Who We Are
Seven Hills Financial, LLC (hereinafter referred to as "the Company", "we", "us" and "our") is a
fee-only1SEC registered investment advisor2, organized as a Florida Limited Liability Company
in May 2007 to provide a wide range of financial management services3designed to assist you,
our client4, achieve the financial stability, security, and independence you desire.
Owners
The following person controls the Company:
NameTitleCRD#
Jeffrey A. Johnson
Donald A. Butcher
Hanna P. Molta
Founder, Principal
Principal
Principal, Chief Compliance Officer
2813334
5025170
6945636
Our Mission
Our mission is to come alongside and assist you with managing your finances and implement
investment strategies designed to maximize wealth, maintain investment expectation, and
minimize risk. We do everything in our power to keep you focused on where you want to go,
offer advice on how best to get there, and continually remind you of the importance of
maintaining a disciplined investment approach to realize your dreams.
Assets Under Management
We offer two (2) investment management services: Portfolio Management and Portfolio
Monitoring.Portfolio Management accounts will be managed on a discretionary basis and
all PortfolioMonitoringaccountsarenon-discretionary,managedbyindependent
third-party money managers ("Portfolio Managers"). As of December 31, 2023, our assets under
management totaled:
Discretionary Managed Accounts .................................$106,683,153
Portfolio Manager5Accounts ......................................$1,425,008
What We Do
We provide investment management solutions and financial planning services. Our advisory
services begin with stressing the importance of you making fiscally responsible decisions and
1As a "fee-only" investment advisor, Seven Hills Financial, LLC does not receive compensation from any source other than what is directly paid by you, our
client, for the services we provide.
2The term "registered investment advisor" is not intended to imply that Seven Hills Financial, LLC has attained a certain level of skill or training. It is used
strictly to reference the fact that we are "Registered" as an "Investment Advisor" with the Florida Office of Financial Regulation - and with such other
regulatory agencies that may have limited regulatory jurisdiction over our business practices.
3Seven Hills Financial, LLC is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 ("ERISA") and/or as
defined under the Internal Revenue Code of 1986 (the "Code") for any financial management services provided to a client who is: (i) a plan participant or
beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an Individual Retirement Account ("IRA").
4A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a corporation and/or small
business, a trust, a guardianship, an estate, a retirement plan, or any other type of entity to which we choose to give investment advice.
5We do not include assets managed by independent Portfolio Managers in our "Regulatory Assets Under Management" calculation in our Form ADV Part 1A,
Item 5.F. since we do not manage these securities held in your account. The Portfolio Manager managing your account is required to include your assets in
their Discretionary Account totals since they do physically manage the securities.Form ADV
disciplined economic choices in your personal life, so we can effectively help you achieve your
monetary goals for today's needs, tomorrow's dreams, and strategy to build a lasting legacy
for future generations.
Some of the best advice we could offer is that success, achievement, and contentment in life
have little to do with personal wealth but are instead related to lifestyle choices.These
lifestyle choices are your unique values, life goals, and future plans.Therefore, the
economic solutions we develop, whether investment management and/or financial planning,
reflect howyoudefine true wealth -- not us. Our services include:
Investment Management
We offer two (2) investment management services: Portfolio Management and Portfolio
Monitoring.
Portfolio Management
Our Portfolio management strategies focus on designing a portfolio allocation of investment
company ("mutual funds") products, exchange-traded funds ("ETFs"), and the occasional
mix of equity ("stock") positions and fixed income/debt ("bond") instruments to achieve the
best return on your investment capital.
You can find more information about our management services under "Portfolio
Management Fee" in Item 5, "Fees & Compensation" below and further description of our
investment strategies under Item 8, "Methods of Analysis, Investment Strategies & Risk of
Loss."
Portfolio Monitoring
Portfolio monitoring consists of recommending Portfolio Managers for you to select, whose
investment disciplines most closely resemble your investment parameters as outlined in
your Investment Policy Statement ("IPS"). Included in your IPS is:
❖An asset allocation guideline to balance investment return and risk, which
emphasizes spreading risk among various asset classes and investment vehicles;
and,
❖Recommended Portfolio Managers to implement your asset allocation strategy.
Under these arrangements, we are not involved in the day-to-day management of your
portfolio assets. Our responsibility will be to continuously evaluate the performance of
your portfolio to ensure the Portfolio Manager adheres to your investment parameters and
to make recommendations regarding the Portfolio Manager as market factors and your
personal goals dictate.
