INDEPENDENT VERDICT
Freedom Fund 25, LLC is most interesting because its September amendment materially changed how the offering is described without changing how much money had actually been raised. The original April 20, 2026 Form D reported a $100 million Rule 506(c) offering, $550,000 sold to four investors, a January 29 first sale and a $100,000 minimum. The September amendment still reports exactly $550,000 sold to the same four investors and $99.45 million remaining, meaning no additional cumulative Form D sales are visible between the two filings. Yet several core fields changed: the security type moved from "Other" to "Debt," Section 3(c)(1) was added as the Investment Company Act exclusion, the expected offering duration changed from no more than one year to more than one year, and the earlier estimated $10,000 sales commission disappeared while a separate estimated $10,000 related-person payment remained. Those are not cosmetic edits. They suggest the legal or economic framing of the offering was revised after capital had already been accepted.
THE MOST IMPORTANT DILIGENCE QUESTION IS WHAT CHANGED BETWEEN APRIL AND SEPTEMBER
Freedom Fund 25 did not merely correct an address or spelling error. The April filing did not claim Section 3(c)(1), described the offered security under the catch-all "Other" category and said the offering would not last more than a year. By September, the issuer was expressly relying on Section 3(c)(1), describing the security as debt and expecting the offering to continue for more than one year. Investors therefore need to establish whether the underlying subscription instrument was amended, whether existing investors exchanged or converted earlier interests into notes or other debt securities, whether the private-fund structure was reorganized, and whether maturity, interest-rate or repayment terms changed. Form D records the categories selected by the issuer but does not publish the promissory note, private placement memorandum or amendment documents necessary to explain the transition. The fact that the sold amount remained fixed at $550,000 makes the structural change itself more significant than fundraising growth.
THE SALES-COMPENSATION SECTION IS ALSO UNUSUAL
Both filings identify Jess Phillips and Gary Schmeichel as persons receiving or potentially receiving sales compensation and authorize solicitation in all states, but neither individual is shown with a CRD number or an associated broker-dealer in the Form D. In April, the filing estimated $10,000 of sales commissions; the September amendment changed reported sales commissions to $0. Both filings also estimate $10,000 of offering proceeds to be used for payments to a related person. Jess Phillips is separately named as the issuer's Executive Officer and signs both filings as Manager. Gary Schmeichel is not listed as an executive officer of Freedom Fund 25, but independent public business records identify a Gary Schmeichel as CEO of Enium Capital Group, a consumer and solar-finance company. FilingDossier did not locate primary evidence establishing that the Enium executive is acting in that capacity for Freedom Fund 25 or that Enium owns, manages or finances this fund. The shared name is a diligence lead, not a confirmed corporate relationship.
THE $100 MILLION TARGET IS FAR AHEAD OF THE FUND'S CURRENT CAPITAL BASE
Freedom Fund 25 had sold only $550,000 against its $100 million stated offering as of the September amendment — approximately 0.55% of the target. With four investors, the simple average subscription is about $137,500, although actual investor amounts may differ. The issuer also reports no aggregate net asset value in the filing. Those facts make it inappropriate to describe Freedom Fund 25 as a $100 million fund in the sense of capital already under management. $100 million is the maximum offering amount; $550,000 is the cumulative amount reported sold. The amended debt classification also means the economics cannot be analyzed like ordinary LP equity. Investors need to know the interest rate, maturity, collateral, seniority, borrower or asset pool, covenant package and what cash-flow source is expected to repay the debt. None of those terms appears in Form D.
THE ADDRESS PRODUCES ANOTHER LEAD, BUT NOT A VERIFIED AFFILIATION
Freedom Fund 25 uses 240 N. E. Promontory Ave in Farmington, Utah. Public investment-adviser materials for Promontory Financial Planning historically identify 240 N E Promontory, Suite 200, Farmington as that advisory firm's office. The building-level overlap is noteworthy, but the Freedom Fund filing does not identify Promontory Financial Planning as adviser, placement agent, manager or affiliate, and its telephone number differs from the advisory firm numbers visible in public records. FilingDossier therefore does not attribute Promontory Financial Planning's CRD, advisory history or personnel to Freedom Fund 25. This is exactly the kind of address clue that deserves further investigation without being converted into an unsupported ownership claim.
FINAL ASSESSMENT
Freedom Fund 25 is defined by five facts that make it substantially different from a generic private fund: the $100 million offering has reported only $550,000 sold; the investor count has stayed at four between April and September; the security classification changed from "Other" to "Debt"; the fund added Section 3(c)(1) and extended the planned offering period beyond one year; and its sales-commission disclosure changed from an estimated $10,000 to $0 while Jess Phillips and Gary Schmeichel remained named in the solicitation section. The public record therefore verifies an active exempt offering but leaves the underlying credit strategy almost entirely undisclosed. The most valuable next documents are the amended PPM, debt instrument, collateral schedule, manager ownership records and explanation of why the September filing materially changed the offering structure without increasing reported capital.
