Bridgebay Financial, Inc. (Bridgebay) is an independent, institutional investment consulting firm that was incorporated in the State of California in December 1987. The firm was founded by Ms. G. Linda Ruiz- Zaiko. The firm provides investment consulting services to institutional clients including corporations, defined contribution plans, corporate foundations, not-for-profit organizations, and non-governmental organizations. Bridgebay is a SEC registered investment adviser under the Investment Advisers Act of 1940. The firm does not manage client assets on a discretionary or non-discretionary basis nor does its custody client assets. Bridgebay does not sponsor nor participate in any wrap-fee programs. Bridgebay’ s advisory services are focused on three key business areas:
• Retirement Plan Services
• Institutional Investment Consulting Services
• Treasury Management Consulting Services Specialty evaluation and additional manager search services that Bridgebay provides include:
• Diversity-Owned Investment Managers
• OCIO (Outsourced Chief Investment Officer)
• Multi-Asset Class Investment Managers
• ESG (Environmental, Social, and Governance) Investment Managers Retirement Plan Services Bridgebay advises employer retirement plans 401(k), 403(b), 457, profit-sharing, and defined contribution plans on investment policy statements, committee charters, asset allocation, investment style selection, investment manager commingled fund or mutual fund selection, ongoing monitoring, record-keeper evaluation and selection and trustee bank selection. Bridgebay provides ongoing monitoring of retirement plan investments. Bridgebay provides advice through consultations with Retirement Committees which does not involve discretionary account management services. Investment Policy Statement An Investment Policy Statement provides plan fiduciaries with a disciplined framework and set of established, prudent standards for the management and oversight of the retirement plan. The policy develops the due diligence and decision-making process for sound plan governance. The Benefits of a Well-Developed IPS
• Acts as the foundation for how an investment program is to be administered by providing clear risk and return objectives
• Establishes the performance evaluation methods and any constraints to be considered
• Creates a framework for fiduciary decisions
• Applies a disciplined and systematic investment approach 2 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193
• Increases the likelihood of meeting investment goals Bridgebay creates a policy that sets the plan objectives, authorities and responsibilities, addresses plan fees, educational objectives, intent to be 404(c) compliant and establishes overall controls consistent with ERISA, DOL and relevant regulatory legislation. The policy establishes a prudent procedure and process for plan management, monitoring and investment oversight. The investment policy statement acts as the foundation for how an investment program is to be administered by providing risk and return objectives, performance evaluation methods, and any constraints that must be considered. Annual reviews of the Investment Policy help fulfill fiduciary responsibilities. Asset Allocation and Gap Analysis The asset allocation and fund choices are the most visible aspects of the plan. An efficient asset allocation in the fund line-up will enable plan participants to create diversified portfolios that will provide sufficient future retirement income. Bridgebay works with plan sponsors to develop an asset allocation structure that is appropriate for their participants. The asset allocation decision seeks strong representation in each asset class, diversified by investment style, and an appropriate risk/return profile. A well-designed fund line-up assists plan sponsors in meeting 404(c) requirements and provides an opportunity for participants to prepare for a secure retirement. Our Gap Analysis assesses plan’s fund lineup along the risk/return spectrum and identifies where gaps and redundancies exist. A fund line up can have a high number of funds yet not provide sufficient diversification. The Gap Analysis may also indicate a need for risk-based (conservative, moderate, aggressive) asset allocation funds and/or target-date funds. Investment Fund Analysis Bridgebay evaluates the overall fund menu to ensure that the asset classes are well represented, cost effective and provide a broad range of funds including actively managed and indexed funds that will ensure participant success. At all times, Bridgebay ensures that all investments in the plan are consistent with the plan’s investment policy statement (IPS). Bridgebay evaluates the fund selections relative to the plan’s unique characteristics such as asset size, number of participants, demographics of participants, cash flows and additional retirement benefits offered by the plan sponsor. Often, participants prefer socially responsible investments and green funds. The analysis focuses on the most cost-effective structure that optimizes asset allocation for participants yet considers the administrative aspects of managing the plan efficiently. Bridgebay’s institutional, investment due diligence is based on our research and evaluations prepared by our consultants and experienced investment professionals. Our institutional quality research on investments and funds is well-documented and presented to the Retirement Committee. 