Firm Overview
Concreit Fund Management LLC (“Concreit” or the “Firm”), a Delaware limited liability company,
is an investment adviser registered with the U.S. Securities and Exchange Commission (the
“SEC”) pursuant to the Advisers Act. Concreit is based in Seattle, Washington and serves as a
wholly owned subsidiary of Concreit Inc., a company dedicated to commercial real estate
fractional investing for everyday investors. Concreit Inc. is working on reshaping the experience
of investing in commercial real estate (“CRE”) by making it social and changing its behaviors of
liquidity and payouts. Concreit Inc. leverages distributed ledger tech in its approach to fund and
asset management. Concreit Inc. is also the owner of an interactive website, invest.concreit.com,
and a mobile application (collectively the “Platform”), intended for use by individual investors
(“Individual Clients”). Concreit operates the aforementioned services. Sean Hsieh serves as the
Founder and Chief Executive Officer of Concreit Inc. Jordan Levy serves co-Founder and Chief
Technology Officer of Concreit Inc., William “Chris” Garnett serves as Chief Compliance Officer
at Concreit Inc., and Christopher Carsley serves as Chief Investment Officer of Concreit Inc.
Basis of Registration
Concreit is classified as a registered investment adviser under the SEC Rule 203A-2(e)
(“Exemption from Prohibition on Commission Registration”) of the Advisers Act, which creates an
eligibility to operate as a registered investment advisor under the Exemption from Prohibition on
Commission Registration, provided the elements of that rule are met. The elements of that rule
include the following:
● An adviser provides investment advice to advisory clients through an interactive website.1
● The adviser provides advice to all of its clients exclusively through the interactive website.
● And, finally, the registered investment adviser maintains documentation demonstrating that
it provides investment advice to clients exclusively through an interactive website.
Concreit notes that the Exemption from Prohibition on Commission Registration includes an
exception that would permit an adviser relying on the rule to advise clients through means other
than its interactive website, so long as the adviser had fewer than 15 of these non-Internet clients
during the preceding 12 months. Concreit also manages Concreit Fund I LLC (the “Fund” or the
“Offering”), and may manage additional Offerings that become available in the future. The Fund
1 An interactive website means a site in which computer software-based models or applications provide
investment advice based on personal information each client submits through the website.
filed an offering statement on Form 1-A, or the Offering Statement, with the SEC, on March 5,
2020, which was qualified by the SEC on May 21, 2020 (the “Offering”). On February 26, 2021,
the Fund filed for a post-qualification amendment with the SEC to update the business plan, as
well as, the redemption plan, distribution plan, retainment of services of Dalmore Group as broker-
dealers, among others, which was qualified by the SEC on May 13, 2021.
Individual Clients and Offerings are collectively referred to in this Brochure as Concreit’s “Clients.”
Individual Clients are encouraged to review the Offering Circular, prospectus, statement of
additional information, or other similar disclosures and governing documents of each Offering.
Advisory Services
Individual Clients
Concreit tailors its investment advice to the specific needs of Individual Clients. Through its
Platform, Concreit will seek information from Individual Clients such as age, investment
objectives, investment experience, time horizon, risk tolerance, exit timing, liquidity needs,
financial situation, and employment. Based on the Individual Client’s responses, Concreit may
recommend that an investment in its Offerings may not be suitable.
Through the Platform, investors can receive updates, make investments, enroll in auto-investment
plans, request redemptions, access account-related documentation and other account-related
functions.
An Individual Client's investment in an Offering may not exceed 10% of the greater of the
Individual Client’s annual income or net worth. Individual Clients are encouraged to review Rule
251(d)(2)(i)(C) of Regulation A under the Securities Act of 1933, as amended, for additional
information on this limitation. The Platform includes methodology to ensure that an Individual
Client’s total investments, including investments made through an automatic investment plan, do
not exceed 10% of the greater of the Individual Client’s annual income or net worth. If you attempt
to make an investment that exceeds these thresholds, you will not be able to complete the
intended investment, or you will be directed to invest a smaller amount.
Concreit, as the investment manager of the Offerings, has discretion with respect to the selection
of specific investments and the purchase and sale of assets within the Offerings. In addition, the
advice provided to Individual Clients is given on a discretionary basis. Individual Clients have the
discretion to decide to accept our recommended allocations in the Offerings, to select other
allocations, or to not invest. Once the Client selects an allocation, we manage the Client’s
investment on a discretionary basis.
