FCA will always  document any transactions that could be construed as conflicts of interest and will never engage in trading  that operates to the client’s disadvantage when similar securities are being bought or sold. 

From time to time, representatives of FCA may buy or sell securities for themselves at or around the same  time as clients. This may provide an opportunity for representatives of FCA to buy or sell securities before or  after recommending securities to clients resulting in representatives profiting off the recommendations they  provide to clients. Such transactions may create a conflict of interest; however, FCA will never engage in  trading that operates to the client’s disadvantage if representatives of FCA buy or sell securities at or around 


the same time as clients. 

Custodians/broker-dealers will be recommended based on FCA’s duty to seek “best execution,” which is the  obligation to seek execution of securities transactions for a client on the most favorable terms for the client  under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent,  

and FCA may also consider the market expertise and research access provided by the broker dealer/custodian, including but not limited to access to written research, oral communication with analysts,  admittance to research conferences and other resources provided by the brokers that may aid in FCA's  research efforts. FCA will never charge a premium or commission on transactions, beyond the actual cost  imposed by the broker-dealer/custodian. 

1. Research and Other Soft-Dollar Benefits 

FCA currently receives soft dollar benefits by nature of our relationship with MTG, LLC dba Betterment  Securities (“Betterment Securities”). 

2. Brokerage for Client Referrals 

FCA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer  or third party. 

3. Clients Directing Which Broker/Dealer/Custodian to Use 

We do recommend a specific custodian for Clients to use, however, Clients may custody their assets at a  custodian of their choice. Clients may also direct us to use a specific broker-dealer to execute  transactions. By allowing Clients to choose a specific custodian, we may be unable to achieve the most  favorable execution of Client transaction and this may cost Clients money over using a lower-cost  custodian. 

The Custodians and Brokers We Use (Betterment) 

FCA does not maintain custody of your assets that we manage, although we may be deemed to have custody  of your assets if you give us the authority to withdraw advisory fees from your account (see Item 15— Custody, below). Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. We may recommend that our Clients use MTG, LLC dba Betterment Securities  ("Betterment Securities"), a registered broker-dealer, member SIPC, as the qualified custodian. We are  independently owned and operated and are not affiliated with Betterment Securities. Betterment Securities  will hold your assets in a brokerage account and buy and sell securities when we and/or you instruct them  to. While we may recommend that you use Betterment Securities as custodian/broker, you will decide  whether to do so and will open your account with Betterment Securities by entering into an account  agreement directly with them. We do not open the account for you, although we may assist you in doing so. 


If you do not wish to place your assets with Betterment Securities, then we cannot manage your account on  Betterment For Advisors (defined below). 

Your Brokerage and Custody Costs 

For our Clients' accounts that Betterment Securities maintains, Betterment Securities generally does not  charge you separately for custody services but is compensated as part of the Betterment For Advisors  (defined below) platform fee, which is a percentage of the dollar amount of assets in the account in lieu of  commissions. We have determined that having Betterment Securities execute trades is consistent with our  duty to seek "best execution" of your trades. Best execution means the most favorable terms for a transaction  based on all relevant factors, including those listed above (see "Factors Used to Select Custodians and/or  Broker-Dealers"). 

Services Available to Us via Betterment For Advisors 

Betterment Securities serves as broker-dealer to Betterment For Advisors, an investment and advice  platform serving independent investment advisory firms like us ("Betterment For Advisors"). Betterment  For Advisors also makes available various support services which may not be available to Betterment's retail  customers. Some of those services help us manage or administer our Clients' accounts, while others help us  manage and grow our business. Betterment For Advisors' support services are generally available on an  unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed  description of Betterment For Advisors' support services: 

1. SERVICES THAT BENEFIT YOU. Betterment For Advisors includes access to a range of investment  products, execution of securities transactions, and custody of Client assets through Betterment  Securities. Betterment Securities’ services described in this paragraph generally benefit you and your  account. 

2. SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU. Betterment For Advisors also makes available to us  other products and services that benefit us, but may not directly benefit you or your account. These  products and services assist us in managing and administering our Clients’ accounts, such as software  and technology that may: 

● Assist with back-office functions, recordkeeping, and Client reporting of our Clients’ accounts. ● Provide access to Client account data (such as duplicate trade confirmations and account statements). ● Provide pricing and other market data. 

● Assist with back-office functions, recordkeeping, and Client reporting. 

1. SERVICES THAT GENERALLY BENEFIT ONLY US. By using Betterment For Advisors, we will be offered  other services intended to help us manage and further develop our business enterprise. These services  include: 

● Educational conferences and events. 

