Firm Description
EMFO, LLC (“EMFO”) was established in May 2017 and is registered with the SEC (US Securities and
Exchange Commission) as a Registered Investment Adviser.
EMFO provides Multi‐Family Office Services, offering a full range of capabilities to serve the needs of high net
worth and ultra‐high net worth families and institutions by offering family office services, including non‐
discretionary investment advice.
EMFO, LLC is co‐owned as follows:
Majority Owner:
Running Rebel Consulting which is wholly owned by the Scot L. Hunter Revocable Trust, for which Scot L.
Hunter serves as the Trustee.
Minority Owners:
DDIAWA Consulting, LLC which is wholly owned by Allan M. Budelman.
CWRS, LLC which is wholly owned by Melissa J. Budelman.
Stoli Advisory LLC which is wholly owned by Keith Stoloff.
Smith Global Holdings LLC which is wholly owned by Colm Smith.
Please refer to the Form ADV Part 1 Schedule A & Schedule B for ownership details
Assets Under Management
As of December 31, 2023, EMFO, currently has regulatory assets under management of $501,692,642 on a
discretionary basis.
Assets Under Advisement
EMFO shall also provide advice, monitoring, and reporting services. As of December 31, 2023, EMFO has Asset
Under Advisement of $3,707,377,796.
SERVICES PROVIDED
At the outset of each client relationship, EMFO spends time with the client, asking questions, discussing the
client’s investment experience and financial circumstances, and broadly identifying major goals of the client.
Portfolio Management Services
EMFO provides advice as to the allocation of client portfolios and the investment of client assets. Investment
advice is tailored to the individual needs of each client. EMFO evaluates the client’s personal and financial
circumstances at the onset of the relationship, and periodically thereafter. Clients are advised that they should
promptly notify us when there are any changes to their financial situation and/or financial objectives for the
purpose of reviewing, evaluating, or revising previous recommendations or services. We also meet with our
clients periodically and ask about any changes to their financial situation and/or financial objectives.
EMFO will manage the client’s investment portfolio on a discretionary or a non‐discretionary basis. As a
discretionary investment adviser, EMFO will have the authority to supervise and direct the portfolio without prior
consultation with the client. Clients who choose a non‐discretionary arrangement must be contacted prior to the
execution of any trade in the account(s) under management. This can result in a delay in executing recommended
trades, which could adversely affect the performance of the portfolio. This delay also normally means the
affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution
quality, timing and/or cost for all accounts included in the block. In a non‐discretionary arrangement, the client
retains the responsibility for the final decision on all actions taken with respect to the portfolio.
Clients can impose certain written restrictions on EMFO in the management of their investment portfolios, such
as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of
certain investments held in the account at the commencement of the relationship. Each client should note,
however, that restrictions imposed by a client could adversely affect the composition and performance of the
client’s investment portfolio. Each client should also note that his or her investment portfolio is treated
individually by giving consideration to each purchase or sale for the client’s account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance
could differ, and clients should not expect that the composition or performance of their investment portfolios
would necessarily be consistent with similar clients of EMFO. Please refer to the Investment Allocation and Trade
Aggregation sections in Item 12 for further information.
Selection of Separate Account Managers
When appropriate and in accordance with the Investment Plan for a client, EMFO shall recommend the use of
one or more Separate Account Managers, each a “Manager.” Having access to various Managers offers a wide
variety of manager styles and offers clients the opportunity to utilize more than one Manager, if necessary, to
meet the needs and investment objectives of the client. EMFO will usually select or recommend the Manager(s)
it deems most appropriate for the client. Factors that EMFO considers in recommending/selecting Managers
generally include the client’s stated investment objective(s), management style, performance, risk level,
reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment supervisory
services for the portfolio. Under certain circumstances, EMFO retains the authority to terminate the Manager’s
relationship or to add new Managers without specific client consent. In other cases, the client will ultimately
select one or more Managers recommended by EMFO. Fees paid to such Manager(s) are separate from and in
addition to the fee assessed by EMFO.
In any case, with respect to assets managed by a Manager, EMFO’s role will be to monitor the overall financial
situation of the client, to monitor the investment approach and performance of the Manager(s), and to assist
the client in understanding the investments of the portfolio.
When appropriate and in the client’s best interest EMFO will recommend the Investment Management services
of other unaffiliated advisors. In the event clients utilize the services of another unaffiliated advisor, the client
will enter into an agreement directly with that advisor which will clearly outline the fee agreement.
Real Estate‐Related and Other Private Offerings
When appropriate, and in accordance with the client’s Investment Plan, EMFO will recommend the use of one or
more alternative and real estate limited partnership operators.
For clients for whom such services are suitable, EMFO will provide advice on real estate‐related investments
(e.g., mortgages, direct investments in real estate and investments in real estate funds). Services included
within the scope of such advice include strategic research, due diligence, investment monitoring and reporting.
Held‐Away Assets
EMFO provides additional services for accounts where it is not possible for the firm to enact trades through
the usual custodians.
EMFO makes recommendations for certain accredited investors for real estate private equity deals. An
accredited investor, in the context of a natural person, includes anyone who:
earned income that exceeded $200,000 (or $300,000 together with a spouse) in each of the prior two
years, and reasonably expects the same for the current year, OR
has a net worth over $1 million, either alone or together with a spouse (excluding the value of the
person’s primary residence).
is a natural person with certain professional certifications in good standing such as the Series 7, Series
65, and Series 82 licenses*
*For information on Series Licenses please go to https://www.finra.org/registration‐exams‐
ce/qualification‐exams
Is a knowledgeable employee of a Private Fund.