3 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Fund Selection Process Asset Allocation Funds and QDIA Evaluations Bridgebay evaluates asset allocation fund suites (target date and target risk funds) and the underlying investments to ensure that the retirement plan has best-in-class diversified funds. Bridgebay uses a range of advanced quantitative tools to assess the performance, quality, asset allocation and embedded fees of Target Date Funds and Target Risk Funds. Target Date and Target Risk Funds are all constructed differently. They have variations in asset classes, allocations, underlying funds and glide paths. Funds differ by their blend of traditional, index, actively managed, derivatives, and alternative asset classes. Many target date funds provide their own custom benchmarks that mirror their own asset allocation and glide path. Making evaluations as to the effectiveness of the fund management and asset allocation decisions can be complex making comparisons between target date funds suites difficult. Our analysis helps plan sponsors understand how their plan's target date funds perform separately by date, compared to third-party benchmarks and their date-based peers. Fee Analysis Prudent best practices specify that the Retirement Committee should periodically review the fees charged by the retirement plan's providers for reasonability. New fee disclosure requirements under the DOL section 408(b)(2) legislation require defined contribution plan providers to disclose all fees. Many fee structures have been hidden and complex to understand. The plan sponsor’s fiduciary responsibility is to ensure that fees are reasonable. Bridgebay assists plan sponsors to re-negotiate fees or recapture fees through an ERISA budget account that can be used to pay for additional plan services such as education, financial wellness or fees can be rebated to the participants. Total fee transparency enables the plan sponsor to enhance plan services, negotiate more competitive and reasonable fees. Bridgebay may benchmark service provider expenses against other providers through an RFP process to identify areas for service improvements and fee reductions. This information is key to re-negotiating service provider fees. We identify total fund fees, expense ratios, wrap fees, 12b- 1, and revenue sharing arrangements and the services covered for those fees. 4 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Bridgebay provides a summary of all asset-based fees and fixed fees, both direct and indirect expenses. Our consultants identify the all-in plan fees paid to providers for their services. Our fee analysis is summarized in a matrix which highlights the underlying costs of the plan. Investment Performance and Plan Monitoring Key to a prudent fiduciary process is the ongoing investment review and plan monitoring program. Our consultants present our evaluation and review the fund performance with the Retirement Committee quarterly. The fund performance summarizes quantitative and qualitative factors, peer comparisons, investment category rankings, and custom benchmark and market index comparisons. Proprietary Scoring System Our proprietary scoring process measures fund quality and synthesizes volumes of financial data into a clear and concise summary. The scoring information enables the Retirement Committee to understand and be confident in making informed decisions. User-Friendly Reports Bridgebay customizes presentations to meet the Committee’s specific level of detail and format. Our user-friendly quarterly reports take complex statistics and deliver an investment review that flags priority issues for the Retirement Committee to address. Meetings We are proactive in meeting consistently with our clients to review their plan. Our consultants meet quarterly with the Retirement Committee and will hold ad hoc meetings during uncertain markets. Performance Measurement Bridgebay helps the plan fiduciaries understand the factors that influenced the investment performance. Bridgebay measures fund performance, attribution, manager success and value-added, risk controls, volatility, consistency of performance, use of leverage and derivatives, and soundness of the strategy. Bridgebay monitors qualitative issues relating to the management stability, research quality, discipline, and potential conflicts of interest. We compare the investments' short-term and long-term performance against relevant market benchmarks, style indexes and peer group universes. 5 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Trends and Developments Bridgebay monitors the funds and their parent companies for developments that may impact the plan's performance and client service. Regulatory, legal, and market developments in the institutional retirement market are reported to the Retirement Committee on an ongoing basis. Proactive Watch Bridgebay has a prescribed criteria and prudent procedure for proactively monitoring, tracking, watch listing, and replacing funds. Our constant vigilance of plan investments is a principal element of a thorough governance process. Provider Search and Evaluation Our RFP provider search is customized to focus on services that are important to the retirement plan. Bridgebay emphasizes open architecture, efficient administrative services, best-in-class funds, fee transparency, effective participant education and communications. Bridgebay uses a broad database of record keepers and retirement plan service providers. Based on the plan's assets, complexity, and number of plan participants, Bridgebay provides the depth of information for the plan sponsor to select the best fit and most appropriate service provider. Our custom RFPs are constructed from a comprehensive database of over 300 questions that Bridgebay can modify to cover key service areas including:
