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Brochure
March 30, 2025
CALLAN FAMILY OFFICE, LLC
a Registered Investment Adviser
201 King of Prussia Road, Suite 650
Radnor, PA 19087
(877) 506-7990
www.callanfamilyoffice.com
Callan Family Office LLC
Disclosure Brochure
Item 2. Material Changes
In this Item, Callan Family Office is required to discuss any material changes that have been made to the
brochure since the last update September 20, 2024 . The Firm has updated Items under Item 4c regarding
Business and Transition Advisory Services, Family Office Consulting, Foundation and Philanthropic
Administration. The Firm also updated the risks discussed in Item 8 to include disclosure about
concentrated positions for certain client assets that are invested through its Global 25 Portfolio.
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Item 3. Table of Contents
Item 2. Material Changes
2
Item 3. Table of Contents
3
Item 4. Advisory Business
4
Item 5. Fees and Compensation
7
Item 6. Performance-Based Fees and Side-by-Side Management
9
Item 7. Types of Clients
10
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
10
Item 9. Disciplinary Information
17
Item 10. Other Financial Industry Activities and Affiliations
17
Item 11. Code of Ethics
18
Item 12. Brokerage Practices
18
Item 13. Review of Accounts
22
Item 14. Client Referrals and Other Compensation
23
Item 15. Custody
23
Item 16. Investment Discretion
24
Item 17. Voting Client Securities
24
Item 18. Financial Information
25
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Item 4. Advisory Business
A. Introduction
Callan Family Office offers a variety of advisory services, which include financial planning, consulting,
and investment management services. Prior to Callan Family Office rendering any of the foregoing
advisory services, clients are required to enter into one or more written agreements with Callan
Family Office setting forth the relevant terms and conditions of the advisory relationship (the
“Advisory Agreement”). While this brochure generally describes the business of Callan Family Office,
certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers,
partners, directors (or other persons occupying a similar status or performing similar functions),
employees or other persons who provide investment advice on Callan Family Office’s behalf and are
subject to the Firm’s supervision or control. Callan Family Office filed for registration as an investment
adviser in December 2021 and is owned by Plectrum LLC, DCH Capital Management LLC, Toxaway LLC,
Blue Wolf Ventures LLC, Laker Capital LLC, Ram Private Holdings LLC, JAWS Capital I LLC, Yellow Springs
LLC, BOPL LLC, WTNGrace Holdings, LLC, Fleetwood d’Elegance LLC, Jcubed3 LLC, Magevney Capital
LLC, Windy Knoll LLC, Wondra Investments LLC, Taughannock LLC, Tavyke Farm LLC, Wooded Acres
LLC Mark Frazier, Aris Investment Holdings LLC, Tom Raymond, Ronald Lennie Bell, Amy Jucoski and
Jeremy Rice. As of December 31, 2024, Callan Family Office has $6,669,553,323 in assets under
management; $5,914,294,645 of which was managed on a discretionary basis and $755,258,678 of
which was managed on a non-discretionary basis.
B. Investment and Wealth Management Services
Callan Family Office manages client investment portfolios on a discretionary and non-discretionary
basis. In addition, Callan Family Office provides most clients with wealth management services which
include a broad range of financial planning and consulting services.
Callan Family Office primarily allocates client assets among various third-party independent managers
(also called separate account managers, model managers, and, herein, “Independent Managers”), use
of direct indexing capabilities, and privately placed securities (including debt, equity, real assets,
and/or interests in pooled investment vehicles) in accordance with their stated investment objectives.
While in most cases the Independent Managers will recommend individual debt and equity securities
(among other investments including mutual funds and exchange-traded funds (“ETFs”)), the Firm will
also directly manage such investments in certain circumstances.
Where appropriate, the Firm may also provide advice about any type of legacy position or other
investment held in client portfolios, but clients should not assume that these assets are being
continuously monitored or otherwise advised on by the Firm unless specifically agreed upon.
Callan Family Office tailors its advisory services to meet the needs of its individual clients and seeks
to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those
needs and objectives. Callan Family Office consults with clients on an initial and ongoing basis to
assess their specific risk tolerance, time horizon, liquidity constraints and other related factors
relevant to the management of their portfolios. Clients are advised to promptly notify Callan Family
Office if there are changes in their financial situation or if they wish to place any limitations on the
management of their portfolios. Clients can impose reasonable restrictions or mandates on the
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management of their accounts if Callan Family Office determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome
to the Firm’s management efforts.
C. Financial Planning and Advisory and Consulting Services
Callan Family Office offers family office services which include financial planning, financial
administration, bill pay, historical performance reporting, data aggregation, document safe-keeping
and exchange, philanthropic consulting, foundation and philanthropic administration, business and
transaction advisory services, family office consulting, and family governance and education. The Firm
provides these services to families as a complement to their investment services. These consultative
services and financial education are principally being used for successor generations. Callan Family
Office’s financial administration services team can assist clients in collecting, storing and
processing bill payments as needed, as well as aggregate personal and business data into
financial statements to track and report on assets, liabilities, equity, and cash flows, at a
detailed level. Data aggregation provides an administrative accounting of all assets held by clients
irrespective of whether they are managed by Callan Family Office or by another provider.
Callan Family Office's Advisory and Consulting Practice revolves around the Firm’s philanthropic,
family governance and education programs for individual clients, their families, foundations and
endowments. In addition to the advice and consulting around client specific topics, best practices, and
thought leadership, the Firm offers numerous programs to support families in achieving their
charitable and legacy goals. The Firm believes that a well-crafted, meaningful family road map
reflective of family values, strengths, and priorities can successfully live on for multiple generations.
