A.Description of the Advisory Firm
Freedom Financial serves as a Managing Member and sponsor to the Freedom Consumer
Credit Fund, LLC, which is a pooled investment vehicle and Delaware multi-series limited
liability company. Freedom Financial is an indirect subsidiary of Pantheon Freedom, Inc.
(“Pantheon”) which is also the ultimate parent company of Freedom Financial Network, LLC
(“FFN”), Lendage LLC (d/b/a “Achieve Home Loans”) and other entities that provide
consumers with a range of financial services including debt settlement services and home
equity lines of credit (“HELOCs”). Form ADV Part 1, Section 7.B.(1) provides a complete list of
pooled investment vehicles serviced by Freedom Financial.
B.Description of Advisory Services
Freedom Financial provides discretionary investment management services to pooled
investment vehicles, the securities of which are offered to investors on a private placement
basis and are exempt from registration under the Securities Act of 1933, as amended. The
Freedom Consumer Credit Fund, LLC (referred to herein as the “Freedom Fund” or the
“Fund”) is exempt from registration as an investment company under the Investment
Company Act of 1940, as amended. Interests in the Fund are offered exclusively to investors
satisfying the applicable eligibility and suitability requirements for private placement
transactions inside the United States.
Currently, Freedom Financial has sponsored the following pooled investment vehicle (which is
disclosed on Form ADV Part 1, Section 7.B.(1)):
●Freedom Consumer Credit Fund, LLC – Series B (“Series B”) is a —Pooled investment
vehicle that is currently accepting outside investors to participate in the
loan-purchase strategies identified by this brochure and Fund offering documents.
Series B relies on Section 3(c)7 of the Investment Company Act of 1940.
Currently, Freedom Financial acquires investments on behalf of Series
B which are held by
the Fund. The investments held by the Fund consist primarily of consumer installment loans
originated by Cross River Bank, Inc. (“Cross River Bank”) and Pathward, N.A., a subsidiary of
Pathward Financial, Inc. (“Pathward”) and purchased by Series B pursuant to loan purchase
agreements between Cross River Bank, Pathward, the Freedom Fund, and Freedom Financial.
Additional investments held by the Fund consist of consumer mortgage loans originated by
Achieve Home Loans, a company under common control.
Freedom Financial directs the investment and reinvestment of capital in accordance with the
Fund’s governing documents. The Firm is also responsible for the management of Fund
affairs, including authority and oversight over operations and general administration of Fund
business. While the Fund serves third party investors, the Fund also supports the commercial
interests of FFN.
The Firm’s investment strategies are discussed in detail within Item 8 of this Brochure.
C.Client Tailored Services and Client Imposed Restrictions
Advisory services are tailored to achieve the Fund’s investment or trading objectives which
are referenced in the Fund’s governing documents. The Fund’s governing documents provide
Freedom Financial with limited discretion to select which consumer installment loans,
consumer mortgage loans, and other specified types of instruments to buy or sell.
D.Wrap Fee Programs
Wrap fee programs are investment programs where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and other administrative fees.
At this time, Freedom Financial does not participate in wrap fee programs.
E.Regulatory Assets Under Management
Freedom Financial has the following regulatory assets under management (“RAUM”):
●Discretionary RAUM – $712,452,726
●Non-Discretionary RAUM – $0
●Date Calculated – December 31, 2023