Lebenthal Global Advisors, LLC, is a federally registered investment adviser primarily based in Hauppauge, New York. We are organized as a Limited Liability Company organized under the laws of the State of New York. Dominick Tavella is the President and principal owner. Michael Hartzman is the Vice President. LGA has been providing investment advisory services since May 2017.
As used in this brochure, the words "we," "our," "us" and "LGA" refer to Lebenthal Global Advisors, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person in this brochure. Our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
We offer portfolio management services through the Lebenthal Advisory Wrap Fee Program ("Program") as described in this wrap fee program brochure to prospective and existing clients. We are the sponsor and one of the investment advisers for the Program. A wrap-fee program is a type of investment program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay our firm a single fee, which includes money management fees, certain transaction costs, and custodial and administrative costs. You are not charged separate fees for the respective components of the total services. We receive a portion of the wrap fee for our services. The overall cost you will incur if you participate in our wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the Program.
Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid.
The Wrap Fee Program Services The Lebenthal Advisory Wrap Fee Program ("Program") offers individualized portfolio management, asset allocation, portfolio monitoring, and consolidated reporting. Portfolios may include mutual funds, exchange traded products ("ETPs"), stocks, bonds, options, and alternative investments such as limited partnerships and real estate investment trusts or third-party investment managers.
Your portfolio ("account" or "investment account") and the investment strategies utilized are determined based upon your specific individual investment objectives, goals and risk tolerances. Our Advisory Representatives periodically adjust your account (a process referred to as "rebalancing") to help ensure that your investment account remains consistent with your objectives, goals, and risk tolerances.
Our Advisory Representatives rely on you to notify them of any changes in your objectives, goals and risk tolerances, as well as any other material changes in your personal circumstances (such as your employment, marital status, financial condition, etc.). These changes may prompt changes in your investment account and the investment strategies employed.
Additionally, we may recommend or select a third-party investment manager to provide investment management services for all or a portion of your investment portfolio. Generally, we will recommend our affiliate Lebenthal Diversified Asset Management Inc. ("LDAM"). Our affiliation with LDAM is further disclosed in the section entitled Other Financial Industry Activities and Affiliations. To assist you in the selection of a particular third-party investment manager, we will use the information you have provided about your investment objectives, goals, and risk tolerances, as well as other relevant information, to identify a third-party investment manager(s) whose investment strategies appear appropriate for you.
4 Some of the other relevant information considered in recommending a third-party investment manager include (but are not limited to):
•your preference for certain types of investments or investment strategies;
•your investment time horizon;
•the size and composition of your investment account;
•your tax considerations;
•your Advisory Representative's prior experience with and preferences for particular investment managers;
•the fees charged by the investment manager; and
•the experience and capabilities of the investment manager. We will provide the respective third-party investment manager's disclosure brochure which will more fully describe the recommended program.
We offer these services on a discretionary basis. Through discussions, interviews and questionnaires we will assist you in determining your investment objectives. We will recommend managers, based on your objectives, risk tolerance, liquidity needs, tax considerations and any other issues related to your financial situation.
We will meet with you no less than annually to discuss the performance of your investments and update your financial information.
You should notify us promptly if there are any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon the management of your account.
Our Advisory Representatives may manage your investment account on either a discretionary basis (meaning that you authorize your Advisory Representative to make specific investment decisions on your behalf without obtaining your approval prior to each transaction) or non-discretionary basis (meaning that your Advisory Representative must obtain your specific prior approval before a transaction can be effected for your investment account).
Whether your Advisory Representative is authorized to exercise discretion with respect to your investment account is your choice. When you establish an advisory relationship with us, we will ask that you advise us in writing how you would like your Advisory Representative to handle your account. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and/or through trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
The scope of the discretionary authority that you may grant to one of our Advisory Representatives is limited to selecting specific investments or third-party investment managers for your account and deciding how to allocate your account assets among those investments. Your Advisory Representative may decide if and when to buy, hold, or sell those investments. If your Advisory Representative selects a third-party investment manager to manage your account, the third-party investment manager will have discretionary authority to make investment decisions for your account. Once you have granted discretionary authority to your Advisory Representative, it is effective until you change it or revoke it in writing.
Execution of Trades Transactions for the Account will be executed through Raymond James & Associates, Inc. or Schwab Advisor Services division of Charles Schwab & Co., Inc. ("Schwab"). The specific broker-dealer and custodian will be named in the Program agreement. In certain cases, clients may direct that transactions for the client's Program Account be executed through an unaffiliated broker-dealer named by the client in the Program Agreement.