In performing these services, Callan Family Office is not required to verify any information received
from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is
expressly authorized to rely on such information. Callan Family Office recommends certain clients
engage the Firm for additional related services and/or other professionals to implement its
recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend
that clients engage Callan Family Office or its affiliates to provide (or continue to provide) additional
services for compensation, including investment management services. Clients retain absolute
discretion over all decisions regarding implementation and are under no obligation to act upon any of
the recommendations made by Callan Family Office under a financial planning or consulting
engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any
change in their financial situation or investment objectives for the purpose of reviewing, evaluating,
or revising Callan Family Office’s recommendations and/or services.
D. Use of Independent Managers
Callan Family Office provides investment management services through a variety of products and
investment vehicles. These include but are not limited to separately managed accounts, model
managed accounts, mutual funds, ETFs and other pooled or collectively managed funds. As
mentioned above, Callan Family Office selects certain Independent Managers to actively manage a
portion of its clients’ assets on either a discretionary or non-discretionary basis. The specific terms
and conditions under which a client engages an Independent Manager are set forth in a separate
written agreement with the designated Independent Manager. That agreement can be between the
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Firm and the Independent Manager (often called a subadvisor), the Firm and an Independent Manager
delivering a model portfolio on a non-discretionary basis (often called model delivery), or the client
and the Independent Manager. In addition to this brochure, clients can also receive the written
disclosure documents of the respective Independent Managers engaged to manage their assets on
request.
Model Delivery
For certain investments, Callan Family Office may utilize a third-party investment manager’s model
portfolio (“Model”) to deliver and implement an Independent Manager, Research Provider, or Sub-
Adviser’s strategy. Callan Family Office may utilize a manager’s Model when Callan Family Office
believes that value can be added in terms of lowering overall investment and trading expenses,
increasing tax-efficiency of the strategy, or enabling customization and personalization of the
strategy, as well as in cases when the manager only offers its strategy through Model Delivery. In
implementing a Model, Callan Family Office will use its discretion to determine the timing and manner
of such implementation, and, if appropriate, will take other factors into consideration affecting the
management of the underlying Client account. Factors such as capital gain or loss management, client
preferences, and systematic tracking-error-based rebalancing may cause the client account to vary
from the underlying Model. In addition, account performance and risk measures may vary from the
Model and differ from a fully delegated separately managed account that does not account for these
client-specific circumstances. These services may be provided directly by Callan Family Office or by a
third-party, and fees may apply.
Direct Indexing
Passive investment allocations may be implemented in part, or in whole, through Direct Indexing.
Direct Indexing involves purchasing a subset of the underlying shares of a reference index with the
goal of realizing a return and volatility like the reference index while achieving one or more client-
specific goals. These client goals may include tax-loss harvesting, customization of the underlying
index constituents, factor or style tilts, applying security restrictions, or incorporating an investor’s
ESG/SRI criteria. Direct Indexing accounts do not typically own all the securities in a reference index,
and therefore will experience tracking error to the underlying index returns. Performance variations
could be positive or negative, and volatility could be higher or lower than the index. Factor exposures,
realized tax losses, ESG/SRI criteria, and other Direct Index metrics will fluctuate based on market
conditions, and outcomes will be unique to each client’s situation and strategy. Direct Index strategies
require ongoing trading and rebalancing to maintain alignment between the client account and the
reference index, and rebalancing decisions consider one or multiple client goals or restrictions that
have been specified for the Direct Index account. Direct Indexing services rely heavily on technological
services which may be interrupted by unforeseen forces. These services may be provided directly by
Callan FO or by a third-party, and fees may apply.
Overlay Services
In some circumstances, Callan Family Office may employ Overlay Services to provide better
coordination of investment strategies across the various sub-advisors within a client portfolio or
across related portfolios in a client household. Callan Family Office will use its discretion to determine
the extent and approach of such services with the goal to create value through actions such as wash
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sale avoidance, tax lot management, capital gain deferral, management of loan to value or margin
levels, targeting client-specified total portfolio characteristics (i.e. yield, quality, etc.), options overlay,
and management of variance of the portfolio relative to targets or benchmarks. Given the high level
of customization required, these services are provided on a best-efforts basis and client acknowledges
that performance and general outcomes are unique to their situation. These services may be provided
directly by Callan Family Office or by a third-party, and fees may apply. The nature and extent of the
services, including risk and liability exposure, shall be reflected in that fee.
To the extent that Callan Family Office provides Model Delivery, Direct Index, or Overlay Services
directly to clients, the firm can charge a fee and earn additional revenue for its services. Callan Family
Office offers these services directly to clients, as opposed to using a third-party solution, when the
firm believes it can reduce overall investment expenses, increase tax-efficiency, meet client demand
for personalization, provide household-level coordination of investment strategies, or provide other
technology capabilities that are not readily available to clients via third-party solutions.
When model delivery, direct index, and overlay services are provided by Callan Family Office, the Firm
will use the technology and capabilities of Aris Investing LLC (“Aris”). As disclosed in this Brochure,
the Independent Manager fees are in addition to those charged by the Firm. Aris is affiliated with the
Firm through common ownership which creates a conflict of interest as there is an incentive to
recommend Aris over another third-party that could provide similar services. The Firm will only
engage Aris if the services and fees are in the best interest of the client and the service is reasonably
expected to improve the net of fee, net of tax results for the client.
Item 5. Fees and Compensation
Callan Family Office offers services on a fee basis, including fixed, and fees based on assets under
management.
A. Family Office Services and Advisory and Consulting Fees
Callan Family Office may charge a fixed fee or on-going fee for providing Family Office Services and
Advisory and Consulting under a stand-alone engagement. These fees are negotiable, but typically
range from $50,000 to $250,000, subjective to the scope and complexity of the services and the
professional rendering the services. The fee can be for a defined project, or for ongoing services. If
the client engages the Firm for additional investment advisory services, Callan Family Office can offset
all or a portion of its fees for those services based upon the amount paid for the financial planning
and/or consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the
Administrative Services Agreement or Advisory Consulting Agreement. For project-based services,
Callan Family Office requires up to one-half of the fee (estimated hourly or fixed) payable upon
execution of the Agreement. The outstanding balance is due upon delivery of the financial plan or
completion of the agreed upon services. Ongoing services are charged as described in the investment
management section, below. The Firm does not, however, take receipt of $1,200 or more in prepaid
fees, six or more months in advance of services rendered.