• Financial Strength of Provider
• Administration and Recordkeeping
• Technology and Systems
• Cybersecurity
• Fees (Direct and Indirect)
• Investments
• Compliance
• Participant Communications
• Financial Wellness
• Service Guarantees
• Legal and Regulatory Filings
• Conversion and Transition Timetable Our proprietary scoring matrix enables plan sponsors to consider numerous qualified providers and make fair evaluations using consistent criteria for assessment. Our scoring matrix ranks providers, side-by-side comparisons of services and costs, and financial strength. Our RFP services are a thorough, well-documented due diligence process that can be used for audit and fiduciary purposes. The documentation and extensive evaluation validate the final provider selection by the plan sponsor. Bridgebay strives to identify the service provider that is the best fit for the plan. Key considerations include identifying the highest quality investments, well-integrated participant services and plan sponsor services. 6 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Plan Design Legislative and regulatory changes continue to burden plan sponsors with changing rules requiring a continuous review of plan design and compliance. As retirement plan experts, Bridgebay coordinates closely with plan sponsors and their providers to ensure that critical legal, design and compliance issues impacting the plan remain current. Some of the plan design features that Bridgebay considers include:
• Automatic enrollment
• Automatic escalation
• Re-enrollment
• Roth 401(k)
• Post 1986 after-tax contributions
• Employer match
• Employer contribution
• Safe harbor plan
• In-plan Roth conversion
• Brokerage window
• Loan provisions
• Withdrawal provisions
• Managed accounts
• Retirement income
• QDIA Fiduciary and Retirement Committee Services Plan fiduciaries may include Human Resource professional, Treasury professional or Retirement Committee members. Our experience with retirement committees enables us to suggest effective plan governance procedures that mitigate fiduciary liability and provide best practices in plan monitoring and management. The complexity of 401(k) and 403(b) plans has never been greater. As the different types of defined contribution and deferred compensation plans continue to converge to the ERISA-covered and similar fiduciary standards,

we recommend that Retirement Committees be aware of ERISA standards even if they do not currently have an ERISA-covered plan. Bridgebay delivers the following services as part of our ongoing engagements:
• Investment Policy Statement updates
• Benchmark investment fund fees and expenses
• Review fee disclosures per 408(b)(2) requirements
• 404(a) and 404(c) compliance guidance and monitoring
• Fiduciary education for Retirement Committee members
• Document Retirement Committee actions/decisions
• Document an investment due diligence process
• Investment evaluations per the Investment Policy Statement
• Communicate regulatory and legislative changes Employee Communications and Education An effective, ongoing employee education and communications program is critical to the success of any retirement plan. Bridgebay helps clients decide the most effective education and communication strategy for their participants. Bridgebay understands that educational needs vary greatly across industries. We will work with plan sponsors to design and execute the most appropriate program for specific employee cultures. Consistent implementation of the plan increases employee understanding and participation while raising the profile and appreciation of the benefit. Bridgebay will work with the plan sponsor’s Human Resources personnel and the plan’s third-party 7 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 education provider to set up an annual communications program that delineates expectations and measures success. Bridgebay monitors plan participation, deferrals and diversification measures which may indicate the quality and level of participant-communications. Bridgebay works with plan sponsors to develop metrics, survey participant feedback and measure the impact of the communications program. A tailored communications program may require the third-party education provider to offer these services:
• Financial wellness
• Student loan modeling
• Online calculators and financial planning tools
• Pre-enrollment communications
• Re-enrollment services
• Multiple media for targeted communications
• On-site group meetings
• Multi-lingual materials, online and phone representatives
• Video conferencing capabilities
• Webinars on current topics A well-crafted communication program will enhance participation, satisfaction, understanding of asset allocation and risk tolerance. This helps plan sponsors to meet 404(c) requirements to provide adequate education about investing in their employer's retirement plan. Institutional Investment Management Consulting Services Bridgebay provides investment consulting services to institutional clients including corporations, corporate foundations, not-for-profit organizations, and non-governmental organizations. Our firm offers pragmatic solutions to a diverse range of investment consulting engagements. In addition to traditional asset manager searches, we conduct specialty evaluations and manager searches for institutional clients including:
