Description of Firm FreeGulliver, L.L.C. d/b/a FreeGulliver is a registered investment adviser based in New Orleans, Louisiana. We are organized as a limited liability company ("LLC") under the laws of the State of Louisiana. We have been providing investment advisory services since 2001. We are primarily owned by Frank Friedler, III and Michael Kirschman.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our," and "us" refer to FreeGulliver and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm.
While this brochure generally describes the business of FreeGulliver, 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 any other person who provides investment advice on FreeGulliver's behalf and is subject to the Firm's supervision or control.
Portfolio Management Services We offer discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant us discretionary authority to manage your account. Subject to a grant of discretionary authorization, we have the authority and responsibility to formulate investment strategies on your behalf. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without obtaining your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
We may also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
As part of our portfolio management services, in addition to other types of investments, we may invest your assets according to one or more model portfolios developed by our firm. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Generally, clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. If a client wishes to set restrictions, it may prevent the client from investing in certain models that are managed by our firm. 4 Financial Planning and Financial Consulting Services We offer financial planning services which typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial planning to consultative or single subject planning. Our financial planning services may involve consultation, analysis, and recommendations in one or more of the areas on which we focus:
•Financial Situations
•Insurance
•Investments
•Retirement Planning
•Estate Planning If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. We may also use financial planning software to determine your current financial position and to define and quantify your goals and objectives. Depending on the scope of work, once we review and analyze the information, we may provide a specific recommendation or deliver a written plan designed to help you achieve your stated financial goals and objectives.
The services provided in this regard may include, but would not be limited to, the following:
•Prepare a net worth statement;
•Create a cash flow statement
•Review current investments and make recommendations thereon;
•Review client's life insurance and disability insurance and make recommendations thereon;
•Review client's estate plan and make recommendations thereon;
•Complete a retirement analysis; and
•Provide education planning advice. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to us. You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
We also offer financial consulting services that primarily involve advising clients on specific financial- related topics. The topics we address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation.
Selection of Other Advisers We may recommend that you use the services of a third-party money manager ("TPMM") to manage all, or a portion of, your investment portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs,

investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remain aligned with your investment goals and objectives. The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. 5 Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written statement, the 408(b)(2) Disclosure, and be consistent with the parameters set forth in the plan documents.
Either party may terminate the agreement upon written notice to the other party. The pension consulting fees will be prorated for the quarter in which the termination notice is given, and any unearned fees will be refunded to the client.
Family Office and Wealth Planning Services We offer Family Office and Wealth Planning Services designed to help our clients organize their financial situation and plan for the successful transfer of wealth to the next generation in the most tax- advantaged manner. Such services generally include financial planning in the following areas:
•Family Continuity
•Estate Planning and Trustee Oversight
•Lifestyle Management
•Family Philanthropy
•Risk Management Private Pooled Investment Vehicle Offerings and Fund Management Services FreeGulliver provides investment advisory services to private pooled investment funds (the "Funds" or each a "Fund"). FreeGulliver also provides management or administrative services to the Funds.
FreeGulliver serves as the Manager/General Partner and the Adviser to Elcano Hedged Equity Fund, LLC, Elcano Market Neutral Fund, LLC, Elcano Value Focus Fund, LLC, GulliverOne Limited Partnership, Gulliver Technology Opportunities Fund, LLC, Octavia Capital Opportunities Fund LP, and Santa Rosa Investment Fund, LLC. Specifically, we will manage the assets of these Funds on a discretionary basis in accordance with the overall investment objectives of each such Fund. Different strategies may be carried out for each Fund and therefore, there should be no expectation that the performance of any individual Fund would or should be similar to that of any other Fund. You should 6 refer to the subscription agreement and other offering documents for a complete description of the fees, investment objectives, risks, and other relevant information associated with investing in the Funds.
We may handle the administrative functions of the aforementioned Funds and other Funds. Among other things, included in those administrative functions are the processing of investor subscriptions to the Funds; overall investor relations; bookkeeping; preparation of investor statements, coordination of annual financial audits, when applicable, for the Funds; and investor reporting. Unless agreed to separately, our Fund management services do not involve the provision of specific investment advisory services to individuals (in general) or individual investors in the Funds.
Investments in the Funds are not registered under the Securities Act of 1933, as amended, and are only offered after delivery of a private placement memorandum and execution of the subscription agreement and other offering documents. Investments in the Funds are offered only to accredited investors within the meaning of SEC Rule 501 of Regulation D of the Securities Act of 1933. Some Funds are offered only to qualified purchasers as defined within the meaning of Section 2(a)(51) of the Investment Company Act of 1940. Investments in the Funds are offered by private offering memorandum which provides investors with full disclosure regarding the objectives of the Funds, the risks involved with the offering and the minimum initial capital contribution or commitment required. Types of Investments We primarily offer advice on mutual funds, exchange traded funds, Private Pooled Investment Vehicles ("PIV") and third-party money managers ("TPMM"). Refer to the Methods of Analysis, Investment Strategies and Risk of Loss section below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
Assets Under Management As of December 31, 2023, we provide continuous management services for $264,896,822 in client assets on a discretionary basis, and $283,377,548 in client assets on a non-discretionary basis. Additionally, we provide advice on a non-continuous basis for $788,954,312 in client assets.
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