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B. Investment and Wealth Management Fees
Callan Family Office offers its investment management and wealth management services for an
annual fee based on the amount of assets under the Firm’s management. Depending upon the size
and composition of a client’s portfolio, the type and amount of services rendered and the
individual(s) providing the services this management fee varies between 15 and 75 basis points
(0.15% – 0.75%).
The annual fee is prorated and charged monthly, in arrears, based upon the market value of the
assets being managed by Callan Family Office on the last day of the previous month as determined
by a party independent from the Firm (including the client’s custodian or another third-party, as well
as the issuers of privately placed securities).
If assets are deposited into or withdrawn from an account after the start of a billing period, the fee
payable with respect to such assets is not adjusted to reflect the interim change in portfolio value.
For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the
advisory agreement is terminated, the fee for the final billing period is prorated through the
effective date of the termination and the outstanding or unearned portion of the fee is charged or
refunded to the client, as appropriate. Independent Managers, including Aris, can bill differently
(frequency and timing) and the Firm will utilize the billing procedures of those Independent
Managers when assets are allocated to them.
Additionally, for asset management services the Firm provides with respect to certain client holdings
(e.g., held-away assets, accommodation accounts, alternative investments, etc.), Callan Family
Office can negotiate a fee rate that differs from the range set forth above. Clients are advised that a
conflict of interest exists for the Firm to recommend that clients engage Callan Family Office for
additional services for compensation, including rolling over retirement accounts or moving other
assets to the Firm’s management. Clients retain absolute authority over all decisions regarding
engaging the Firm and are under no obligation to act upon any of the recommendations.
C. Fee Discretion
Callan Family Office may, in its sole discretion, negotiate to charge a lesser fee based upon certain
criteria, such as but not limited to, anticipated future earning capacity, anticipated future additional
assets, dollar amount of assets to be managed, related accounts, account composition, pre-
existing/legacy client relationship, account retention, pro bono activities, or competitive purposes.
D. Additional Fees and Expenses
In addition to the advisory fees paid to Callan Family Office, clients can also incur certain charges
imposed by other third parties, such as broker-dealers, custodians, technology fees, trust
companies, banks, and other financial institutions (collectively “Financial Institutions”). These
additional charges include securities brokerage commissions, transaction fees, custodial fees, fees
attributable to alternative assets, reporting charges, technology fees, fees charged by the
Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual
fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees
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and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer
and electronic fund fees, trustee fees ,and other fees and taxes on brokerage accounts and
securities transactions. The Firm’s brokerage practices are described at length in Item 12, below.
If Callan Family Office incurs any costs (including attorneys’ fees and expenses) in responding to
legal process related to the client’s account, Callan Family Office may charge these costs to any
account client maintains with Callan Family Office.
E. Direct Fee Debit
Clients provide Callan Family Office and/or certain Independent Managers with the authority to
directly debit their accounts for payment of the investment advisory fees. The Financial Institutions
that act as the qualified custodian for client accounts, from which the Firm retains the authority to
directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all
account transactions, including any amounts paid to Callan Family Office.
F. Use of Margin
Clients can authorize Callan Family Office to use margin in the management of the client’s
investment portfolio. In these situations, the fee payable will be assessed gross of margin such that
the market value of the client’s account and corresponding fee payable by the client to Callan Family
Office will be increased. Where investment management fees are assessed gross of margin, a
conflict of interest exists as the Firm has an incentive to use margin to increase its fees.
In addition, Callan Family Office can recommend that certain clients utilize margin in the client’s
investment portfolio or other borrowing for non-investment needs, such as bridge loans and other
financing needs. The Firm’s fees are determined based upon the value of the assets being managed
gross of any margin or borrowing.
G. Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to Callan
Family Office’s right to terminate an account. Additions can be in cash or securities provided that
the Firm reserves the right to liquidate any transferred securities or declines to accept particular
securities into a client’s account. Clients can withdraw account assets on notice to Callan Family
Office, subject to the usual and customary securities settlement procedures. However, the Firm
designs its portfolios as long-term investments, and the withdrawal of assets may impair the
achievement of a client’s investment objectives. Callan Family Office may consult with its clients
about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, short-term
redemption fees, fees assessed at the fund level (e.g., re-registration fees ) and/or tax ramifications.
Item 6. Performance-Based Fees and Side-by-Side Management
Callan Family Office does not provide any services for a performance-based fee (i.e., a fee based on a
share of capital gains or capital appreciation of a client’s assets).
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Item 7. Types of Clients
Callan Family Office offers services to individuals, trusts, estates, charitable organizations, corporations,
limited partnerships, and other business entities.
Minimum Account Value
As a condition for starting and maintaining an investment management relationship, Callan Family Office
imposes a minimum portfolio value of $50,000,000. Callan Family Office may, in its sole discretion, accept
clients with smaller portfolios based upon certain criteria, including anticipated future earning capacity,
anticipated future additional assets, dollar amount of assets to be managed, related accounts, account
composition, pre-existing client, account retention, and pro bono activities. Callan Family Office only
accepts clients with less than the minimum portfolio size if the Firm determines the smaller portfolio size
will not cause a substantial increase of investment risk beyond the client’s identified risk tolerance. Callan
Family Office may, in its sole discretion, aggregate the portfolios of family members to meet the minimum
portfolio size.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Serving as the client’s out-sourced chief investment officer, Callan Family Office will make asset
management decisions across a global opportunity set inclusive of liquid and illiquid investments and
utilizing both passive and active solutions. Discretion over these assets will vary from full authority to
consultative.
