Item 5 - Additional Compensation 19
Item 6 - Supervision 19
Form ADV Part 2B Brochure Supplement 20
Marc T. Giannone CFP®, RICP 20
Item 2 - Educational Background and Business Experience 21
Item 3 - Disciplinary Information 22
Item 5 - Additional Compensation 22
Item 6 - Supervision 23
Form ADV Part 2B Brochure Supplement 27
Nathan Bergstrom 27
Item 2 - Educational Background and Business Experience 27
Item 3 - Disciplinary Information 27
Item 5 - Additional Compensation 27
Item 6 - Supervision 28
Form ADV Part 2B Brochure Supplement 27
Brian Hagan 27
Item 2 - Educational Background and Business Experience 27
Item 3 - Disciplinary Information 27
Item 5 - Additional Compensation 27
Item 6 - Supervision 28
Eaton-Cambridge Inc. (“Eaton-Cambridge” or the “Advisor”) is an investment advisory firm offering a
variety of advisory services customized to your individual needs. The services are more fully described
below.
Eaton-Cambridge Inc. was initially founded in 1998 under the business name Cambridge Wealth
Management, Inc. In September 2012, Cambridge Wealth Management, Inc. changed its name to Eaton-
Cambridge Inc. Eaton-Cambridge is owned by Robert Korljan (Founder, President and Wealth Management
Advisor) and Marc Giannone (Partner, Wealth Management Advisor, and Chief Compliance Officer).
Eaton-Cambridge offers the following advisory services to individuals, high net worth individuals, trusts,
estates, charitable organizations and business entities (each a “Client” and also referred to as “you”). As
previously stated, each of the services is more fully described below.
● Investment Management Services
● Selection of Third-Party Money Managers, Platforms and Programs
● Financial Planning Services
● Tax Services
● Advisory Services to Retirement Plans
Investment Management Services
Eaton-Cambridge provides investment management services to individuals, high net worth individuals,
pension and profit-sharing plans, charitable organizations, corporations or other businesses that are tailored
to meet the needs and investment objectives of the client. We offer discretionary portfolio management
services. Subject to any written guidelines, which you may provide, you will grant us discretion and authority
to manage your account. Accordingly, our firm is authorized to perform various functions, at your expense,
without further approval from you. Such functions include the determination of securities to be purchased
or sold and the amount of securities to be purchased or sold. We primarily recommend mutual funds and
exchange-traded funds ("ETFs") and individual stocks in limited circumstances. Once the portfolio is
constructed, we provide continuous supervision and re-optimization of the portfolio as changes in market
conditions and your circumstances may require. 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.
Selection of Third-Party Money Managers, Platforms and Programs
We have entered into agreements with various third-party investment advisors for the provision of certain
investment advisory services. Factors considered in the selection of a third-party advisor include but may
not be limited to: i) Our firm’s preference for a particular third-party advisor; ii) the client’s risk tolerance,
goals and objectives, as well as investment experience; and, iii) the amount of client assets available for
investment. In order to assist clients in the selection of a third-party advisor, we will typically gather
information from you about your financial situation and investment objectives in regard to the management
of the account.
The third-party advisor may customize your portfolio by blending traditional investment strategies with an
allocation to asset classes. The investment strategy adopted by the third-party advisor could include value,
growth, or contrarian investing styles. Generally, securities transactions will be decided upon and executed
by the third-party advisor on a discretionary basis. This means that the manager selected will have the ability
to buy and sell securities in your account without obtaining your approval. We will not manage or obtain
discretionary authority over the assets in accounts participating in these programs. Generally, clients may
not impose restrictions on investing in certain securities or types of securities in accounts managed by a
third-party advisor.
We will periodically review reports provided to the client. We will contact the client at least annually, or
more often to review your financial situation and objectives, communicate information to the third-party
advisor managing the account as necessary, and, to assist you in understanding and evaluating the services
provided by the third-party advisor. Please notify us of any changes in your financial situation, investment
objectives, or account restrictions.
A complete description of the services provided, the amount of total fees, the payment structure, termination
provisions and other aspects of the third-party advisor’s advisory business are detailed and disclosed in: i)
the third-party advisor’s Form ADV Part 2A; ii) the program wrap brochure (if applicable) or other
applicable disclosure documents; iii) the disclosure documents of the portfolio manager(s) selected; or, iv)
the third-party advisor’s account opening documents. A copy of all relevant disclosure documents of the
third-party advisor and of the individual portfolio manager(s) will be provided to anyone interested in these
programs/managers.
