A. Firm Information
Authentic Counsel, LLC (“WealthBuilders Investments ” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC)
in March 2011 under the laws of the State of Colorado. WealthBuilders Investments became a registered
investment advisor in January 2015 and is owned by CK Venture Holdings, LLC and WealthBuilders Holdings Corp.
The Advisor is operated by Chad Frantzen (Founder and Chief Compliance Officer). The Advisor conducts
business under WealthBuilders Investments. This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Authentic Counsel, LLC.
B. Advisory Services Offered
Authentic Counsel, LLC offers investment advisory services to individuals, high net worth individuals, trusts,
estates, businesses, and charitable organizations (each referred to as a “Client”).
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. WealthBuilders Investments' 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.
Investment Management Services
WealthBuilders Investments provides customized investment advisory solutions for its Clients. This is achieved
through continuous personal Client contact and interaction while providing discretionary and non-discretionary
investment management and related advisory services. WealthBuilders Investments works closely with each Client
to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a
portfolio strategy. WealthBuilders Investments will then construct an investment portfolio, consisting of low-cost,
diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The
Advisor may also utilize individual stocks, bonds, REITs or alternative investments to meet the needs of its Clients.
The Advisor may retain certain types of investments based on a Client’s legacy investments based on portfolio fit
and/or tax considerations.
WealthBuilders Investments’ investment approach is primarily long-term focused, but the Advisor may buy, sell or
re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. WealthBuilders Investments will construct, implement and monitor the portfolio to ensure it meets the
goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
WealthBuilders Investments evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. WealthBuilders Investments may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. WealthBuilders Investments may recommend specific positions to
increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible
hedge against market movement. WealthBuilders Investments may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk
tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
Use of Independent Managers
WealthBuilders Investments will recommend that Clients utilize one or more unaffiliated investment managers or
investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio,
based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence
over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and
overall best interests. The Advisor will also assist the Client in the development of the initial policy
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recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
For certain accounts, WealthBuilders Investments may recommend that all or a portion of a Client’s investment
portfolio be established through an online investment management program offered by WealthBuilders Investments
and the Custodian, Charles Schwab, Inc or LPL Financial. Under this service, Clients will engage WealthBuilders
Investments through an investment management agreement for these advisory services and then establish an
online account through Schwab Wealth Investment Advisory, Inc. (“SWII”), a subsidiary of Charles Schwab, Inc.
SWII is what is often termed a “robo-advisor”, an online wealth management service that provides automated,
algorithm-based portfolio management advice. Robo-advisors use technology to deliver similar services as
traditional advisors, but generally only offer portfolio management and do not get involved in a Client’s personal
situation, such as taxes and retirement or estate planning. WealthBuilders Investments chose to affiliate with SWII
due to the Investment Platform’s customized portfolio allocations, automated rebalancing, and competitive fees.
WealthBuilders Investments utilizes SWII to provide additional diversity, continuous rebalancing, and a rational and
balanced approach to the management of smaller accounts, generally lower than the Advisor’s required
relationship size.
WealthBuilders Investments will have the discretionary authority to instruct SWII with respect to portfolio
construction, asset allocation and other investment decisions, subject to the limitations described herein. SWII will
implement the portfolio and be responsible for the discretionary trading of the ETFs in the Client’s portfolio,
including the purchase and sale of investments and the automatic rebalancing back to targets.
SWII utilizes ETF’s, representing various asset classes for the construction of investment portfolios. As discussed
above, WealthBuilders Investments will work with each Client to select/construct a portfolio to meets the needs of
the Client. The Client has limited ability to put restrictions on its accounts. The account[s] cannot contain
investments that are not included in the SWII universe of ETFs and cash equivalents.
WealthBuilders Investments will delegate limited investment discretion to SWII to implement trading and
rebalancing within the parameters of the Advisor’s investment strategies. The Advisor’s investment philosophy is
long-term, but the Advisor may make such tactical overrides to take advantage of market pricing anomalies or
strong market sectors. The Advisor will not actively trade in the Client’s account[s]. Client accounts must maintain a
minimum balance of $5,000 to be eligible for automatic rebalancing.
For its services, SWII will charge an asset-based fee that is in addition to the Advisor’s fee. SWII’s fee includes the
securities transaction fees for all trades. The Advisor will only receive its investment advisory fees as detailed in
Item 5.A. below and does not share in any fees earned by SWII.
The Advisor will provide the Client with SWII’s current Form ADV2A – Disclosure Brochure (or a brochure that
contains all required disclosures). The Advisor’s investment advisory fee is added to the SWII platform fee, which
also includes securities transaction fees. The Advisor does not share in any fees charged by SWII. The Advisor
shall only earn its fees as described in Item 5 below. For additional information regarding the brokerage practices
for
SWII accounts, please see Item 12.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
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At no time will WealthBuilders Investments accept or maintain custody of a Client’s funds or securities, except for
the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage
Practices.
Private Fund Management Services
WealthBuilders Investments serves as investment adviser to Solomon Fund I, LP (the “Fund”) an exempt-from-
registration pooled investment vehicle.
Solomon Fund I GP, LLC, an affiliated entity, will serve as the general partner of the Fund. Thus, WealthBuilders
Investments will not be independent of the Fund. Also refer to Item 5 – Fees and Compensation, Item 10 – Other
Financial Industry Activities and Affiliations, and Item 16 – Custody of this Disclosure Brochure for more
information.
The service is detailed in the offering document of the Fund, which include as applicable, operating agreements,
private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and
all amendments thereto (“Offering Document”).
The Advisor manages the Fund based on the investment objectives, policies and guidelines as set forth in the
respective Offering Document and not in accordance with the individual needs or objectives of any particular
investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription
agreement in which the prospective investor attests as to whether or not such prospective investor meets the
qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with
such an investment. In general, investors in the Funds are not permitted to impose restrictions or limitations.
The Advisor will recommend that certain Clients invest in the Fund. The recommendation to invest in the Fund
poses a conflict between the interests of the Advisor and the interests of the Client, as the Advisor is incentivized to
increase the amount of assets in the Fund, not already managed by the Advisor, in order to increase the revenue
generated to the Advisor. This conflict is mitigated as Clients will only pay the asset-based fee as described in the
Offering Document. The Advisor will not receive investment advisory fees for its management of assets invested in
the Fund. Clients of the Advisor are under no obligation to invest in the Fund.
For more detailed information on investment objectives, policies and guidelines, please refer to the Fund’s
Offering Document.
Financial Planning Services
WealthBuilders Investments will typically provide a variety of financial planning and consulting services to Clients,
pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial
situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a
formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and
objectives. This planning or consulting may encompass one or more areas of need, including but not limited to,
investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of
a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
WealthBuilders Investments may also refer Clients to an accountant, attorney or other specialists, as appropriate
for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary. Plans or consultations are typically completed within six (6) months of
contract date, assuming all information and documents requested are provided promptly.
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Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
C. Client Account Management
Prior to engaging WealthBuilders Investments to provide investment advisory services, each Client is required to
enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities
of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – WealthBuilders Investments, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – WealthBuilders Investments will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – WealthBuilders Investments will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – WealthBuilders Investments will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
WealthBuilders Investments includes, in addition to administrative fees (herein “Covered Costs together with its
investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”.
The Advisor customizes its investment management services for its Clients. The Advisor sponsors the
WealthBuilders Investments Wrap Fee Program solely as a supplemental disclosure regarding the combination of
fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay
more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee
Program Brochure, which is included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, WealthBuilders Investments manages $121,666,733 in Client assets, $120,722,855 of
which are managed on a discretionary basis and $943,878 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.