In general, Callan Family Office believes value can be added by offering institutional-grade solutions and
processes to their client’s investment portfolio. The goal is to enhance return and/or minimize risk at each
step of the investment process- summarized as follows:
•
Client Discovery & Planning
•
Asset Allocation & Modeling
•
Due Diligence & Research
•
Portfolio Construction & Management
•
Risk Management & Review
Foundational to the Firm’s approach is a reliance on fundamental analysis to evaluate the risk and reward
of each asset class, fund or security held in a client’s portfolio. Discounted future cash flows, relative
valuations, and asset class appropriate financial metrics are among a broad array of analytics employed
to consider the merits of each investment. The goal is to achieve the best total, net, real return for clients
to realize their unique goals while minimizing taxes, fees, volatility, and the effects of inflation over time.
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A. Client Discovery & Planning
Callan Family Office believes that a critical first step and ongoing aspect of client engagement and
effective asset management centers around client discovery and planning. An exhaustive and
comprehensive dialogue with clients to clearly identify and enunciate both qualitative and
quantitative variables that thereby establishes appropriate expectations and is a necessary part
of successful long-term relationships. A combination of financial planning, estate planning and
investment policy review is often integrated to understand the client architecture and overarching
goals and objectives.
Measures of risk tolerance, liquidity preference, time horizon, taxability, restrictions, and income
requirements are gathered alongside understanding client investment experience, return
expectations and prior investment decisions. Taken together, they form the basis for a written
investment policy statement(s) which guides the governance of the client assets and provides an
investable universe and benchmarks for future comparison.
Through clear, open, and consistent communication, the Firm strives to reduce risks, educate the
client, collaborate with outside advisors and family members, increase the range of opportunities,
and improve the probability of successful client outcomes.
B. Asset Allocation & Modeling
The Firm develops long-term Capital Market Assumptions, which serve as the key inputs for our
strategic asset allocation process. These projections establish risk and return expectations for
each asset class and estimate the correlations on how the different asset classes are interrelated.
Efficient frontiers are generated from these assumptions that serve as the basis for a range of
taxable, tax free, liquid, illiquid, and various time horizon investor profiles. Current valuations and
recent market performance can affect these projections and subsequently revisited periodically,
but no less than annually.
A set of Investment Objectives with progressive levels of risk (volatility) are derived from the
varying efficient frontiers. Each objective will have specific asset class targets and ranges that
optimize the return for a given level of risk. Throughout an investment mandate, Investment
Policy Statements are established and maintained that articulate the various objectives and
include strategic targets and ranges to keep the risk parameters within acceptable bounds and
instill a level of portfolio management discipline.
Callan LLC and several third-party research providers provide analytical support for investment
models and research content to inform our views of the current and long-term market
environment including the formation of the Firm’s Capital Market Assumptions. There is an
intentional, holistic selection process that ensures we have balanced views across assets classes
in effort to avoid any bias and a diversity of market and economic perspectives. These
relationships are periodically reviewed to confirm that we are receiving thoughtful advice and add
value to our investment decision-making process.
Within the Firm’s long-term, strategic framework, Callan Family Office monitors market
developments on a regular basis to identify emerging opportunities, risks, or trends that should
be considered as part of a tactical opportunity to reposition the portfolio. All tactical positions or
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tilts are incorporated in our ongoing portfolio management and rebalancing program. Research
to support these positions is gathered internally and externally from multiple third-party
providers, which is aggregated to summarize the overall risk posture of the portfolios in the broad
market.
C. Due Diligence and Research
Callan Family Office employs a deep fundamental research approach to evaluating all investment
opportunities regardless of how they are presented. The Firm maintains a long-term investment
horizon and seek to invest our client’s portfolios globally. Callan Family Office is unconstrained
and open-minded in our pursuit of superior investments with favorable risk-return profiles, but,
at the same time, selective in our choices. The Firm’s investment professionals employ economic
and market research as they serve as both Portfolio Managers and Research Analysts. The Firm
constantly collects and analyzes economic and capital market data, and third-party
strategy/analysis from public and private sources. Callan Family Office values diverse viewpoints
amongst its sources, and its team.
Callan LLC is the Firm’s primary research partner and relies heavily on them for much of the
investment offering. (Callan Family Office (CFO) is the exclusive trademark licensee of Callan LLC.
Callan LLC provides products and services to CFO. Clients of CFO are not clients of Callan LLC, and
the parties are not affiliated. Callan LLC, CFO and the other Callan trademarks and service marks
are registered and/or unregistered trademarks of Callan LLC and may not be used without its
permission.) Callan Family Office supplements its research and technology through several third-
party providers. The Firm receives a plethora of perspectives from its investment managers,
engages with industry luminaries, and continually evaluates and pursues additional value-add
insight providers. Callan Family Office works with all its research partners for searches, pipeline
evaluation, analysis, and monitoring. Manager and product decisions and ratings are devised
through a formal process, maintained, and updated when needed by Callan Family Office.
The Firm manages customized individual securities portfolios, at client request, through a
combination of quantitative and qualitative analysis. For equity mandates, the process is designed
to provide Portfolio Managers with a diverse list of high-quality US large cap companies to
construct a portfolio that achieves a client’s strategy. Callan Family Office's coverage list is
monitored for ongoing changes and renewed/approved quarterly. For fixed income mandates,
the Firm works with third party managers to develop a strategy and security selection that fulfills
a client’s objective.
D. Portfolio Construction & Management
Callan Family Office focuses on constructing investment portfolios that help clients achieve their
goals and objectives. Generally, this involves an emphasis on total net returns after accounting
for expenses and taxes. Typically, we employ a Core-Satellite approach in which both passive and
active management strategies are utilized. Where appropriate, we will utilize technology to
implement a combination of both direct indexing, model delivery, and some overlay management
to affect a higher level of efficiency for client benefit. In addition, we may incorporate the use of
illiquid investments to complement a client’s liquid holdings and enhance a portfolio’s risk and
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return prospects. These illiquid investments may include hedge funds and private capital
investments in debt, equity, and real assets.