Financial Planning Services
We offer various financial planning related services, which assist our clients in the management of their
financial resources. Financial planning services are based upon an analysis of your individual needs and
begin with one or more information gathering consultations. Once we collect and analyse all documentation
gathered during these consultations, we provide a financial plan designed to achieve your financial goals
and objectives. In this way, Eaton-Cambridge assists you
in developing a strategy for the successful
management of income, assets, and liabilities. In general, financial planning services may include any one
or all of the following:
● Cash Flow Analysis – Assessment of your present financial situation by collecting information
regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios,
pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk, coordinate,
and organize records, and estate information.
● Retirement Analysis – Identification of your long-term financial and personal goals and objectives
including advice for accumulating wealth for retirement income or appropriate distribution of assets
following retirement.
● Portfolio Analysis/Investment Planning – We provide investment alternatives, including asset
allocation, and effect on your portfolio. We evaluate economic and tax characteristics of existing
investments as well as their suitability for your objectives.
● Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding
of college or other post-secondary education.
● Estate Analysis – We provide advice with respect to property ownership, distribution strategies, estate
tax reduction, and tax payment techniques.
The recommendations and solutions are designed to achieve your desired goals, subject to periodic
evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans
are based on your financial situation based on the information provided to the firm. We should be notified
promptly of any change to your financial situation, goals, objectives, or needs.
You may choose to accept or reject our recommendations. If you decide to proceed with our
recommendations, you may do so either through our investment advisory services or by using the advisory
or brokerage provider of your choice.
Advisory Services to Retirement Plans
Eaton-Cambridge provides advisory services to qualified retirement plans. Our retirement plan services are
designed to assist in the investment management process for employers. Eaton-Cambridge provides
investment advisory services and assists plan fiduciaries with plan management. Pursuant to the terms of an
agreement with the client, Eaton-Cambridge may serve as an ERISA Section 3(38) Investment Manager for
investment selection, monitoring and construction of model investment portfolios. Eaton-Cambridge will
also provide recommendations regarding the frequency of rebalancing of the plan participant portfolios. In
providing such services, we generally use the same investment strategies and construct similar portfolios as
those used with our individual investment management clients. Eaton-Cambridge's range of services
includes:
● Investment selection, monitoring and model portfolio construction with rebalancing.
● Plan analysis to ensure the plan provisions align with the employer's goals and objectives.
● Employee education meetings, at least annually to educate participants regarding plan provisions,
investment options, and the importance of planning for retirement.
In providing services to the Plan, our status is that of an investment advisor registered under the Investment
Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In
performing fiduciary services, we are acting either as a non-discretionary fiduciary of the Plan as defined in
Section 3(21) under ERISA, or as a discretionary fiduciary of the plan as defined in Section 3(38) under
ERISA.
Plan Participants who wish to engage our firm for individualized financial planning or consulting services
outside the scope of the qualified plan may do so by executing a separate agreement, including separate fees
and fee payment arrangements, with our firm.
Pontera
We use a third-party platform (Pontera) to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to
have custody of Client funds since we do not have direct access to Client log-in credentials to affect trades.
We are not affiliated with the platform in any way and receive no compensation from them for using their
platform. A link will be provided to the Client allowing them to connect an account(s) to the platform. Once
Client account(s) is connected to the platform, Advisor will review the current account allocations. When
deemed necessary, Eaton-Cambridge will rebalance the account considering client investment goals and
risk tolerance, and any change in allocations will consider current economic and market trends. The goal is
to improve account performance over time, minimize loss during difficult markets, and manage internal fees
that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes
will be made as deemed necessary.
Types of Investments
Eaton-Cambridge reserves the right to advise you on any other type of investment that it deems appropriate
based upon your stated goals and objectives. We may also provide advice on any type of investment held in
your portfolio at the inception of the advisory relationship or on any investment on which you request advice.
Educational Seminars and Newsletters
Eaton-Cambridge may periodically provide educational seminars for its current and potential clients. While
the content may be informed by current events and emerging financial planning related issues, these seminars
will be educational in nature and will not be tailored to any individual client’s needs but rather give general
information. Access to these seminars will be free to all current and potential clients. Eaton-Cambridge does
also provide occasional newsletters to clients at no charge.
Assets Under Management
As of December 31, 2023, we manage $319,886,737 in client assets on a discretionary basis, and $0 in client
assets on a non-discretionary basis. Eaton-Cambridge does not have trading authority over the assets placed
with third party managers but oversees the management of the assets and the suitability of the management
program selected by the Client.