SEC SNAPSHOT
Issuer: Freedom Fund 25, LLC CIK: 0002129972 SEC Form: Form D/A Accession No.: 0002129972-26-000002 Latest Filing Date: September 14, 2026 Original Filing Date: April 20, 2026 Year Organized: 2025 Jurisdiction: Wyoming Principal Place of Business: Farmington, Utah Business Address: 240 N. E. Promontory Ave, Farmington, UT 84025 Telephone: 801-503-7990 Industry: Pooled Investment Fund Fund Classification: Other Investment Fund Investment Company Registered: No Investment Company Act Exclusion: Section 3(c)(1) Offering Exemption: Rule 506(c) Security Type - April Filing: Other Security Type - September Amendment: Debt Offering Amount: $100,000,000 Amount Sold: $550,000 Remaining: $99,450,000 Percentage of Target Sold: Approximately 0.55% Investors: 4 Minimum Investment: $100,000 First Sale: January 29, 2026 Offering Duration - April Filing: Not more than one year Offering Duration - September Amendment: More than one year Related Person: Jess Phillips Role: Executive Officer / Manager Sales Compensation Recipient: Jess Phillips Jess Phillips CRD: None reported Associated Broker Dealer: None reported Sales Compensation Recipient: Gary Schmeichel Gary Schmeichel CRD: None reported Associated Broker Dealer: None reported
FILING CHANGE ANALYSIS
April 20, 2026 Amount Sold: $550,000 September 14, 2026 Amount Sold: $550,000 Incremental Form D Sales: $0
April Security Type: Other September Security Type: Debt
April Section 3(c)(1) Claimed: NO September Section 3(c)(1) Claimed: YES
April Offering Duration Over One Year: NO September Offering Duration Over One Year: YES
April Estimated Sales Commissions: $10,000 September Sales Commissions: $0
April Estimated Related-Person Use of Proceeds: $10,000 September Estimated Related-Person Use of Proceeds: $10,000
Investor Count April: 4 Investor Count September: 4
Interpretation: The amendment materially changed legal and offering classifications while cumulative fundraising remained unchanged.
WEBSITE / ENTITY PENETRATION
Freedom Fund 25 SEC issuer confirmed: YES CIK 0002129972 confirmed: YES Jess Phillips executive relationship confirmed: YES Jess Phillips signer / Manager role confirmed: YES Gary Schmeichel sales-compensation listing confirmed: YES Jess Phillips CRD number in Form D: NONE Gary Schmeichel CRD number in Form D: NONE Associated broker-dealer listed for either recipient: NO Dedicated Freedom Fund 25 website confirmed: NO Investment adviser independently confirmed: NO Adviser CRD / SEC 801 confirmed: NO Underlying credit strategy publicly confirmed: NO Borrower or asset pool publicly confirmed: NO Collateral publicly confirmed: NO Interest rate publicly confirmed: NO Maturity publicly confirmed: NO Fund-level auditor confirmed: NO Administrator confirmed: NO Custodian confirmed: NO Fund counsel confirmed: NO
PUBLIC IDENTITY LEADS
Freedom Fund Address: 240 N. E. Promontory Ave, Farmington, UT 84025 Promontory Financial Planning historically uses same building address: YES Promontory Financial Planning confirmed as Freedom Fund adviser: NO Gary Schmeichel publicly identified as Enium Capital Group CEO: YES Enium Capital Group described publicly as consumer / solar finance company: YES Gary Schmeichel appearing in Enium records proven to be acting for Freedom Fund in that corporate capacity: NO Enium ownership or management of Freedom Fund 25 confirmed: NO
CORE INVESTOR QUESTIONS
Why did Freedom Fund 25 change its offered security from "Other" to Debt Were the four original investors' securities amended or exchanged What interest rate is paid on the debt What is the maturity date Is the debt secured or unsecured What collateral supports repayment Who is the borrower or economic obligor What assets or receivables are being financed Why was Section 3(c)(1) added only in the amendment Why was the offering duration extended beyond one year Why did estimated sales commissions change from $10,000 to $0 Were any commissions actually paid before the amendment What is the nature of the continuing estimated $10,000 related-person payment What services do Jess Phillips and Gary Schmeichel perform What relationship, if any, exists between Gary Schmeichel's other finance businesses and Freedom Fund 25 Is there any relationship between Freedom Fund 25 and Promontory Financial Planning How will the fund deploy capital if subscriptions eventually approach the $100 million target What happens if the offering remains materially below target Who provides independent accounting, administration and custody
PRIMARY EVIDENCE REVIEWED
Freedom Fund 25 LLC original Form D filed April 20, 2026. Freedom Fund 25 LLC Form D/A filed September 14, 2026. SEC-derived filing records confirming CIK 0002129972, Rule 506(c), $100 million target, $550,000 sold and four investors. Original filing showing "Other" security classification, no Section 3(c)(1) claim, offering duration below one year and estimated $10,000 sales commissions. September amendment showing Debt classification, Section 3(c)(1), offering duration above one year and $0 sales commissions. Public business records identifying Gary Schmeichel as CEO of Enium Capital Group. Historical public adviser records for the 240 N E Promontory Farmington address used only as an address-comparison lead.
IMPORTANT FORM D NOTICE
Freedom Fund 25's $100 million figure is the stated maximum offering amount, not capital already raised or current AUM. The September 2026 filing reports only $550,000 sold to four investors. The amendment materially changed the security classification and private-fund exclusion while leaving fundraising unchanged; Form D does not explain why. FilingDossier does not infer an affiliation with Enium Capital Group, Promontory Financial Planning or any other business solely from a person's name or shared building address. Rule 506(c), CIK and Section 3(c)(1) filings are regulatory classifications and exempt-offering notices, not SEC approval or endorsement.