Callan Family Office incorporates diversification, a primary risk management technique, across,
and within, each of the major asset classes of equity, fixed income, cash, real assets, and
alternatives (private capital and hedge funds). Ordinarily, the Firm’s core positions are broadly
diversified, long-term, strategic, passive positions which are then complemented by more focused
or concentrated investments (i.e., satellite) that represent higher conviction or tactical positions.
Callan Family Office believes this combination of core and satellite investments delivers an
improved risk-adjusted, and more tax sensitive, return for clients over time. Reference Portfolios
are developed to meld Callan Family Office's recommended investment objectives with specific
investment managers that work together in a portfolio context to maximize the after- tax and/or
after-fee return given a client’s risk tolerance. The managers that are included in the reference
portfolios serve as a guide to represent the highest conviction ideas and combination of positions
that harness the performance drivers the Firm seeks for each objective.
E. Risk Management & Review
The final, recurring, part of the Firm’s process is risk management and review. At the investor
level, it is influenced by a broad array of circumstances and objectives that Callan Family Office
strives to thoroughly understand and goes about this discovery work by examining two categories
– ability and willingness to take risk.
An investor’s ability to assume risk can be formulaic in that cash needs, time horizon, investment
experience, illiquidity tolerance, and other similar aspects can lead to clear decisions on what
asset classes are appropriate. Willingness to take risk is more subjective and often related to
investing experience and, notably, enduring more difficult market environments.
Callan Family Office’s goal is an optimal match of a portfolio that considers these risk factors.
Further, we know that circumstances and objectives can change and so too will an investor’s
profile as such our discovery work is on-going. Lastly, as a fiduciary under the Investment Advisers
Act of 1940, Callan Family Office always embeds risk considerations into its decision-making.
Risk is multi-dimensional and often defined as a permanent loss of capital which can be brought
on by selling into a distressed market. To understand this, the Firm analyzes several risk measures
(such as volatility, drawdown, credit quality, lack of marketability, etc.) but also recognizes their
limitations. Periodic portfolio reviews encompass performance, position analysis, along with risk
metrics, such as standard deviation. These reviews occur routinely and with client participation.
Performance is most often measured against a portfolio-level benchmark and/or client specific
goals. Performance of the portfolio is considered both in terms of return and the risks incurred
to achieve the results.
Stated Investment Objectives and/or specific client goals, are documented within the Investment
Policy Statement to be monitored by the portfolio managers and used for account reviews.
Enhanced software programs aid this process. These enabled systems will generate reports that
monitor portfolio holdings and activity relative to stated goals, positions, and ranges, which
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ushers in discipline and accountability for the Firm’s investment professionals. For all exceptions,
portfolio managers rebalance the portfolio back to within acceptable limits unless extenuating
circumstances exist.
F.
In Summary
Callan Family Office relies on an investment process built from the multiple decade experiences
of its investment professionals. Each stage of the process is critical to support an effective set of
portfolio results for the client. The Firm has committed to each part of the process and seeks
ways to continually improve each section over time.
G. Risks in General
The following list of risk factors does not purport to be a complete enumeration or explanation of
the risks involved with respect to the Firm’s investment management activities. Clients should
consult with their legal, tax, and other advisors before engaging the Firm to provide investment
management services on their behalf.
H. Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly. The profitability of a significant portion of Callan Family Office’s recommendations
and/or investment decisions may depend to a great extent upon correctly assessing the future
course of price movements of stocks, bonds, and other asset classes. In addition, investments
may be adversely affected by financial markets and economic conditions throughout the world.
There can be no assurance that Callan Family Office will be able to predict these price movements
accurately or capitalize on any such assumptions.
I. Volatility Risks
The prices and values of investments can be highly volatile, and are influenced by, among other
things, interest rates, general economic conditions, the condition of the financial markets, the
financial condition of the issuers of such assets, changing supply and demand relationships, and
programs and policies of governments.
J. Cash Management Risks
The Firm may invest a portion of a client’s assets temporarily in money market funds or other
similar types of investments, during which time an advisory account may be prevented from
achieving its investment objective.
K. Illiquidity Risks
The Firm may employ strategies that invest in illiquid investments for either Qualified Purchasers
or Accredited Investors in the normal course of business. These illiquid investments will be
directly overseen by Third Party Managers who specialize in these vehicles. These investments
have unique risks inherent in their strategies, such as; Key Person Risk, Mis-sized positions,
Geopolitical, Leverage, and Exit Strategy Impairment.
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L. Lack of Diversification
The Firm will invest certain client assets through its Global 25 Portfolio. The Global 25 Portfolio
holds a limited number of securities in comparison to other portfolios. Holding fewer securities
increases volatility of returns.
M. Equity-Related Securities and Instruments
The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national
securities exchanges and over-the-counter markets. The value of equity securities varies in
response to many factors. These factors include, without limitation, factors specific to an issuer
and factors specific to the industry in which the issuer participates. Individual companies may
report poor results or be negatively affected by industry and/or economic trends and
developments, and the stock prices of such companies may suffer a decline in response. In
addition, equity securities are subject to stock risk, which is the risk that stock prices historically
rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of
substantial price volatility in the past and may do so again in the future. In addition, investments
in companies that have market capitalizations smaller than $10 billion and/or financially
distressed companies may be subject to more abrupt or erratic price movements and may lack
sufficient market liquidity, and these issuers often face greater business risks.
N. Fixed Income Securities
While the Firm emphasizes risk-averse management and capital preservation in its fixed-income
bond portfolios, clients who invest in this product can lose money, including losing a portion of
their original investment. The prices of the securities in our portfolios fluctuate. The Firm does
not guarantee any specific level of performance. Below is a representative list of the types of risks
clients should consider before investing in this product.
•
Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate
changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the
duration and average maturity of a portfolio, the greater the likely reaction to interest rate
moves.