Auto-Invest Function and Goals Feature
An Individual Client may establish an automatic investment plan through Concreit’s Auto-Invest
Function or “Goals” Feature for recurring
investments into the Offerings on a predefined schedule.
The Individual Client will be required to read the Offering Circular and any supplements.
Both the Auto-Invest Function and Goals Feature permit Concreit to periodically pull funds from
the Client’s account via ACH, in the frequency and amount as indicated by the Client via the
Platform. The Platform offers functionality whereby Clients, upon successful set of the Auto-
Invest Function or the Goals Feature, can indicate the amount and frequency of investments.
Clients can choose to enroll in the Auto-Invest Function or Goals Feature upon their initial account
opening, and anytime while their account remains active. Clients may terminate the Auto-Invest
Function or Goals Feature at any time by providing notice at least 5 business days prior to the
date the Client desires to terminate either of them via the Platform.
The Goals feature is a hypothetical guide for investors and not a guarantee for achieving the
desired outcome in a defined period of time. Concreit’s investment advisory services includes
advice to help investors achieve a particular set of financial goal(s) designated by them in their
account. The expected investment portfolio returns used in the goal forecast graph are based on
the hypothetical returns and/or historical returns of investments in the portfolio. Actual individual
investor performance results will vary depending on the market performance, the time of the initial
investment, amount and frequency of contributions or withdrawals, intraperiod allocation changes,
investment options, and taxes.
Concreit Fund I LLC
The Fund has engaged Concreit to manage the assets, operations and affairs of the Fund
pursuant to the Management Services Agreement, dated July 12, 2019 (the “Original
Management Agreement”) and the First Amended and Restated Management Services
Agreement, dated May 13, 2020 (the “Amended Management Services Agreement''). Concreit
provides asset management, marketing, investor relations, and other administrative services.
Concreit also manages all of the decisions regarding the selection, negotiation, financing and
disposition.
The Fund is a Delaware organized limited liability company formed to invest in and manage a
diversified portfolio of commercial real estate investments located in the United States and Real
Estate-Related Securities. The Fund expects to use substantially all of the net proceeds from the
Offering to originate, structure and acquire (i) commercial real estate, including industrial,
multifamily, office, retail and other real property types (“Direct CRE”) and (ii) real estate-related
securities, including equity and debt securities of both publicly traded and private companies,
including REITs and pass-through entities that own real property or loans secured by real estate,
including investments in commercial mortgage-backed securities and derivative instruments
(“Real Estate-Related Securities,” collectively with Direct CRE sometimes referred to as “Real
Estate Investments”).2
Concreit will seek to create and maintain a portfolio of investments that generate a low volatility
income stream of attractive, frequent, and consistent cash distributions. Our focus on investing in
debt instruments will emphasize the payment of current returns to investors and preservation of
2 Real Estate-Related Securities may include equity and debt securities of both publicly traded and private companies, including REITs
and pass-through entities that own real property or loans secured by real estate, including investments in commercial mortgage-
backed securities and derivative instruments.
invested capital. We also intend to diversify our portfolio by investing in equity instruments in real
estate-related companies, subject to certain limitations related to the Fund’s intended qualification
as a REIT and to maintain our exclusion under the Investment Company Act. We will also seek
to realize growth in the value of our investments by timing their sale to maximize value.
With the exception of offering our shares online through the Platform, our shares will be sold by
the Issuer. Please see the Offering Circulars for additional information about the Fund and other
Offerings (when available).
Redemption Plan
An individual Client can request to liquidate all or part of the securities in their account in
accordance with Concreit Fund I’s redemption plan. Concreit, at its discretion, reserves the right
to choose to redeem such Investor Shares presented for redemption for cash to the extent it has
sufficient funds available. There is no assurance that there will be sufficient funds available for
redemption nor that Concreit will exercise its discretion to redeem such Investor Shares and,
accordingly, a Member’s Investor Shares may not be redeemed in such redemption period, or at
any point thereafter.
Regulatory Assets Under Management
As of December 31, 2023, Concreit managed approximately $8,158,816 of regulatory assets
under management. The SEC has adopted a uniform method for advisers to calculate assets
under management for regulatory purposes which it refers to as an adviser’s “regulatory assets
under management.” Regulatory assets under management are generally an adviser’s gross
assets, i.e., assets under management without deduction for outstanding indebtedness or other
accrued but unpaid liabilities. Concreit reports its regulatory assets under management in Item 5
of Part 1 of Form ADV which you can find at www.adviserinfo.sec.gov.