You can find more information about our monitoring arrangements under "Portfolio
Monitoring Fee" in Item 5, "Fees & Compensation" below and how we evaluate Portfolio
Managers is also discussed under Item 8, "Methods of Analysis, Investment Strategies &
Risk of Loss."
Financial Planning
Thoughtful planning is one of the most important services that successful people use to
create an extraordinary personal life and business career. However, it requires a lifetime
commitment, not only from us, the Financial Planner, but from you as well. We offer two (2)
types of planning services to help you on this life journey:
Financial Life Planning
Financial Life Planning is about using money to make a life rather than the other way
around - a life to make money. It is a process of creating and implementing a financial plan
that is tailored to your most cherished dreams.
What is a Financial Life Plan?
Financial life planning is an evaluation of the investment and financial options available
to you based upon your defined lifestyle choices. Planning includes: (i) attempting to
make optimal decisions; (ii) projecting the consequences of these decisions for you in the
form of a financial life plan - a working blueprint; and, (iii) implementing the protocols
to achieve the objectives of the plan. Once complete the financial life plan, or working
blueprint, becomes the plumb line to compare a future financial performance to be sure
you are achieving your economic goals and objectives.
Financial Life Planning Composition
A financial life plan is a mutually defined review, analysis and evaluation of your
personal financial needs. In general, our financial life planning may encompass one or
more of the following areas of financial need as communicated by you:
❖Personal - Family records, budgeting, personal liability, estate information and
financial goals.
❖Education - Education IRAs, financial aid, and state savings plans including 529
plans, grants and general assistance in preparing to meet dependents'
continuing education needs through development of an education plan.
❖Taxes and Cash Flow - Understanding the impact of various investments on
current and future income tax liability.
❖Survivor and Beneficiary Planning - Cash needs at death, income needs of
surviving dependents, estate planning and income analysis.
❖Estate - Reviewing estate-planning documents, including wills and trusts to
determine whether you should seek the assistance of an estate-planning
attorney.Reviewing powers of attorney, nursing home and assisted living
agreements, living trusts, and Medicare/Medicaid benefits.
❖Retirement - Analysis of current strategies and investment plans to help
achieve retirement goals.
❖Investments - Analysis of investment alternatives including risk and return
analysis and their effect on your investment portfolio(s). Assessment of your
risk tolerance profile.
❖Real Estate - Analysis of real estate investment opportunities.
❖Insurance - Review of existing policies to ensure proper coverage for life,
health, disability, long-term care, liability, home and automobile.
❖Asset Protection - Look for opportunities to shield your wealth from the
attacks from creditors and lawsuits.
Preparing the Financial Life Plan
In the development of your financial life plan, we will follow the Financial Planning
Practice Standards process established by the Certified Financial Planner Board of
Standards, Inc. Your financial life plan will be prepared in four (4) phases. These phases
are defined as follows:
Phase 1:The Discovery Process
Positive Focus
Through discovery process, we learn about you and what you want to achieve. This is
accomplished through personal interviews and profile questionnaires6, which are
designed to address all of the financial life planning disciplines discussed above. You
will have the opportunity to prioritize your objectives and to remove from the process
any areas that are not applicable to your circumstances. The time we invest in the
discovery process to listen and cater to your desires is critical for developing a
strong financial life plan foundation. Such time helps to:
❖Define and narrow objectives and investment options;
❖Stimulate creative thinking;
❖Identify areas of greatest concern;
❖Cultivate peace of mind;
❖Create an accurate picture of your overall financial personality; and,
❖Provide an effective and efficient way for us to address your unique financial
needs and objectives.
After the interview process, we will prepare an agenda and conduct a meeting with you
to begin formally documenting your goals and objectives. From this meeting, we will
draft a report documenting the financial life planning process disciplines that you wish
to address, detailing the specific objectives under each discipline.Redrafting and
meetings can be repeated until you are completely satisfied.Depending upon the
engagement, different levels of financial reporting will be undertaken.
Phase2:StrategicOptions
Architecture
We define financial life planning as a road map (a series of blueprints) designed to take
you from where you currently are financially, to where you want to be at some point in
the future. This is the creative portion of the process. There are usually several ways
to accomplish a given goal.The objective, however, is to integrate financial
instruments into a plan that you will be comfortable executing. In some cases, the
drafting of the plan reveals the need for us to help you reconcile the gap between your
expectations and your financial realities. Once a viable plan has been drafted, it is
presented to you and reviewed. The draft and review process may be repeated until
you are satisfied with the financial life plan.