•
• Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled
interest or principal payment, if the credit rating of the security is downgraded, or if the
perceived creditworthiness of the issuer deteriorates.
Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading
activity. When there is little or no trading activity in a security, it can be difficult to sell the
security at or near its perceived value. In such a market, bond prices may fall.
• Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity
date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be
reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable
securities may be subject to increased volatility.
• Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be
prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to
be reinvested at a lower yield.
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• Extension risk. When interest rates rise or there is a lack of refinancing opportunities,
prepayments of mortgage-backed securities or callable bonds may be less than expected. This
would lengthen the portfolio’s duration and average maturity and increase its sensitivity to
rising rates and its potential for price declines.
O. Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund
and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of
the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-
level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the
event they sell securities for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund
itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to
a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales
loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the
end of each business day, although the actual NAV fluctuates with intraday changes to the market
value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV
during periods of market volatility, which may, among other factors, lead to the mutual fund’s
shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the
secondary market. Generally, ETF shares trade at or near their most recent NAV, which is
generally calculated at least once daily for index-based ETFs and potentially more frequently for
actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a
premium or discount to their pro rata NAV. There is also no guarantee that an active secondary
market for such shares will develop or continue to exist. Generally, an ETF only redeems shares
when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid
secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way
to dispose of such shares.
P. Use of Independent Managers
As stated above, Callan Family Office selects certain Independent Managers to manage a portion
of its clients’ assets. In these situations, Callan Family Office continues to conduct ongoing due
diligence of such managers, but such recommendations rely to a great extent on the Independent
Managers’ ability to successfully implement their investment strategies or to effectively deliver
their models to Callan Family Office. In addition, Callan Family Office is reliant on Callan LLC and
other providers (including technology services) for continuous coverage of the Independent
Managers used in client accounts.
Q. Use of Private Collective Investment Vehicles
Callan Family Office recommends that certain clients invest in privately placed collective
investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles
have broad discretion in selecting the investments. There are few limitations on the types of
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securities or other financial instruments which may be traded and no requirement to diversify.
Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing
the risk to the vehicle. In addition, because the vehicles are not registered as investment
companies, there is an absence of regulation. There are numerous other risks in investing in these
securities. Clients will have access to each fund’s private placement memorandum and/or other
documents explaining such risks by request.
R. Use of Margin
While the use of margin borrowing for investments can materially improve returns, it may also
increase overall portfolio risk. Margin transactions are generally affected using capital borrowed
from a Financial Institution, which is secured by a client’s holdings. Under certain circumstances,
a lending Financial Institution may demand an increase in the underlying collateral. If the client
is unable to provide the additional collateral, the Financial Institution may liquidate account assets
to satisfy the client’s outstanding obligations, which could have extremely adverse consequences.
In addition, fluctuations in the amount of a client’s borrowings and the corresponding interest
rates may have a significant effect on the profitability and stability of a client’s portfolio.
S. Currency Risks
An advisory account that holds investments denominated in currencies other than the currency
in which the advisory account is denominated may be adversely affected by the volatility of
currency exchange rates.
T.
Interest Rate Risks
Interest rates may fluctuate significantly, causing price volatility with respect to securities or
instruments held by clients.
Item 9. Disciplinary Information
Callan Family Office has not been involved in any legal or disciplinary events that are material to a client’s
evaluation of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Affiliation with Other Investment Adviser
The Firm has a controlling interest in Aris Investing LLC (CRD # 325320) (“Aris”). As discussed above in
Item 4, the Firm will utilize Aris when providing model delivery, direct indexing and overlay services. A
conflict of interest exists to the extent that Callan Family Office recommends or engages Aris for clients.
The Firm mitigates this conflict by only using Aris where it is in the best interest of the client and the
service is reasonably expected to improve the net of fee, net of tax results for the client.
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Item 11. Code of Ethics
Callan Family Office has adopted a code of ethics in compliance with applicable securities laws (“Code of
Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Callan Family Office’s
Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as
the use of material non-public information by the Firm or any of its Supervised Persons and the trading
by the same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of Callan Family Office’s personnel to report their personal
securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public
offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell
securities that it also recommends to clients if done in a fair and equitable manner that is consistent with
the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some
securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed
without any appreciable impact on the markets of such securities. Therefore, under limited
circumstances, exceptions may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
that security unless:
•
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
•
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States;
(ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by money market funds; iv) shares issued by other unaffiliated open-end
mutual funds; and v) exchange traded funds.
Clients and prospective clients may contact Callan Family Office to request a copy of its Code of Ethics by
contacting the Firm at the phone number on the cover page of this brochure.
Item 12. Brokerage Practices
A. Recommendation of Broker-Dealers for Client Transactions
Callan Family Office recommends that clients utilize the custody, brokerage and clearing services of
Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) or investment
management accounts. The final decision to custody assets with Schwab is at the discretion of the
client, including those accounts under ERISA or IRA rules and regulations, in which case the client is
acting as either the plan sponsor or IRA accountholder. Callan Family Office is independently owned
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and operated and not affiliated with Schwab. Schwab provides Callan Family Office with access to its
institutional trading and custody services, which are typically not available to retail investors.
Factors which Callan Family Office considers in recommending Schwab or any other broker-dealer to
clients include their respective financial strength, reputation, execution, pricing, research, and service.
The commissions and/or transaction fees charged by Schwab may be higher or lower than those
charged by other Financial Institutions.
The commissions paid by Callan Family Office’s clients to Schwab comply with the Firm’s duty to
obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial
Institution might charge to execute the same transaction where Callan Family Office determines that
the commissions are reasonable in relation to the value of the brokerage and research services
received. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the full
range of a Financial Institution’s services, including among others, the value of research provided,
execution capability, commission rates and responsiveness. Callan Family Office seeks competitive
rates but may not necessarily obtain the lowest possible commission rates for client transactions.