5 Other Assets In certain limited circumstances, Lebenthal Financial Services, Inc. ("LFS"), an affiliated broker-dealer may permit assets that are not being managed under the Program to be held in the same account as the Program assets.
These assets are referred to as "non-Program assets." LGA will not provide discretionary management of the non- Program assets, and the assets will not be considered when LGA manages the Program Assets. You will typically receive consulting services in connection with the non-Program assets from your Advisory Representative and pay fees to them based on the value of the non-Program assets.
Fees and Compensation Our Program fee varies depending upon the market value of your assets under our management, the type and complexity of the asset management services provided, as well as the level of administration requested either directly or assumed by the client. Our Program fee is made up of an advisory fee and a platform fee, both of which are negotiable and will be memorialized in the Program Agreement you enter into with us. The maximum advisory fee that can be assessed is 2.00% and the maximum platform fee that can be assessed is 0.40%. Thus, the maximum Program fee that you could ever be charged is 2.40%. However, our clients are typically charged a total Program fee that ranges between 1.25% and 1.75%. Assets in each of your account(s) are included in the fee, unless excluded by written acknowledgement.
Depending on the asset value of your account(s), our Program fee will be assessed either on a single flat fee basis or on a blended tiered fee basis; whichever is most favorable to you. Accounts with a value of $800,000 or less, will typically be charged a single flat fee basis. Accounts with a value of more than $800,000 will typically be charged on a blended tiered fee basis. For a better understanding of a flat fee basis and a blended fee basis, please see the examples below. Please note these examples are for illustrative purposes only.
For Illustrative Purposes Only (All agreed upon fee schedules will be provided in the Advisory Agreement) A flat fee basis is when a single fee rate is assessed against the total value of your account. For example, an account with a balance of $500,000 would pay a 1.25% (1.00% advisory fee + 0.25% platform fee) on the entire balance of $500,000. When assessing a fee on blended tiered basis, different fee rates will be applied to different asset tiers. Using the same 1% advisory fee cited in the example above, an account containing a balance of $1,000,000 would pay 1.40% on the first $100,000 of the client's account balance; 1.35% on the next $150,000 of the client's balance; 1.25% on the next $250,000 of the client's balance; and 1.15% on the remaining $500,000 of the account balance. Our blended tiered Program Fees are determined as follows: Value of Account Assets Account Size Range Maximum Annual Program Fee Maximum Advisory Fee Platform Fee Up to$100,0002.40 %2.00 %0.40 % Next $150,000$100,001 - $250,0002.35 %2.00 %0.35 % Next $250,000$250,001 - $500,0002.25 %2.00 %0.25 % Next $500,000$500,001 - $1,000,0002.15 %2.00 %0.15 % Next $4,000,000$1,000,001 - $5,000,0002.12 %2.00 %0.12 % Assets over $5,000,000$5,000,0001 and up2.05 %2.00 %0.05 % 6 The Program Fee will be calculated based on the value of the Program Assets in the account on the last day of the previous quarter, as determined by the account custodian. If the Program Agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client.
Furthermore, the wrap fee charged by our firm may be higher or lower than those charged by others in the industry, and that it may be possible to obtain the same or similar services from other firms at lower or higher rates. A client may be able to obtain some or all of the types of services available through our firm's wrap fee program on an individual basis through other firms and, depending on the circumstances, the aggregate of any separately paid fees may be lower or higher than the annual fees shown above.
Either party at any time upon written notice may terminate the Program Agreement and a pro rata portion of any Program Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by LGA.
The Program Fee covers the consulting services provided by the Advisory Representative, the portfolio management services provided by LGA and third-party asset managers (if applicable), program administrative services, execution of transactions through the broker-dealer named in the agreement and custodial services (unless otherwise agreed between the custodian and the client). LGA's portion of the Program Fee for portfolio management is up to 2.00%.
Lebenthal Financial Services, Inc. ("LFS") receives a portion of the Program Fee for supervision and administrative services, if one of its registered representatives is the Advisory Representative for the Account. If the broker-dealer for the account is LFS, LFS will also receive a portion of the Program Fee for the execution of transactions and generally pays part of its compensation to the custodian. If Lebenthal Diversified Asset Management Inc. ("LDAM")

provides third-party investment management services, then LDAM will receive a portion of the Platform Fee for its services.
If Client directs LGA to execute transactions through Raymond James & Associates, Inc. and/or Schwab, LGA will pay the broker-dealer a transaction charge for each trade in the account. The cost of these trades is covered by the Program Fee. The client will not pay separately for each transaction, unless specifically set forth in the client's Program Agreement. Thus, LGA, including its Advisory Representative, will earn more compensation if fewer transactions are executed for the accounts or if transacted through its affiliated broker/dealer. LGA reduces this conflict of interest by managing these accounts in the same way that it manages accounts that execute through LFS.