Phase3:StrategicIntegration
Construction
A financial life plan is of limited value if it is not put into action.Accordingly, we
assist you with implementing?and monitoring the plan. The implementation schedule
provides you with a list of tasks and deadlines designed to ensure that you put your
plan into action. The following are some examples of implementation:
❖Drafting of appropriate estate documents (performed by estate attorney).
❖Purchase of various insurance policies (provided by our licensed insurance
agents or another independent agent of your choice).
❖Investment advisory services, including preparation of an Investment Policy
Statement ("IPS") and implementing your asset allocation strategy
6The profile questionnaire we use is an important tool in gathering information about your investment methodology, risk tolerance, income/tax bracket,
liquidity, time horizons, etc. If you elect not to answer the questionnaire or choose to respond with limited input, it is possible that we could operate in a
handicapped capacity contrary to your investment needs.Therefore, if you desire the most effective and accurate recommendations regarding your
managed account(s), you should make every effort to provide us with your detailed personal needs and objectives, along with detailed financial and tax
information.
7Implementing the recommendations made in a financial life plan often requires consultation or coordination with one or more outside professionals (e.g.
attorneys, CPAs, insurance agents, and securities representatives).All personal and private information received from you will be kept entirely
confidential, not only by us, but by the outside professionals as well. Your confidential information will be disclosed to third parties only with your consent
or as may be permitted or required by law.
(performed by us, or another investment adviser/broker-dealer of your
choice).
❖Adopting and monitoring of a personal budget.
❖Ongoing income tax planning (prepared by an independent Certified Public
Accountant or tax accountant of your choice).
Phase 4:Strategic Completion Management
Once the plan has been built and the recommendations have been implemented it is
critical that these recommendations be monitored on a continuing basis to ensure that
they remain consistent with your investment parameters.This process requires
periodic rebalancing of the portfolio to ensure your original objectives are maintained.
Continued monitoring of established personal budgets and the continued effects
of
taxation on the plan are assessed regularly at your option per the Annual Review.
Information about our planning fees can be found under "Financial Life Planning Fee" below
in Item 5, "Fees & Compensation".
Business and Corporate Planning
Business and corporate planning is forward thinking; projecting thought into the future to
plan for tomorrow's needs and stay one step ahead of the competition.It involves
formulating and implementing decisions about the company's present and future direction
in accordance with the company's goals as set out in a strategic plan or other such
document.
Business and Corporate Planning Composition
Business and Corporate Planning is a blueprint for present/future policy and resource
decisions. It guides day-to-day organizational choices, provides a measurement tool to
evaluate progress; assists with managing the "big picture", and guides with preserving a
positive cash flow. We work with your management team in the following areas:
❖Define Goals - Discover and help prioritize short and long-term planning goals
and aspirations with the business.
❖Plan for Performance - Identify business life cycle transitions that you are
experiencing and expect to be experiencing.
❖Business Risk Management - Analyze your current insurance documents in
comparison to business continuation and risk retention goals.
❖Employee Benefits - Assist in determining the optimal employee benefit
package to maximize employee performance and retention.
❖Develop a Key-Man Policy - Implement a Key-Man reward and retention plan to
reward key executives and to retain employees.
❖Business Owner and Employee Retirement Planning - Analyze or develop
pension plans to assure that you meet the fiduciary responsibilities to plan
participants.
❖Business Transition and Exit Planning - Provide plan development and
implementation tools for your transition to retirement.
❖Design a Business Financial Plan - Provide written recommendations and
alternatives to help you achieve stated business financial and employee goals.
❖Offer Pension Consulting Services - Help to implement financial decisions and
to coordinate the necessary financial product providers.
Preparing the Business and Corporate Plan
Wegather the necessary information to complete our analysis through personal
interviews and review of various documents you supplied.Information gathered may
include statements regarding your current financial status, a list of assets, insurance,
wills and/or trust documents, income and expenses, Social Security eligibility, and other
informationsbased on your financial status and future goals.
Information about our business planning fees can be found under "Business and Corporate
Planning Fee" below in Item 5, "Fees & Compensation".