Consistent with obtaining best execution, the Firm receives investment research products and/or
services which assist Callan Family Office in its investment decision-making process. The receipt of
investment research products and/or services poses a conflict of interest because Callan Family Office
does not have to produce or pay for the products or services. Callan Family Office places trades for
its clients' accounts subject to its duty to seek best execution and its other fiduciary duties. Callan
Family Office may use broker-dealers other than Schwab to execute trades for client accounts
maintained at Schwab, but this practice may result in additional costs to clients so that Advisor is more
likely to place trades through Schwab rather than other broker-dealers. Schwab's execution quality
may be different than other broker-dealers.
Callan Family Office periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions considering its duty to obtain best execution.
B. Software and Support Provided by Financial Institutions
Callan Family Office receives without cost from Schwab administrative support, computer software,
related systems support, as well as other third-party support as further described below (together
"Support") which allow Callan Family Office to better monitor client accounts maintained at Schwab
and otherwise conduct its business. Callan Family Office receives the Support without cost because
the Firm renders investment management services to clients that maintain assets at Schwab. The
Support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”).
The Support benefits Callan Family Office, but not its clients directly. Clients should be aware that
Callan Family Office’s receipt of economic benefits such as the Support from a broker-dealer creates
a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over another
that does not furnish similar software, systems support or services Schwab. In fulfilling its duties to
its clients, Callan Family Office endeavors always to put the interests of its clients first and has
determined that the recommendation of Schwab is in the best interest of clients and satisfies the
Firm's duty to seek best execution.
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Specifically, Callan Family Office receives the following benefits from Schwab: i) receipt of duplicate
client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively
services its institutional traders; iii) access to block trading which provides the ability to aggregate
securities transactions and then allocate the appropriate shares to client accounts; and iv) access to
an electronic communication network for client order entry and account information.
These services generally are available to independent investment advisors on an unsolicited basis, at
no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in
accounts at Schwab. Schwab’s services include brokerage services that are related to the execution
of securities transactions, custody, research, including that in the form of advice, analyses and reports,
and access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
For client accounts maintained in its custody, Schwab generally does not charge separately for custody
services but is compensated by account holders through commissions or other transaction-related or
asset-based fees for securities trades that are executed through Schwab or that settle into Schwab
accounts.
Schwab also makes available to the Firm other products and services that benefit the Firm but may
not benefit its clients’ accounts. These benefits may include national, regional or Firm specific
educational events organized and/or sponsored by Schwab. Other potential benefits may include
occasional business entertainment of personnel of Callan Family Office by Schwab personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms of
entertainment, some of which may accompany educational opportunities.
Schwab provides other products and services that assist Callan Family Office in managing and
administering clients’ accounts. These include software and other technology (and related
technological training) that provide access to client account data (such as trade confirmations and
account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts), provide research, pricing information and other market data, facilitate payment of
the Firm's fees from its clients’ accounts, and assist with back-office training and support functions,
recordkeeping and client reporting. Many of these services generally may be used to service all or
some substantial number of the Firm’s accounts, including accounts not maintained at Schwab.
Schwab also makes available to Callan Family Office other services intended to help the Firm manage
and further develop its business enterprise. These services may include professional compliance, legal
and business consulting, publications and conferences on practice management, information
technology, business succession, regulatory compliance, employee benefits providers, human capital
consultants, insurance, and marketing. In addition, Schwab may make available, arrange and/or pay
vendors for these types of services rendered to the Firm by independent third parties. Schwab may
discount or waive fees it would otherwise charge for some of these services or pay all or a part of the
fees of a third-party providing these services to the Firm.
While, as a fiduciary, Callan Family Office endeavors to act in its clients’ best interests, the Firm's
recommendation that clients maintain their assets in accounts at Schwab may be based in part on the
benefits received and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which creates a potential conflict of interest.
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C. Loan from Schwab
Schwab has provided a loan to Callan Family Office to assist its business operations, and the loan is
guaranteed by the principal(s) of the Firm. The terms of the loan require that management fees to
Callan Family Office be paid to an account at Schwab for deduction of interest and principal payments
on the loan before the Firm may access such management fees. The loan agreement contains various
representations and covenants by Callan Family Office, which can include net assets held at Schwab
(“Assets Under Management at Schwab”), and that Callan Family Office will comply with all applicable
laws, regulations, and agreements, and obtain all necessary licenses, consents and permits. Upon the
occurrence and during the continuance of an event of default under the loan agreement, Schwab may
terminate and/or accelerate the loan, which may have a material adverse effect on the Firm's ability
to perform services for clients.
Some of the products, services and other benefits provided by Schwab, including the loan noted
above, benefit the Firm and may not benefit the Firm’s client accounts. Callan Family Office’s
recommendation or requirement that a client place assets in Schwab's custody may be based in part
on benefits Schwab provides to the Firm, or the Firm’s agreement to maintain certain Assets Under
Management at Schwab, and not solely on the nature, cost or quality of custody and execution
services provided by Schwab.
D. Brokerage for Client Referrals
Callan Family Office does not consider, in selecting or recommending broker-dealers, whether the
Firm receives client referrals from the Financial Institutions or other third party.
E. Directed Brokerage
The client may direct Callan Family Office in writing to use a particular Financial Institution to execute
some or all transactions for the client. In that case, the client will negotiate terms and arrangements
for the account with that Financial Institution and the Firm will not seek better execution services or
prices from other Financial Institutions or be able to “batch” client transactions for execution through
other Financial Institutions with orders for other accounts managed by Callan Family Office (as
described above). As a result, the client may pay higher commissions or other transaction costs,
greater spreads or may receive less favorable net prices, on transactions for the account than would
otherwise be the case. Subject to its duty of best execution, Callan Family Office may decline a client’s
request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements
would result in additional operational difficulties.
