Model Reference

Complete documentation of the FRDM Collective financial model, share classes, waterfall mechanics, and the 50/50 operator structure.

Entity Structure

Legal Entity

  • Type: Delaware LLC
  • Tax Treatment: Partnership (pass-through)
  • Roll-in Structure: Section 721 exchange (tax-deferred)
  • 83(b) Election: Available for operator units
  • Exit Treatment: Capital gains

Governance

  • Board: 3 seats (2 Management, 1 Seed Observer)
  • Major Decisions: Board + Seed consent
  • Day-to-Day: Management discretion
  • Operator Control: Operational autonomy maintained

Share Classes

ClassHolderEconomicsWaterfall Position
Class A-1Seed Investors1.50x preference + 5.0% participation1st (First Out)
Class A-2Series A Investors1.50x preference + 3.0% participation2nd (If Raised)
Class BOperators50% Rollover Equity + 50% Operator Promote4th
Class CManagement25.0% of profit pool (anti-diluted)3rd

50/50 Operator Structure

The operator pool (75% of proceeds after Seed and Management) is split 50/50 between two components, providing operators with both a guaranteed floor and performance upside.

50% Rollover Equity (Floor)

  • Basis: Pro-rata by entry valuation
  • Entry Valuation: 5x Entry EBITDA
  • Protection: Guaranteed floor regardless of performance
  • Tax Treatment: 83(b) election available at roll-in

Pool Size: $74.3M

50% Operator Promote (Performance)

  • Basis: Ending EBITDA tier multiple
  • Allocation: Pre-determined tier table
  • Upside: Bigger EBITDA = bigger promote
  • Bonus Pool: Remainder distributed by growth rate

Pool Size: $74.3M

Waterfall Mechanics

1

Seed Preference (Class A-1)

1.50x × $5.0M = $7.5M

First money out. Paid before anyone else.

2

Series A Preference (Class A-2)

1.50x × Investment (if raised)

Second position. Only applies if Series A is raised.

3

Seed Participation

5.0% × Remaining = $10.4M

5.0% off the top of remaining proceeds after preferences.

4

Series A Participation

3.0% × Remaining (if raised)

3% participation if Series A is raised.

5

Management Carry (Class C)

25.0% × Remaining = $49.5M

25% of profit pool. Anti-diluted — never changes.

6

Operator Pool (Class B) - 50/50 Split

75.0% × Remaining = $148.6M

50% Rollover Equity

$74.3M

50% Operator Promote

$74.3M

Operator Entry Mechanics

Entry Valuation Formula

Entry Valuation = Entry EBITDA × 5x

Operators roll in at 5x their entry EBITDA. This determines their rollover equity share.

83(b) Election

Available for both rollover equity and operator promote units

Operators can elect 83(b) treatment at roll-in to lock in capital gains treatment on future appreciation.

Market Multiple Table (Reference)

EBITDA RangeMarket Multiple
$0 - $150K1.8x
$150K - $300K2.5x
$300K - $500K3.5x
$500K - $750K4.5x
$750K - $1M5.5x
$1M - $2M6.5x
$2M - $4M7.5x
$4M - $5M8.5x

Operator Promote Tiers (Exit)

At exit, operators receive a promote multiple based on their ending EBITDA tier. This is applied to the 50% operator promote pool.

Ending EBITDA TierPromote MultipleTarget Net Multiple*
$0K - $400K0.53x - 0.77x4.03x - 4.27x
$400K - $500K1.18x - 1.42x4.68x - 4.92x
$500K - $600K1.58x - 1.82x5.08x - 5.32x
$600K - $700K1.93x - 2.17x5.43x - 5.67x
$700K - $800K2.33x - 2.57x5.83x - 6.07x
$800K - $900K2.73x - 2.97x6.23x - 6.47x
$900K - $1.00M3.08x - 3.32x6.58x - 6.82x
$1.00M - $1.25M3.48x - 3.72x6.98x - 7.22x
$1.25M - $1.50M3.93x - 4.17x7.43x - 7.67x
$1.50M - $1.75M4.33x - 4.57x7.83x - 8.07x
$1.75M - $2.00M4.78x - 5.02x8.28x - 8.52x
$2.00M - $2.50M5.18x - 5.42x8.68x - 8.92x
$2.50M - $3.00M5.28x - 5.52x8.78x - 9.02x
$3.00M - $4.00M5.38x - 5.62x8.88x - 9.12x
$4.0M+6.18x - 6.42x9.68x - 9.92x

*Target Net Multiple = Rollover contribution (~3.5x) + Promote Multiple. Actual net multiples may vary based on portfolio performance.

Performance Bonus Pool

How It's Created

After all promote tier payouts are made from the 50% operator promote pool, any remaining capital becomes the Performance Bonus Pool. This rewards operators who grew faster than their tier minimum.

How It's Distributed

Distributed by growth rate (Exit EBITDA ÷ Entry EBITDA). Operators who grew the most get the largest share of the bonus pool.

Current Model Parameters

Seed Investment

$5.0M

Seed Preference

1.50x

Seed Participation

5.0%

Management Carry

25.0%

Entry Multiple

5x

Rollover Equity %

50.0%

Operator Promote %

50.0%

Hold Period

4 years

Target Exit EBITDA

$18.0M

Corporate Overhead (Y1)

$2.0M

Overhead Growth Rate

8.0%

Calculated Outputs

Enterprise Value

$216.0M

Seed Total Return

$17.9M

Seed MOIC

3.58x

Management Carry

$49.5M

Operator Pool

$148.6M

Profit Pool

$208.5M

Rollover Equity Pool

$74.3M

Operator Promote Pool

$74.3M

83(b) Election & Tax Treatment

What is an 83(b) Election?

An 83(b) election is an IRS provision that allows you to pay taxes on equity at the time of grant (when value is low) rather than at vesting (when value may be much higher).

For FRDM operators, this means you can elect to be taxed on your entry valuation rather than your exit valuation.

Example: If you roll in at $400K EBITDA (5x = $2M entry value) and exit at $1.5M EBITDA (8x = $12M exit value), you're taxed on the $2M, not the $12M.

How Your Roll-In Works

1

Section 721 Exchange

Your business rolls into FRDM tax-deferred. No immediate tax event.

2

Profits Interest Units (PIUs)

You receive PIUs representing your share of future profits. These have $0 value at grant.

3

83(b) Election Filed

Within 30 days, you file 83(b) to lock in the low basis. Future appreciation is capital gains.

4

Exit = Long-Term Capital Gains

At exit (4+ years), your payout is taxed at LTCG rates (~20%), not ordinary income (~37%).

Tax Comparison: 83(b) vs No Election

ScenarioTax RateOn $10M GainYou Keep
No 83(b) (Ordinary Income)~37%$3.7M tax$6.3M
With 83(b) (LTCG)~20%$2.0M tax$8.0M

You save ~$1.7M on a $10M gain by filing 83(b). Consult your tax advisor for your specific situation.

What are Profits Interest Units (PIUs)?

PIUs are a form of equity compensation in LLCs that give you a share of future profits rather than current value. Key benefits:

  • $0 value at grant: No immediate tax liability when you receive them
  • 83(b) eligible: File within 30 days to lock in the $0 basis
  • Capital gains treatment: All future appreciation taxed at LTCG rates
  • Vesting schedules: Your PIUs vest over the 4-year hold period
  • Participation in upside: You benefit from portfolio growth

Important: 30-Day Deadline

You must file your 83(b) election with the IRS within 30 days of receiving your equity. This deadline is strict and cannot be extended. Our team will guide you through every step of the process as part of your onboarding.