Firm Information
Acorn Creek Capital LLC (“Acorn Creek” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission. The Advisor is organized as a limited liability company under the laws of the
State of Colorado. Acorn Creek was founded in April 2023 and is wholly owned and operated by Ben Loeffler
(President). This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Acorn Creek.
Advisory Services Offered
Asset Management:
As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange
traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the previously
mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to
the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and
regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and
objectives.
Our firm utilizes the sub-advisory services of a third party investment advisory firm or individual advisor to aid in the
implementation of an investment portfolio designed by our firm. Before selecting a firm or individual, our firm will
ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific
securities or other investments in connection with this service. We will provide initial due diligence on third party
money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of
a third party money manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review third party money manager reports provided to the client at least annually. Our firm
will contact clients from time to time in order to review their financial situation and objectives; communicate
information to third party money managers as warranted; and, assist the client in understanding and evaluating the
services provided by the third party money manager. Clients will be expected to notify our firm of any changes in
their financial situation, investment objectives, or account restrictions that could affect their financial standing.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Acorn Creek's fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Comprehensive Portfolio Management:
As part of our Comprehensive Portfolio Management service clients will be provided asset management and
financial planning or consulting services. This service is designed to assist clients in meeting their financial goals
through the use of a financial plan or consultation. Our firm conducts client meetings to understand their current
financial situation, existing resources, financial goals, and tolerance for risk. Based on what is learned, an
investment approach is presented to the client, consisting of individual stocks, bonds, ETFs, options, mutual funds
and other public and private securities or investments. Once the appropriate portfolio has been determined,
portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual
needs, stated goals and objectives. Upon client request, our firm provides a summary of observations and
recommendations for the planning or consulting aspects of this service.
Our firm utilizes the sub-advisory services of a third party investment advisory firm or individual advisor to aid in the
implementation of an investment portfolio designed by our firm. Before selecting a firm or individual, our firm will
ensure that the chosen party is properly licensed or registered. Our firm will not offer advice on any specific
securities or other investments in connection with this service. We will provide initial due diligence on third party
Page 5
money managers and ongoing reviews of their management of client accounts. In order to assist in the selection of
a third party money manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account. Our firm will
periodically review third party money manager reports provided to the client at least annually. Our firm will contact
clients from time to time in order to review their financial situation and objectives; communicate information to third
party money managers as warranted; and, assist the client in understanding and evaluating the services provided
by the third party money manager. Clients
will be expected to notify our firm of any changes in their financial
situation, investment objectives, or account restrictions that could affect their financial standing.
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the management
of financial resources based upon an analysis of current situation, goals, and objectives. Financial planning
services will typically involve preparing a financial plan or rendering a financial consultation for clients based on the
client’s financial goals and objectives. This planning or consulting may encompass Investment Planning,
Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax
Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance
Analysis, Lines of Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general recommendations for a
course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at
the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for
financial planning engagements. Financial consultations are not typically accompanied by a written summary of
observations and recommendations, as the process is less formal than the planning service. Assuming that all the
information and documents requested from the client are provided promptly, plans or consultations are typically
completed within 6 months of the client signing a contract with our firm.
Retirement Plan Consulting:
Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally,
such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their
company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may
include:
• Establishing an Investment Policy Statement – Our firm will assist in the development of a statement
that summarizes the investment goals and objectives along with the broad strategies to be employed
to meet the objectives.
• Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options
and make recommendations for appropriate changes.
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation models to
aid Participants in developing strategies to meet their investment objectives, time horizon, financial
situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and notify the client
in the event of over/underperformance and in times of market volatility.
• Participant Education – Our firm will provide opportunities to educate plan participants about their
retirement plan offerings, different investment options, and general guidance on allocation strategies.
In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to
the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded
REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window
programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the
applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or
Page 6
other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services
to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of
ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services
described therein.
Tailoring of Advisory Services
Our firm offers individualized investment advice to our Asset Management and Comprehensive Portfolio
Management clients.
General investment advice will be offered to our Financial Planning & Consulting, Retirement Plan Consulting, and
Referrals to Third Party Money Management clients. Each Asset Management or Comprehensive Portfolio
Management client has the opportunity to place reasonable restrictions on the types of investments to be held in
the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the
level of difficulty this would entail in managing the account.
Participation in Wrap Fee Programs
Acorn Creek does not manage or place Client assets into a wrap fee program.
Assets Under Management
As of December 31, 2023, Acorn Creek manages $421,257,258in Client assets, $400,932,977 of which are
managed on a discretionary basis and $20,324,281 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.