FEES & COMPENSATION
Portfolio Management Fee
Portfolio management is provided on an asset-based fee9arrangement. Management fees are
calculated based on the aggregate market value of your account on the last business day of the
previous calendar quarter multiplied by one-fourth (i.e., 1.25% ÷ 4 = 0.3125%) of the
corresponding annual percentage rate for each portion of your portfolio assets that fall within
each tier (see "Billing" below under "Protocols for Portfolio Management" for more information
on how the fee is calculated).
We retain discretion to negotiate the management fee within each tier on a client-by-client
basis depending on the size, complexity, and nature of the portfolio managed. In addition, as
your portfolio value exceeds each tier level, either through additional deposits or asset growth,
a fee break will occur for that portion of your portfolio that falls within that tier level. The
tier breaks are as follows:
Account Value
Annual
Fee
Rate
Not to
Exceed
First $250,000 .................................................1.25%
Next $250,000 .................................................1.10%
Next $500,000 .................................................1.00%
Next $1,000,000 ..............................................0.75%
Over $2,000,000 ..............................................0.50%
We generally require a minimum initial investment of $100,000 to open a managed account;
however, we retain the right to waive or reduce this minimum if we feel circumstances are
warranted.
Protocols for Portfolio Management
The following protocols establish how we handle our portfolio management accounts and
what you should expect when it comes to: (i) managing your account; (ii) your bill for
investment services; (iii) deposits and withdrawing funds from your account(s); and (iv) other
fees charged to your account(s).
8All information provided by and to you will be kept entirely confidential. Such information will be disclosed to third parties only with mutual written
consent or as may be permitted by law.
9An asset-based fee is a percentage fee charged based on your assets under management for our professional time giving continuous advice, managing
investment strategies, and suggesting investment options. We receive no other compensation for this advisory service unless first disclosed to you.
Discretion
We will establish discretionary trading authority on all management accounts to execute
securities transactions at any time without your prior consent or advice.
At any time however, you may impose restrictions, in writing, on our discretionary
authority (i.e., limit the types/amounts of particular securities purchased for your account,
exclude the ability to purchase securities with an inverse relationship to the market, limit
our use of leverage, etc.).
Billing
Your account will be billed a blended fee quarterly in advance based on the aggregate, fair
market value for the portion of your portfolio that fall within each tier of our fee schedule.
For example:
Account Value:
$2,500,000
Annual Fee
%
(Per Tier)
Tier Fee
Contribution
(Based on the Account Value WithinEach Tier)
First $250,0001.25%0.125%
Next $250,0001.10%0.110%
Next $500,0001.00%0.200%
Next $1,000,0000.75%0.300%
Next $500,0000.50%0.100%
Blended Annual Fee %0.835%
For new managed accounts opened in mid-quarter, our fee will be based on a pro-rated
calculation of your assets to be managed for the current calendar quarter. For existing
management accounts, pro-rated adjustments may be made for partial deposits between
billing cycles.We do not make partial refunds of our quarterly fee for withdraws you
make during a calendar quarter.
Advisory fees will be deducted first from any money market funds or cash balances. If such
assets are insufficient to satisfy payment of such fees, a portion of the account assets will
be liquidated to cover the fees.
Fee Exclusions
The above fees for all of our management services are exclusive of any charges imposed by
the custodial firm who has custody of your account; including, but not limited to: (i) any
Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account charges, such as,
postage/handling fees, electronic fund and wire transfer fees, auction fees, debit
balances, margin interest, certain odd-lot differentials and mutual fund short-term
redemption fees; and (iv) brokerage and execution costs associated with securities held in
your managed account.There can also be other fees charged to your account that are
unaffiliated with our management services.
In addition, all fees paid to us for portfolio management services are separate from any
fees and expenses charged on mutual fund shares by the investment company or by the
investment advisor managing the mutual fund portfolios. These expenses generally include
management fees and various fund expense, such as redemption fees, account fees, and
purchase fees, which may occur, but are the exception within managed accounts at
institutional custodians. A complete explanation of these expenses charged by the mutual
funds is contained in each mutual fund's prospectus. You are encouraged to carefully read
the fund prospectus.
For more information on the custodial firm that we will recommend to custody your
portfolio accounts, see Item 12, "Brokerage Practices".