• Diversity-Owned Investment Managers
• OCIO (Outsourced Chief Investment Officer)
• Multi-Asset Class Investment Managers
• ESG (Environmental, Social, and Governance) Investment Managers Our consulting style has consistently focused on the four key areas involved with designing, implementing, monitoring and controlling investment programs. We provide the following institutional consulting services:
• Investment policy statements
• Separate account and pooled account evaluations
• Investment manager evaluations
• Separate account manager search and selection
• Institutional mutual fund and commingled fund selection
• Performance benchmarks 8 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193
• Performance evaluation and reporting
• Quarterly performance reporting
• Custodian and trustee searches
• Manager universe and peer comparisons Investment Policy Statement Bridgebay consultants review and update the Investment Policy Statement to incorporate additional protections in light of changing market innovations and improved risk management techniques. All modifications will be recommended based on the client’s risk tolerance and investment horizon. The policy review includes safeguards to avoid the inadvertent introduction of excessive risk, compliance issues, poor collateral quality, and hidden derivative exposures. Investment Manager Selection and Evaluation We conduct investment manager searches and evaluate existing managers for various institutional clients with multiple managers and asset pools. Our ongoing discussions with investment managers focus on investment performance relative to their peers and organizational issues such as changes in ownership, retention of professional staff, fee changes, litigation and new products. We evaluate all managers in the context of their objectives and guidelines and specifically comment on factors affecting performance. We inform clients of important developments and, when appropriate, may recommend changing managers if they are not meeting the client's objectives. The manager search process consists of having the manager candidates complete a comprehensive Request for Proposal which provides detailed information about their personnel, investment strategies, portfolio characteristics, pre-trade and post-trade compliance systems, and risk management processes. Any material regulatory or pending litigation disclosures are requested. Investment Manager Search Process 9 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Performance Measurement Bridgebay provides performance measurement in quarterly client reports that compare the portfolio total rates of return against the returns of relevant benchmark returns. Some of the third-party benchmarks include indices provided by BloombergBarclays, FTSE, ICE BoA, MSCI, Russell, and S&P. Ongoing Monitoring Bridgebay provides quarterly monitoring of client investments managed in-house by the client or by third party investment managers. The monitoring process includes performance measurement, risk monitoring, market benchmarks, economic/market updates and investment style changes. We meet with our clients quarterly to review the reports, interpret the results and update the investment approach as appropriate. Universes and Peer Group Comparisons Bridgebay uses an array of peer group and manager universes from third party databases and data obtained through our manager search process. The composite returns are based on portfolios with similar characteristics. Universe comparisons are made based on the managers' 1-, 3-, 5- and 7-year annualized returns. Additional peer comparisons include the volatility of returns, risk/return profile, risk-adjusted and duration adjusted returns. Custodian Selection & Implementation Bridgebay conducts custodian searches for domestic and international fixed income and equity assets. Custodians are evaluated based on their global securities clearing, securities lending, reporting capabilities, online services, service standards, systems capabilities, credit strength, insurance coverages and pricing. Bridgebay provides a side-by-side comparison of custodian bids and services that enables our clients to make relevant comparisons. 10 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Treasury Management Consulting Services Working Capital Clients We provide consulting services for working capital and liquidity management to institutional clients. Our clients include Treasury groups of corporations and non-profits that manage liquidity portfolios internally or use external investment managers and cash management funds. Some Treasury groups may have multiple pools of balance sheet cash with different investment horizons, risk profiles, tolerance for volatility and liquidity needs. These clients invest in fixed income securities. Strategic Investment Plan The Strategic Investment Plan is the framework for the overall investment program. Bridgebay has prepared investment plans for cash pools resulting from mergers, debt issuance, and secondary equity offerings. The monies may include cash pools