This Disclosure document is being offered by Class VI Family Office about the investment
advisory services we provide. It discloses information about the services that we provide and
the way those services are made available to our clients. We are an investment management
firm located in Colorado. Class VI Family Office provides business owners, executives, and
entrepreneurs with consultative and holistic wealth planning solutions prior to, throughout
the process of, and following a significant liquidity event involving privately held business
and/or other assets. The firm was established by David Tolson and Chris Younger in 2016.
Class VI Investments, LLC is the Managing Member of Class VI Family Office, LLC.
Clients can choose to employ Class VI Family Office to design and proactively manage an
investment portfolio, customized to the goals, objectives, and risk tolerance of each client.
Class VI Family Office encourages clients to go through the wealth planning process to design
and manage an investment portfolio that will meet their needs for cash flow, tax-efficiency,
and overall allocation. We will offer initial complimentary meetings; however, investment
advisory services are initiated only after the client(s) and Class VI Family Office execute a client
agreement.
Investment and Wealth Management and Supervision Services
We offer discretionary and non-discretionary investment management and investment
supervisory services for a fee, based on a percentage of the assets under management or on
a flat dollar arrangement. These services include investment analysis, allocation of
investments, portfolio reports, financial commentaries, and ongoing monitoring of client
portfolios. We primarily allocate client assets among various mutual funds, exchange-traded
funds (“ETFs”), and individual debt (bonds) and equity securities in accordance with a client’s
stated investment objectives.
We work with clients to obtain necessary information regarding their financial condition,
investment objectives, liquidity requirements, risk tolerance, time horizons, and any
restrictions on investing. Clients can place reasonable restrictions on the types of investments
that may be purchased in an account, however we retain the right to decline to enter into a
management agreement with any clients whose investment requirements are contrary to the
firm’s investment strategies. The financial and risk information gathered allows us to
determine the portfolio best suited for a client’s investment objective and needs.
In performing our services, we shall not be required to verify any information received from
the client or from other professionals. We may recommend clients engage the services of
other professionals for implementation purposes. Clients have the right to decide whether to
engage the services of any such recommended professional. Once we have determined the
types of investments to be included in a client portfolio and allocated them, we will provide
ongoing portfolio review and management services. This approach requires us to review
client portfolios at least quarterly.
We tailor our advisory services to meet the needs of our clients and seek to ensure that
portfolios are managed in a manner consistent with those needs and objectives. We trade
these portfolios and rebalance them as deemed appropriate, based on the combination of
our market views and client objectives, using our investment process. If a non-discretionary
relationship is in place, we will present the recommendations and only upon client
authorization will any action be taken on their behalf.
In all cases, clients have a direct and beneficial interest in their securities, rather than an
undivided interest in a pool of securities. We do have limited authority to direct the
Custodian to deduct our investment advisory fees from client accounts, but only with the
appropriate written authorization from the client. Where appropriate, we provide advice
about any type of legacy position or other investment held in client portfolios. Clients can
engage us to advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer
sponsored retirement plans and qualified education plans.
Clients are advised and are expected to understand that past performance is not a guarantee
of future results. Certain market and economic risks may exist that adversely affect an
account’s performance. This could result in capital losses in client accounts.
Wealth Planning
Through the Wealth Planning process, the Class VI Family Office team strives to engage our
clients in conversations around the family’s goals, objectives, priorities, vision, and legacy –
both for the near term as well as for future generations. With the unique goals and
circumstances of each family in mind, the Class VI Family Office team will offer wealth planning
ideas and strategies to address the client’s holistic financial picture, including estate, income
tax, charitable, cash flow, wealth transfer and family legacy objectives. Our team partners
with our client’s other advisors (CPA, estate attorney, insurance broker, etc.) to ensure a
coordinated effort of all parties toward the client’s stated goals. Such services include various
reports on specific goals and objectives, general investment and/or planning
recommendations, guidance to outside assets, and periodic updates.
Our specific services in wealth planning include:
• Review and clarification of client financial goals.