Termination of Portfolio Management Services
To terminate our portfolio management services, either party (you or us) by written
notification to the other party, may terminate the Investment Advisory Agreement at any
time, provided such written notification is received at least 30 days prior to the date of
termination (i.e.; To terminate services on October 1st, a request for termination should be
received in our office by September 1st.).Such notification should include the date the
termination will go into effect along with any final instructions on the account (i.e., liquidate
the account, finalize all transactions and/or cease all investment activity).
In the event termination does not fall on the last day of a calendar quarter, you shall be
entitled to a pro-rated refund of the prepaid quarterly management fee based upon the
number of days remaining in the quarter after the termination notice goes into effect. Once
the termination of investment advisory services has been implemented, neither party has
any obligation to the other - we no longer earn management fees or give investment advice
and you become responsible for making your own investment decisions.
Portfolio Monitoring Fee
Under the arrangements with the Portfolio Managers, we are not involved in the day-to-day
management of your portfolio assets. Our responsibility to the Portfolio Manager(s) will be to
ensure you meet their minimum qualifications. Once your account has been established we will
provide all administrative and clerical duties as may be required to service your account. The
Portfolio Manager(s) may have little or no direct contact with you.
Our responsibility to you will be to: (i) continuously evaluate the performance of your
portfolio to ensure the Portfolio Manager selected adheres to your asset allocation guidelines;
and, (ii) make recommendations regarding the Portfolio Manager as market factors and your
personal goals dictate.
Portfolio Managers Fee Structure
The Portfolio Managers who will be used to manage your account(s) will disclose the fees for
management services in their Disclosure Brochures (the Portfolio Manager's ADV Part 2A: Firm
Brochure or Part 2A Appendix 1: Wrap Fee Program Brochure), which we will provide you
prior to, or at the same time as, opening an account. The total fees to be charged to your
account will include:
1.The Portfolio Manager's management fee;
2.Our portfolio monitoring fee (not to exceed 1.25%) that the Portfolio Manager will
pay us from the total management fee they collect; and,
3.Trading commissions and/or account charges, depending on if the Portfolio
Manager is "wrapping" all the fees, which may be imposed by the custodian or
broker/dealer used to custody your account(s).
The Portfolio Manager's Disclosure Brochure contains all pertinent disclosures relating to
their management services, fee structure for such services, and termination provisions - you
are encouraged to carefully review these disclosures.
Protocols for Portfolio Monitoring
You will want to consult the Portfolio Manager's Disclosure Brochure for their policies on how
they will handle your account; such as, billing, deposits and withdrawals, fee exclusions,
termination, and any other unique advisory costs associated with their service since we do
not take discretion over the management of your account and we do not handle any of the
billing. We will discuss these arrangements with you when we go to open your account with a
Portfolio Manager; however, you are also encouraged to read their terms for
management on your own.
Financial Life Planning Fee
How we charge to develop a financial life plan depends on the size, complexity, and nature of
your personal and financial situation and the amount of time it will take to analyze and
summarize the plan and perform the services you desire.
Financial life planning services are offered at an hourly rate not to exceed $250 an hour. We
do not provide "fixed fee" engagements. We will give you an estimated cost at the outset of
the engagement; however, financial planning is a consulting process, and by its very nature, the
time incurred will vary.Life planning fees may be reduced, or waived, if we also are
monitoring your portfolio account.
For the initial consultation, the fee will be due at the end of the session. Thereafter we will
bill you at the agreed upon hourly rate, in a monthly billing statement itemizing all time and
expenses.
Financial Planning Termination
You can terminate financial planning services at any.We will bill you for any services
rendered from the date of the last bill up to the date of termination at the fee rate that was
agreed to in the proposal, engagement letter and/or retainer agreement.
Business and Corporate Planning Fee
Business and corporate planning services are offered at an hourly rate not to exceed $250 an
hour. We will give you an estimated cost at the outset of the engagement; however, business
planning is a consulting process, and by its very nature, the time incurred will vary.
For the initial consultation, the fee will be due at the end of the session. Thereafter we will
bill you at the agreed upon hourly rate, in a monthly billing statement itemizing all time and
expenses.
Termination of the Business and Corporate Planning Agreement
You can terminate business and corporate planning services at any time. We will bill you for
any services rendered from the date of the last bill up to the date of termination at the fee
rate that was agreed to in the proposal, engagement letter and/or retainer agreement
PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
We do not charge fees based on a share of capital gains or the capital appreciation of the assets
held in your accounts.