LGA absorbs certain transaction costs in wrap fee accounts. We have a financial incentive not to place transaction orders in those accounts because doing so increases our transaction costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement.
The Program may cost you more or less than purchasing such services separately depending on the frequency of trading in the Program Account, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers and other factors.
The Program Fee does not cover:
•Brokerage commissions or other charges resulting from transactions not effected through the broker- dealer named in the client's Program Agreement;
•Any additional custodial services contracted for directly by the client with the custodian;
•Certain costs or charges that may be imported by the broker-dealer or custodian named in the client's Program Agreement or third parties, including costs associated with exchanging foreign currencies, odd- lot differentials, IRA fees, transfer taxes, exchange fees, wire transfer fees, postage fees, and other fees or taxes required by law. 7 In addition to the Program Fee, each mutual fund or exchange-traded products (ETP) in which a client may invest also bears its own fees and other expenses. The mutual funds available through the Program may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Program Fee and ETPs are available outside of the Program without paying the Program Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investment through the Program comes from redemptions of the client's mutual fund or other investments outside of the Program, there may be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Program Fee on those assets.
LFS will receive payments from mutual funds (including money market funds) pursuant to a 12b-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund's total assets and will affect the performance of the investments. These funds' advisory, administrative, and 12b-1 fees are described in the funds' prospectuses. Mutual fund share prices and execution costs differ based on share class. The Adviser will review the cost of a fund's share classes in conjunction with execution costs to assure that it meets its fiduciary duty to obtain best execution. The Advisory Representative will receive a portion of these fees received by LFS in his or her separate capacity as its registered representative in connection with non-Program assets. This creates a conflict of interest, as the Advisory Representative has a financial incentive to recommend LFS as broker-dealer of a client's account. You are under no obligation, contractually or otherwise, to purchase securities products through any person affiliated with our firm. Additional expenses associated with the specific underlying investment funds such as, redemption fees may apply. Certain mutual funds and mutual fund share classes used in the Program charge a redemption fee if shares are redeemed within a specified period. Clients may incur redemption fees in the event that a sell is executed or model update is implemented. Redemption fees vary by fund and are described in each fund's prospectus.
The Advisory Representative recommending the Program to the client may receive more compensation than if the client participated in other programs offered by LGA or paid separately for investment advice, brokerage, and other services. Thus, the Advisory Representative has a financial incentive to recommend the Program over other programs or services.
Custody An unaffiliated entity acts as custodian for Program Accounts. The custodian is named in the client's Program Agreement. LGA will recommend LFS as introducing broker-dealer clearing through Raymond James or Schwab to act as custodian for Program Accounts although we may agree to employ the services of one or more other custodians.
LGA is deemed to have custody when you authorize us to deduct our advisory fees directly from your accounts. At least quarterly, you will receive statements from your account custodian. The statements will show the advisory fees paid to us. Your custodian does not verify the accuracy of fee calculations so please review the fees carefully.
You should also confirm that the transactions in your account are consistent with the investment goals and the objectives for your account.
Products and Services Available to us from Schwab Schwab provides us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us.
Schwab also makes available various support services. Some of those services help us manage or administer our 8 clients' accounts, while others help us manage and grow our business. Schwab's support services are generally available on an unsolicited basis (we don't have to request them) and at no charge to us. Following is a more detailed description of Schwab's support services: Services that benefit you. Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab's services described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients' accounts and operating our firm. They include investment research, both Schwab's own and that of third parties. We use this research to service all or a substantial number of our clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:
•Provide access to client account data (such as duplicate trade confirmations and account statements)
•Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
•Provide pricing and other market data
•Facilitate payment of our fees from our clients' accounts
•Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:
•Educational conferences and events
•Consulting on technology and business needs
•Consulting on legal and compliance related needs
•Publications and conferences on practice management and business succession
•Access to employee benefits providers, human capital consultants, and insurance providers
•Marketing consulting and support
•Recruiting and custodial search consulting Our Interest in Schwab's Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don't have to pay for Schwab's services. Schwab has also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on our behalf. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as custodian and broker is in the best interests of our clients. As noted above, our selection is primarily supported by the scope, quality, and price of Schwab's services and not Schwab's services that benefit only us.
9 Standing Letter of Authorization LGA, or persons associated with our firm, may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, as long as the client has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third party wire transfers has access to the client's assets, and therefore has custody of the client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. We hereby confirm that we meet the above criteria.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Please promptly contact our Chief Compliance Officer, Thomas Katovitz at (516) 785-1800, should you have any questions or concerns regarding your account.
10