• Assessment of overall financial position including cash flow, balance sheet,
investment strategy, risk management, and estate planning.
• Creation of a unique financial plan according to the client’s specific situation,
objectives, assets, income, and goals for spending, giving, and wealth transfer.
• Development of a goal-oriented investment plan, with consideration to tax efficiency,
asset allocation, expenses, risk, and liquidity across all client accounts (taxable,
qualified, trust, etc).
• Ongoing monitoring of financial plan and investment plan to ensure tracking toward
goals as circumstances, needs, or objectives may change.
• Assess risk management, asset protection, and insurance needs that may be present
for client families.
• Crafting and implementation of, in conjunction with legal and tax counsel, an estate
plan to ensure client wishes for beneficiaries in the event of an incapacity or death.
Financial Plans are presented by Class VI Family Office and reviewed with clients utilizing an
online financial planning software, with paper or electronic copies to be provided as requested
by the client. Reviews and updates to the plan will occur and/or be presented based on
material changes to circumstances or upon request by the client.
Third Party Managers
Class VI Family Office IARs assist clients with identifying their risk tolerance and investment
objectives. When appropriate, Class VI Family Office may recommend the use of Third-Party
Managers (“Managers” or “TPM”) within a client portfolio to meet certain goals previously
identified by the client. Class VI Family Office maintains a selected list of high-quality Managers
who handle day-to-day management of their portfolios based on an established objective.
Managers selected for client investments need to meet several quantitative and qualitative
criteria established by the Firm. Among the criteria that may be considered are the Manager’s
experience, assets under management, performance record, client retention, the level of
client services provided, investment style, buy and sell disciplines, capitalization level, and the
general investment process.
Following recommendations by Firm IARs, clients will have final authority to select a Manager.
The IAR will assist clients in completing appropriate documents to enter into a Third-Party
Advisory Program Agreement directly with the Manager.
Class VI Family Office IARs shall be available to answer questions the client may have regarding
their account and act as the communication conduit between the client and the Manager.
Managers may take discretionary authority to determine the securities to be purchased and
sold for the client.
Information collected by our Firm regarding
Managers is believed to be reliable and accurate,
but Class VI Family Office does not necessarily independently review or verify it on all
occasions. All performance reporting will be the responsibility of the respective Manager. Such
performance reports will be provided directly to the client and Class VI Family Office. The Firm
does not audit or verify that these results are calculated on a uniform or consistent basis as
provided by a Manager directly to Class VI Family Office, or through the consulting service
utilized by the Manager.
Third-party managed programs generally have account minimum requirements that will vary
among investment advisors. A complete description of the Manager’s services, fee schedules,
and account minimums will be disclosed in the Manager’s Form ADV or similar disclosure
brochure, which will be provided to clients at the time an agreement for services is executed
and account is established.
Consulting Services
We also provide clients investment advice on a more-limited basis on one or more isolated
areas of concern such as estate planning, real estate, retirement planning, or any other
specific topic. Additionally, we provide advice on non-securities matters about the rendering
of estate planning, insurance, real estate, and/or annuity advice or any other business
advisory/consulting services for equity or debt investments in privately held businesses. In
these cases, clients will be required to select their own investment managers, custodian,
and/or insurance companies for the implementation of consulting recommendations. If client
needs include brokerage and/or other financial services, we will recommend the use of one
of several investment managers, brokers, banks, custodians, insurance companies, or other
financial professionals ("Firms"). Consulting clients must independently evaluate these Firms
before opening an account or transacting business and have the right to choose whether to
follow the consulting advice, and to effect business through any firm they choose.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in
the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if
one is available and rollovers are permitted, (iii) rollover to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result
in adverse tax consequences). Our Firm may recommend an investor roll over plan assets to
an IRA for which our Firm provides investment advisory services. As a result, our Firm and its
representatives may earn an asset-based fee. In contrast, a recommendation that a client or
prospective client leave their plan assets with their previous employer or roll over the assets
to a plan sponsored by a new employer will generally result in no compensation to our Firm.
