A. Firm Information
SevenBridge Financial Group, LLC (“SevenBridge” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commissions (“SEC”). The Advisor was organized as a Limited Liability Company
(“LLC”) under the laws of the Commonwealth of Pennsylvania in August 2015. Effective October 1, 2018,
SevenBridge became a wholly-owned subsidiary of SevenBridge Financial Holdings, LLC, which is primarily
owned by 7B Holdings, LLC (“7B Holdings”). 7B Holdings is owned by Charles R. Eberly (Managing Partner and
Chief Compliance Officer of SevenBridge) and Lawrence J. DeFluri (Managing Partner of SevenBridge). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by SevenBridge.
B. Advisory Services Offered
SevenBridge provides investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, retirement plans, and businesses (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the 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. SevenBridge’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
SevenBridge may provide Clients with wealth management services, which generally includes a broad range of
comprehensive financial planning and consulting services as well as discretionary management of investment
portfolios. These services may also be offered separately on a stand-alone basis.
Investment Management Services
SevenBridge 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. SevenBridge works with each Client to identify their investment goals and objectives
as well as risk tolerance and financial situation. SevenBridge will then develop a “core-satellite” investment
strategy for each Client portfolio. The “core” of a portfolio comprises investments that are financially sound, well-
managed and globally based with additional focus on generating a strong and growing dividend stream.
“Satellite” positions complement the “core” by adding either stability or the potential for growth.
SevenBridge primarily allocates Client assets among various individual debt and equity securities, as well as
certain mutual funds, exchange-traded funds (“ETFs”), and unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) in accordance with their stated investment objectives. For
Clients with smaller accounts and retirement plans, SevenBridge allocates (or recommends the assets be
allocated where the Advisor is not directly managing the assets) primarily among various mutual funds and ETFs.
For certain Clients, SevenBridge may employ stock option strategies to enhance and/or develop income by
selling puts and calls on existing cash and stock positions, respectively. Additionally, for certain Clients,
SevenBridge may recommend the use of Alternative Investments (Limited Partnerships) in Client portfolios. In
addition, SevenBridge sometimes utilizes options to protect account holdings via long put positions and zero-cost
collars. SevenBridge’s work with options is customized to the particular needs of each Client.
SevenBridge’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. SevenBridge 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.
http://sevenbridgefinancial.com
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SevenBridge evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. SevenBridge 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. SevenBridge 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 Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will SevenBridge 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 terms of the advisory agreement, please see Item 12 – Brokerage Practices.
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 recommend 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.
Donor Advised Fund Services – The Advisor also provides the Schwab Charitable Donor Advised Fund (“DAF”)
to Clients via Schwab Charitable, a web-based interface and administrative solution for charitable giving to
philanthropic vehicles via the Schwab Charitable Fund (“SCF”), an IRS approved philanthropic vehicle
established for the purpose of managing charitable donations contributed by or on behalf of donor clients. The
DAF allows the Advisor to actively manage assets that have been donated to and are owned by SCF, while
charging an investment management fee. The Advisor’s DAF participation is in conjunction with approval by the
SCF Investment Committee for the Advisor to operate as an advisory manager on the platform. The Schwab
Charitable Fund is an independent company and unaffiliated with the Advisor.
Use of Independent Managers – SevenBridge will recommend that Clients utilize one or more Independent
Managers for all or a portfolio of a Client’s investment portfolio. In such instances, the Client will then enter into
an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] will provide investment management and related services. SevenBridge may also assist in the
development of the initial policy recommendations and managing
the ongoing Client relationship. The Advisor will
perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy
remains aligned with Client investment objectives and overall best interests. The Advisor will also assist the
Client in the development of the initial policy recommendations and managing the ongoing Client relationship.
The Client, prior to entering into an agreement with an Independent Manager, will be provided with the
Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures).
Schwab Bank Pledged Asset Line® – The Advisor may introduce certain Clients to a Pledged Asset Line®, a non-
purpose revolving line of credit available offered through Charles Schwab Bank, secured by eligible assets held in
an account maintained at the Custodian. (“Lending Program”). In such instances, the Client’s assets in their
account[s] at the Custodian will be utilized as collateral for a non-purpose revolving line of credit. The
recommendation of a Lending Program presents a conflict of interest as the Advisor will continue to receive
investment advisory fees for managing the collateralized assets in the Client’s account[s]. Clients are not obligated
to engage the Advisor for the Lending Program. For additional information related to the risks involved non-purpose
loans, please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss.
Financial Planning Services
SevenBridge will typically provide a variety of financial planning services to individuals and families either as a
component of wealth management services or pursuant to a written financial planning agreement. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives.
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Generally, such financial planning services will involve preparing a financial plan or rendering a 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 business planning, investment planning, retirement
planning, insurance planning, personal savings, education savings, cash flow forecasting, large purchase
planning, charitable giving, tax planning, trust/estate planning and other areas of a Client’s financial situation.
A financial plan developed for 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. SevenBridge may also refer Clients to an accountant, attorney or other specialist, as
appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a
written summary of 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 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, 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.
Retirement Plan Advisory Services
SevenBridge provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Management Services (ERISA 3(38))
• Performance Reporting
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by SevenBridge serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of SevenBridge’s fiduciary status, the specific services to
be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
Business Consulting Services
SevenBridge also offers Business Consulting, pursuant to a written business consulting agreement. Services are
offered in several areas, depending on their goals, objectives and financial situation. Generally, such consulting
services will involve rendering a financial consultation based on the Client’s financial goals and objectives. This
consulting may encompass one or more areas of need, including, but not limited to business planning, tax
planning, cash flow forecasting, risk management and reporting.
A business consultation rendered to the Client will usually include general recommendations for a course of
activity or specific actions to be taken by the Client. SevenBridge may also refer Clients to an accountant,
attorney or another specialist, as appropriate for their unique situation.
Business consulting poses 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, as it would increase the amount of advisory
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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.
C. Client Account Management
Prior to engaging SevenBridge to provide investment advisory services, each Client is required to enter into one
or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – SevenBridge, in connection with the Client, will develop a strategy
that seeks to achieve the goals of the Client.
• Asset Allocation – SevenBridge will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – SevenBridge will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – SevenBridge will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
SevenBridge does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by SevenBridge.
E. Assets Under Management
As of December 31, 2022 SevenBridge manages approximately $444,150,000 in Client assets, all of which are
managed on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.