● Consulting on technology, compliance, legal, and business needs. 

● Publications and conferences on practice management and business succession. 

Our Interest in Betterment Securities’ Services 

The availability of these services from Betterment For Advisors benefits us because we do not have to  produce or purchase them. In addition, we don’t have to pay for Betterment Securities’ services. These  services may be contingent upon us committing a certain amount of business to Betterment Securities in  assets in custody. We may have an incentive to recommend that you maintain your account with Betterment  Securities, based on our interest in receiving Betterment For Advisors and Betterment Securities’ services 


that benefit our business rather than based on your interest in receiving the best value in custody services  and the most favorable execution of your transactions. This is a potential conflict of interest. We believe,  however, that our selection of Betterment Securities as custodian and broker is in the best interests of our  Clients. Our selection is primarily supported by the scope, quality, and price of Betterment Securities’  services and not Betterment For Advisors and Betterment Securities’ services that benefit only us. 

If FCA buys or sells the same securities on behalf of more than one client, then it may (but would be under  no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to  seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, FCA  would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for  all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not  systematically disadvantaged by this policy. FCA would determine the appropriate number of shares and  select the appropriate brokers consistent with its duty to seek the best execution, except for those accounts  with specific brokerage direction (if any). 

Account Reviews 

All client accounts for FCA's advisory services provided on an ongoing basis are reviewed at least annually  by Calvin F Williams, CEO, with regard to clients’ respective investment policies and risk tolerance levels. All  accounts at FCA are assigned to this reviewer. 

All Financial Planning program accounts are reviewed upon financial plan creation and plan delivery by  Calvin F Williams, CEO. Financial Planning program clients are provided on-going Financial Planning tools  concerning their financial situation until services are terminated by the client or FCA. II investment Management Rebalancing  

FCA periodically rebalances the client’s investment management to make sure that the optimized investment  managements stay at the client’s determined risk level and adjusts if that risk level changes. It attempts to  do this in a tax-efficient fashion while seeking to ensure that the multiple objectives of the client remain  feasible. The rebalance algorithm including when and how much should be rebalanced will be determined  by FCA’s AI Investment Advisor and Investment Services. 

Reviews may be triggered by material market, economic or political events, or by changes in the client's 


financial situations (such as retirement, termination of employment, physical move, or inheritance). 

Each client of FCA's advisory services provided on an ongoing basis will receive a quarterly report detailing  the client’s account, including assets held, asset value, and calculation of fees. This written report will come  from the custodian. FCA will also provide at least monthly a separate written statement to the client. 

Each Financial Planning program client will receive ongoing Financial Planning services until terminated by  the client or FCA. 

We receive a non-economic benefit from Betterment For Advisors and Betterment Securities in the form of  the support products and services it makes available to us and other independent investment advisors  whose Clients maintain their accounts at Betterment Securities. These products and services, how they  benefit us, and the related conflicts of interest are described above (see Item 12—Brokerage  Practices). The availability to us of Betterment For Advisors and Betterment Securities’ products and  services is not based on us giving particular investment advice, such as buying particular securities for our  Clients. 

Freeman Capital may enter into solicitation agreements pursuant to which it compensates third-party  intermediaries for client referrals that result in the provision of investment advisory services by Freeman  Capital. Freeman Capital will disclose these solicitation arrangements to affected investors, and any cash  solicitation agreements will comply with Rule 206(4)-3 under the Advisers Act. Solicitors introducing  clients to Freeman Capital may receive compensation from Freeman Capital, such as a retainer, a flat fee  per referral, and/or a percentage of introduced capital. Such compensation will be paid pursuant to a  written agreement with the solicitor and generally may be terminated by either party from time to time.  The cost of any such fees will be borne entirely by Freeman Capital and not by any affected client. 

When advisory fees are deducted directly from client accounts at the client's custodian, FCA will be deemed  to have limited custody of the client's assets and must have written authorization from the client to do so.  Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they 


should carefully review those statements for accuracy. 

FCA provides discretionary investment advisory services to clients. The advisory contract established with  each client sets forth the discretionary authority for trading. Where investment discretion has been granted,  FCA generally manages the client’s account and makes investment decisions without consultation with the  client as to when the securities are to be bought or sold for the account, the total amount of the securities to  be bought/sold, what securities to buy or sell, or the price per share. 

FCA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from  the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the  security. 

FCA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in  advance of services rendered, and therefore is not required to include a balance sheet with this brochure. 

Neither FCA nor its management has any financial condition that is likely to reasonably impair FCA’s ability  to meet contractual commitments to clients.