Our Firm therefore has an economic incentive to encourage a client to roll plan assets into an
IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of
interest, there are various factors that our Firm will consider before recommending a rollover,
including but not limited to: (i) the investment options available in the plan versus the
investment options available in an IRA, (ii) fees and expenses in the plan versus the fees and
expenses in an IRA, (iii) the services and responsiveness of the plan’s investment professionals
versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax
consequences, if any. Rollover recommendations are also reviewed in a best effort to
determine that the recommendation to a client was reasonable or that the client has
determined to make the rollover after being provided ample information about their options.
No client is under any obligation to roll over plan assets to an IRA advised by our Firm or to
engage our Firm to monitor and/or advise on the account while maintained with the client's
employer. Our Firm’s Chief Compliance Officer remains available to address any questions
that a client or prospective client has regarding this disclosure.
We are Fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to clients regarding retirement plan account or individual retirement
account we are also Fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. We have to act in the best interest of clients and not put our interest
ahead of theirs. At the same time, the way we make money creates some conflicts with clients’
interests.
Related Adviser – Private Fund
The Firm’s related Adviser, Class VI Ventures, LLC, is an adviser to a Private Fund. Class VI
Ventures, LLC manages the Private Fund based on the particular investment objectives and
strategies described in the applicable Client’s (i) confidential offering memorandum or
separate account agreement and (ii) governing documents (referred to collectively as “Offering
Documents”). The Fund’s focus is primarily making growth capital investments in small to mid-
sized companies. The Private Fund is not registered under the Investment Company Act, and
their shares or interests, as applicable, are not registered under the Securities Act, and are
instead sold to qualified investors who meet certain criteria on a private placement basis.
Class VI Ventures Private Fund requires that investors be “accredited investors” as defined
under Regulation D under the Securities Act (“Regulation D”). Accordingly, the Class VI Private
Fund is not publicly offered in the United States.
Our Firm will recommend Private Fund to certain wealth management account clients of Class
VI Family Office. Other qualified individuals who may not be employees or advisory clients of
Class VI or another Class VI entity, but who have pre-existing business relationships with the
Firm or its affiliates or industry expertise in the sector in which a fund may be investing, also
may participate alongside other investors. It is important clients refer to the private placement
memorandum and Class VI Ventures 2A Brochure for disclosure of applicable risks and the
related conflicts. Class VI Family Office’s recommendations of Fund interests are considered
principal transactions by the Firm due to the percentage of the Fund owned by Class VI
affiliates. Our Firm will prepare a disclosure on principal transactions and consent to be
delivered to Family Office clients referred to the Fund. The consent will provide disclosure of
all material facts and will conform to the requirements of Section 206(3) of the Advisers Act.
The client must sign the consent prior to acceptance of any Commitment or investment in the
Fund. Class VI Ventures and Class VI Family Office, its affiliates and their related persons will
receive a potential allocation of Carried Interest (discussed in Item 6 of Class VI Ventures Part
2A Brochure and Offering documents) from the Class VI Private Fund. Such compensation
provides an incentive for our Firm and its Affiliates to recommend the Class VI Private Fund to
our wealth management clients. Class VI Ventures will not charge an investment management
fee to Class VI Family Office wealth management clients for the amount invested in the Class
VI Private Fund. However, because the Carried Interest charged to the Class VI Private Fund is
higher than the investment management fee charged to the Firm’s clients, even with this fee
offset there is still an incentive for the Firm to recommend the Class VI Private Fund to Class
VI Family Office clients. To mitigate this conflict, the Firm will only recommend an investment
in the Class VI Private Fund to clients in keeping with its fiduciary requirements and will make
such investment only upon the written approval and consent of the client.
Assets
As of December 31, 2022, we have a total of $958,632,592 in regulatory assets under our Firm’s
management. Discretionary regulatory assets under management total $946,622,263 and
regulatory non-discretionary assets under our management total $12,010,329.