A. Firm Information
Byrne Financial Freedom, LLC (“Byrne Financial” or the “Advisor”) is a registered investment advisor with
the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability
company (“LLC”) under the laws of the Commonwealth of Massachusetts. Byrne Financial was founded in
2006 and became a registered investment advisor in August 2013. Byrne Financial is owned and operated
by Joseph Byrne (Owner and Chief Executive Officer). This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Byrne Financial.
B. Advisory Services Offered
Byrne Financial offers wealth management services to individuals, high net worth individuals, trusts,
estates, charitable organizations, retirement plans, and other businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest. Byrne Financial’s fiduciary commitment is further described in the
Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
Byrne Financial provides Clients with wealth management services, which generally includes a broad range
of comprehensive financial planning services and access to a wealth management software in connection
with discretionary management of investment portfolios. These services are described below.
Investment Management Services - Byrne Financial provides customized investment advisory solutions for
its Clients. This is achieved through continuous personal Client contact and interaction while providing
discretionary investment management and related advisory services. Byrne Financial works closely with
each Client to identify their investment goals and objectives as well as risk tolerance and financial situation
in order to create a portfolio strategy. Byrne Financial will then construct a portfolio, consisting of low-cost,
mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor
may also utilize individual stocks, bonds and/or real estate investment trusts (“REITs”) to meet the needs of
its Clients. The Advisor may retain certain types of investments based on a Client’s legacy investments
based on portfolio fit and/or tax considerations.
Byrne Financial selects, recommends and/or retains mutual funds on a fund by fund basis and seeks to use
non-retail or institutional classes when possible. Due to specific custodial or mutual fund company
constraints, and/or material tax consideration, Byrne Financial may select, recommend and/or retain a
mutual fund share class that has a higher expense ratio than an equivalent share class. Byrne Financial will
seek to select the lowest cost share class available that is in the best interest of each Client and will ensure
the selection aligns with the Client’s financial objectives and state investment guidelines
Byrne Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to
market conditions. Byrne Financial will construct, implement and monitor the portfolio to ensure it meets the
goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective
portfolio, subject to acceptance by the Advisor.
Byrne Financial evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Byrne Financial may recommend specific positions to increase sector or
asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against
market movement. Byrne Financial may recommend selling positions for reasons that include, but are not
limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class
of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the
Client, generating cash to meet the Client’s needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of
the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest,
the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement
account or to roll over the assets to an IRA, or a similar transaction including rollovers from one ERISA
sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g.
commission-based account to fee-based account). Such a recommendation creates a conflict of interest if
the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is
under any obligation to roll over a retirement account to an account managed by the Advisor.
At no time will Byrne Financial accept or maintain custody of a Client’s funds or securities, except for the
limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the wealth management agreement, please see Item 12 –
Brokerage Practices.
Use of Independent Managers – When deemed to be in the Client’s best interest, Byrne Financial will
recommend to Clients that all or a portion of their investment portfolio be implemented by utilizing one or
more unaffiliated money managers or investment platforms (collectively “Independent Managers”).
Independent Managers may be sourced directly or accessed through an investment management platform.
The Client may be required to enter into a separate agreement with the Independent Manager[s] and/or
provide authorization through its custodial application to utilize the Independent Manager[s].
Byrne Financial serves as the Client’s primary advisor and relationship manager. However, the Independent
Manager[s] will assume discretionary authority for the day-to-day investment management of those assets
placed in their control. Byrne Financial will assist and advise the Client in establishing investment objectives
for their account[s], the selection of the Independent Manager[s], and defining any restrictions on the
account[s]. Byrne Financial will continue to provide oversight of the Client’s account[s] and ongoing
monitoring of the activities of these unaffiliated parties.
The Independent Manager[s] will implement the selected investment strategies based on their investment
mandates. The Client may be able to impose reasonable investment restrictions on these accounts, subject
to the acceptance of these third parties.
The Client, prior to entering into an agreement with an Independent Manager, will be provided with the
Form ADV Part 2A (or a brochure that makes the appropriate disclosures) of those parties. Byrne Financial
does not receive any compensation from these Independent Managers or Investment Platforms, other than
Byrne Financial’s wealth management fee, as described in Item 5.
Financial Planning Services - Byrne Financial will typically provide a variety of financial planning and
consulting services to Clients as part of its wealth management services. Services are offered in several
areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, estate/legacy planning, insurance needs, access to
WealthVisionSM and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or
alter retirement savings, establish education savings and/or charitable giving programs.
Byrne Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for
their unique situation. For certain financial planning engagements, the Advisor will provide a written
summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically
completed within six months of contract date, assuming all information and documents requested are
provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor
and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients
engage the Advisor for investment management services or to increase the level of investment assets with
the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated
to implement any recommendations made by the Advisor or maintain an ongoing relationship with the
Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under
no obligation to implement the transaction through the Advisor.
Wealth Management Software - Clients may also have access to WealthVisionSM, a wealth management
software that provides the Client with various financial management services, such as tracking of financial
data, maintaining financial documents, and the aggregation of accounts and reporting across multiple financial
institutions.
Retirement Plan Advisory Services
Plan Sponsors may engage Byrne Financial to serve as a 3(38) Fiduciary to their plan and assume
investment discretion over the Plan. In such instances, the Plan Sponsor shall authorize this discretion to
select and implement the Plan investment options. Services generally include:
• Ongoing Investment Recommendation and Assistance
C. Client Account Management
Prior to engaging Byrne Financial to provide wealth management services, each Client is required to enter
into a wealth management agreement with the Advisor that defines the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Byrne Financial, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Byrne Financial will develop a strategic asset allocation that is targeted to meet
the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
• Portfolio Construction – Byrne Financial will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – Byrne Financial will provide investment management
and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Byrne Financial includes securities transaction fees together with its wealth management fees. Including
these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its
wealth management services for its Clients. The Advisor sponsors the Byrne Financial Wrap Fee Program
solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading
required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if
the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is
included as a supplement to this Disclosure Brochure.
E. Assets Under Management
As of December 31, 2023, Byrne Financial manages $357,402,351 in Client assets, $357,275,701 of which
are managed on a discretionary basis and $126,650 on a non-discretionary basis. Clients may request
more current information at any time by contacting the Advisor.