earmarked for future acquisitions, capital expenditures, stock repurchase, strategic business development, and short-term liquidity. The overall investment plan may include specific gain/loss constraints and liquidity requirements. The strategic investment plan is designed to meet specific needs such as construction drawdown schedules, bond covenants, tax efficiency or regulatory limitations. Corporate Cash Investment Policy Statements We develop and update investment policies specific to liquidity and corporate cash portfolios that have unique needs such as liquidity, loss constraints, accounting issues, and risk controls. The policies incorporate short investment horizons, diversification, cash flow needs and short-duration benchmarks for performance tracking. Guidelines are tiered to reflect different pools of cash with different risk tolerances, investment horizons and liquidity needs. Investment policies cover taxable US domestic, offshore USD and multi-currency, tax efficient (crossover), municipal (tax-advantaged) and global bonds. Corporate Cash and Liquidity Portfolio Evaluation Bridgebay is experienced in evaluating many different fixed income securities including, but not limited to the following:
• Commercial Paper
• Bank Obligations
• US Governments and Agencies
• Corporate Notes
• Sovereign Bonds
• Global Corporate Bonds
• SOFR Floating Rate Notes (FRN)
• Asset Backed Securities (ABS)
• Mortgage-Backed Securities (MBS)
• Covered Bonds
• Collateralized Mortgage Obligations (CMO)
• Municipal Bonds Treasury Risk Management Bridgebay provides treasury consulting services to public and private corporations, not-for-profit and public sector organizations. Bridgebay advises Chief Financial Officers, Treasurers, and Treasury Managers on various aspects of working capital management strategies, investment programs, monitoring and risk controls. Some institutional clients require collaboration with Finance and Treasury in reviewing and analyzing their investment structure and risk management practices. Bridgebay may assist them in preparing Treasury risk management plans, building consensus and gaining approval for their plan and presenting the results to an Audit or Finance Committee. 11 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Ongoing Portfolio Monitoring Bridgebay provides ongoing portfolio monitoring and reviews the portfolio composition and characteristics of corporate cash/liquidity portfolios that consist of the following:
• Credit Quality Distribution
• Sector or Security Type Distribution
• Industry Distribution
• Duration Breakdown
• Maturity Distribution
• Weighted Average Life
• Convexity
• Yield by Sector
• Option Adjusted Spread (OAS) The liquidity portfolio summary includes the following data sourced from the client's third-party manager and third-party custodian reports:
• Amortized Cost
• Fair Market Values
• Unrealized Gains/Losses
• Average Portfolio Credit Quality
• Average Portfolio Duration
• Average Maturity
• Book Yield
• Yield to Maturity
• Total Rate of Return
• Comparative Performance to Market Benchmark Corporate cash/liquidity portfolios managed by the client or third-party investment managers are generally comprised of investment grade fixed income securities. Bridgebay monitors these portfolios for credit quality, guideline compliance, issuer and sector concentration, duration, weighted average life and yield curve positioning. Bridgebay provides quarterly and trailing annual performance data compared to portfolio benchmarks. Fixed Income Manager Searches Bridgebay conducts fixed income manager searches for taxable, tax-advantaged, crossover, domestic, offshore, and multi-currency portfolios that are appropriate for corporate cash and liquidity portfolios. The investment manager selection process for separate account management follows the same process described in the Institutional Investment Management Consulting Services. The due diligence process screens potential managers for their ability to manage portfolios against net realized gain/loss constraints and provide sufficient short-term liquidity per the client's requests. The manager evaluation includes a quantitative analysis of the overall portfolio trend by sector, maturity, duration, average quality, issuer type, risk/return, and duration-adjusted returns. The qualitative assessment addresses such issues as personnel turnover, experience, expertise, investment implementation, client turnover, investment discipline, credit research and bond structure research capabilities. 12 Bridgebay Brochure & Form ADV Part 2A CRD Number 130279 SEC File No. 801-108193 Custodian Selection & Implementation Bridgebay conducts custodian searches for separately managed, corporate cash and liquidity portfolios. Criteria considered in the custodian selection includes the financial strength of the custodial institution, insurance coverage, SSAE 18 (SOC reports), regulatory oversight, disaster recovery plans, reporting capabilities, on-line services, service standards, systems capabilities, fair market valuations and competitive fees. Bridgebay does not have discretion in the selection of the custodian. Bridgebay provides a comparison matrix of custodian bids and services that highlights relevant comparisons. Bridgebay, at the client’s request, may assist in the negotiation of fees and service standards and terms with the custodian. Bridgebay does not provide legal advice.