EMFO makes recommendations from time to time to accredited investor clients involving Real Estate Private
Equity deals from operators that are also Family Office Clients of EMFO. The recommendation poses a conflict
of interest as it is in EMFO's best interest to assist these operators in funding their deals. EMFO shall disclose
this to the clients that are receiving the recommendation, and those clients are free to turn down the deal or
seek a deal outside the management of EMFO. As stated in Item 11 Code of Ethics, EMFO’s associated persons
are allowed to invest in the same securities recommended to clients. EMFO is not paid a commission or fee for
helping the operator fund the deal. EMFO is only paid a Family Office Fee by the Real Estate Operators for
performing Family Office Services as described in our form ADV. It is in EMFO’s best interest that the
accredited investor client is invested in products we believe to be best suited for the client. In addition to full
disclosure, EMFO has a fiduciary duty to exercise good faith and act solely in the best interest of clients and
maintains policies and procedures, including a Code of Ethics which requires the interests of clients be placed
ahead of other interests to address this conflict of interest.
Therefore, EMFO utilizes specific investment criteria when making these real estate private equity
recommendations. The criteria followed includes:
Due Diligence of the Real Estate Operators
Product Review of the Deals by the Investment Committee of EMFO
Client Risk and Suitability Analysis
Family Office Services
EMFO provides Multi‐Family Office Services, offering a full range of capabilities to serve the needs of a select
group of high net worth and ultra‐high net worth individuals, families, and their related entities. As a strategic
partner, EMFO will develop and implement a comprehensive wealth management plan. Our goals‐based
planning process helps align clients’ objectives with appropriate wealth management strategies and leverages
EMFO’s extensive resources to develop integrated solutions tailored to meet clients’ needs. Clients generally
work with a dedicated partner of the firm with in‐depth experience supported by a team of professionals
brought together to help achieve the client’s goals. Clients engaging EMFO for Family Office Services receive:
Wealth Management Plan
Development of a comprehensive wealth management profile and plan. The profile and plan are discussed
regularly with each client but are not necessarily written documents.
Wealth Management Services
Strategic Planning and Coordination of Investment, Banking, Insurance, Legal and other Advisors Portfolio
Management Services (as described above)
Trust & Fiduciary: Coordinate with client and legal advisors to develop a personalized wealth transfer plan.
Philanthropy: Coordination and assistance in development of philanthropic structures and processes
*Special Projects
*Special projects include, without limitation, business consulting, organization projects, as well as other matters
specific to the client as and when requested by the client and agreed to by EMFO.
Business Introductory Services
EMFO provides extensive industry connections for expediting the introduction and connection process between
client and potential business partners and trusted service providers.
Serves as an intermediary to facilitate and manage confidential connections between clients for specific business
purposes.
Business Introductory Services are provided as part of the relationship with our clients. EMFO does not charge a
fee, receive a commission or any other monetary compensation for these introductory services.
Reporting and Administration
Consolidated Financial Reporting
Consolidated Net Worth Report
Consolidated Asset Summary Report
Consolidated Real Estate Inventory
Consolidated Cash Flow Summary
Holistic View of Client’s Assets (Reported assets include those over which the client does not grant EMFO
investment discretion. Such assets are be included for informational purposes only.)
Document Management and Archiving: Maintain copies of all family document inventory including entity
organization documents, tax documents, a summary of major assets by ownership, key contacts, investment
documents and financial reports, and correspondence.
Family Governance: Family meeting facilitation and maintenance of a family communication process and
governance system.
Education: Provide access to group and individual education programs for family members encompassing a
wide variety of topics, including next‐generation education.
As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s request, the
client’s Consolidated Report may also include certain non‐financial assets (e.g., real assets). In such
instances, we rely on the client to provide current and accurate price or other valuation information for
those assets to be included in the client’s consolidated account report. We do not independently verify, and
expressly disclaims responsibility for, the accuracy of any non‐financial asset values (including any portfolio
performance including those values) clients provide to us to include in their reporting.
To further assist our clients, we also offer bill paying, bookkeeping, and trustee services. These services
create a custody situation which we address in Item 15‐ Custody of this document.
Bill Paying and Bookkeeping Services
Bill paying and bookkeeping services are customized to fit our client's unique situations and specific needs.
These service accommodations to certain existing clients where EMFO receives bills and invoices payable by
clients and EMFO pay such bills using EMFO's access to the clients' bank accounts (known as "Bill Pay
Services"). The access may be through online banking tools or by the client's signature authority to EMFO
over the client's bank accounts.
Trustee Services
Trusteeship Services ‐EMFO engages in arrangements under which Allan Budelman serves as trustee or co‐
trustee. Allan Budelman, Scot Hunter, and Melissa Budelman have also been appointed as successor
trustees for certain EMFO client‐related entities. When enacted, the trustee, co‐trustee and successor
trustee roles would take legal responsibility for carrying out the terms of the instrument for estates and
various trusts. Allan acting as the trustee or co‐trustee for the Trust utilizes the advisory and family office
services of EMFO. Trustee fees are separately collected and are paid to EMFO through an agreement
between Allan Budelman and EMFO. Trustee fees are listed in the separate Trustee Agreement. The Trust,
also managed by EMFO, would pay a separate advisory and family office fee for EMFO’s services which will
be outlined in the Family Office Agreement. Please see Item 5 Fees and Compensation for more
information.
Non‐Discretionary Investment Advisor: EMFO sources and recommends alternative investment
opportunities to our select group of high net worth clients. Our client's receive information, advice, and
recommendations for private equity, venture capital and direct real estate opportunities. EMFO does not
receive compensation from any investment we recommend. EMFO also provides due diligence on non‐
EMFO sourced investments for our clients.