F. Trade Aggregation
Transactions for each client will be executed independently unless Callan Family Office decides to
purchase or sell the same securities for several clients at approximately the same time. Callan Family
Office may (but is not obligated to) combine or “batch” such orders to obtain best execution or to
allocate equitably among the Firm’s clients the differences in prices that might not have been
obtained had such orders been placed independently. Under this procedure, transactions will be
averaged as to price and allocated among Callan Family Office’s clients pro rata to the purchase and
sale orders placed for each client on any given day. To the extent that the Firm determines to
aggregate client orders for the purchase or sale of securities, including securities in which Callan
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Family Office’s Supervised Persons may invest, the Firm does so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S.
Securities and Exchange Commission. Callan Family Office does not receive any additional
compensation or remuneration because of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the
particular circumstances, the allocation will be made based upon other relevant factors, which
include: (i) when only a small percentage of the order is executed, shares may be allocated to the
account with the smallest order or the smallest position or to an account that is out of line with respect
to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may
be given to one account when one account has limitations in its investment guidelines which prohibit
it from purchasing other securities which are expected to produce similar investment results and can
be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot
participate in an allocation, shares may be reallocated to other accounts (this may be due to
unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale
allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation
of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may
exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all
accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
A. Account Reviews
Callan Family Office monitors client portfolios on a continuous and ongoing basis and regular account
reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s Principals
and/or portfolio managers. All investment advisory clients are encouraged to discuss their needs,
goals and objectives with Callan Family Office and to keep the Firm informed of any changes thereto.
B. Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. From time-to-time or as
otherwise requested, clients may also receive written or electronic reports from Callan Family Office
and/or an outside service provider, which contain certain account and/or market-related information,
such as an inventory of account holdings or account performance. Clients should compare the
account statements they receive from their custodian with any documents or reports they receive
from Callan Family Office or an outside service provider.
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Item 14. Client Referrals and Other Compensation
Client Referrals
In the event a client is introduced to Callan Family Office by either an unaffiliated or an affiliated party (a
“Promoter”), the Firm may pay that Promoter a referral fee in accordance with applicable securities laws.
Unless otherwise disclosed, any such fee is paid solely from Callan Family Office’s fees and does not result
in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated Promoter,
the client will receive a disclosure statement from that Promoter containing the terms and conditions of
the solicitation arrangement and any conflicts of interest. Any affiliated Promoter of Callan Family Office
is required to disclose the nature of his or her relationship to prospective clients at the time of the referral.
Other Compensation
The Firm receives economic benefits from Schwab. The benefits, conflicts of interest and how they are
addressed are discussed above in response to Item 12.
Item 15. Custody
Callan Family Office is deemed to have custody of client funds and securities because the Firm is given the
ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are
maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such
assets. Such qualified custodians will send account statements to clients at least once per calendar
quarter that typically detail any transactions in such account for the relevant period.
In addition, as discussed in Item 13, Callan Family Office will also send, or otherwise make available,
periodic supplemental reports to clients. Clients should carefully review the statements sent directly by
the Financial Institutions and compare them to those received from Callan Family Office. Any other
custody disclosures can be found in the Firm’s Form ADV Part 1.
A. Standing Letters of Authorization
Callan Family Office also anticipates having custody due to clients giving the Firm limited power of
attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties
as specifically designated by the client. In such circumstances, the Firm will implement the steps in
the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide
instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the
specific third party; iii) the custodian will perform appropriate verification of the instruction and
provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the
ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate
or change the identity or any information about the third party; vi) the Firm will keep records showing
that the third party is not a related party of the Firm or located at the same address as the Firm; and
vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions.
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B. Surprise Independent Examination
In some cases, Callan Family Office provides bill pay service offerings to client accounts via an affiliated
company, and the Firm will take power of attorney to pay bills on behalf of clients. In limited
situations, an employee of the firm is listed as Trustee or Power of Attorney on client accounts. Also,
some custodians may rely solely on Callan Family Office for instructions to disburse, or transfer, funds
or securities. These types of custody requires the Firm to engage an independent accounting Firm to
perform a surprise annual examination of those assets and accounts over which it maintains custody.
Any related opinions issued by an independent accounting Firm are filed with the SEC and are publicly
available on the SEC’s Investment Adviser Public Disclosure website. Callan Family Office does not
have direct access to client funds as they are maintained with an independent qualified custodian.
Item 16. Investment Discretion
Callan Family Office is given the authority to exercise discretion on behalf of clients. Callan Family Office
is considered to exercise investment discretion over a client’s account if it can effect and/or direct
transactions in client accounts without first seeking their consent. Callan Family Office is given this
authority through a power-of-attorney included in the agreement between Callan Family Office and the
client. Clients may request a limitation on this authority (such as certain securities not to be bought or
sold). Callan Family Office takes discretion over the following activities:
The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Acceptance of Proxy Voting Authority Callan Family Office accepts the authority to vote a client’s securities
(i.e., proxies) on their behalf. When the Firm accepts such responsibility, it will cast proxy votes only in a
manner it believes consistent with the best interest of its clients. At any time clients may contact the Firm
to request information about how it voted proxies for that client’s securities.
A brief summary of Callan Family Office’s proxy voting policies and procedures is as follows:
• Callan family Office employs a third-party proxy voting service. The Firm has provided the servicer
with guidance as to how to vote common proxy matters. In the event a specific proxy matter was
to arise and not contemplated in the Firm’s general guidelines, an appointed employee of Callan
Family Office votes the proxy in a manner that is most advantageous for the shareholder.
• Callan Family Office will do initial and ongoing due diligence regarding the proxy voting of the
•
third-party, including reviewing how the third-party handles any conflicts of interest.
Clients cannot typically direct the Firm’s vote on a particular proxy solicitation when the Firm has
been given voting authority. The client, however, can revoke the Firm’s authority to vote proxies.
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In addition, clients can, in limited circumstances, make requests for accommodations regarding
the Firm’s (and the third-party’s) proxy voting.
Item 18. Financial Information
Callan Family Office is not required to disclose any financial information listed in the instructions to Item
18 because:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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