A. Firm Information
Cable Hill Partners, LLC (“Cable Hill Partners” or the “Adviser”) is a registered investment adviser with the U.S.
Securities and Exchange Commission (“SEC”). The Adviser is organized as a limited liability company (“LLC”)
under the laws of the State of Delaware. Cable Hill Partners was founded in February 2014 and is owned and
operated by David Christian (Founding Partner, Managing Director), and Brian Hefele (Founding Partner). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Cable Hill Partners. For information regarding this Disclosure Brochure, please contact
Jennifer Estner, Chief Compliance Officer, at (888) 313-0417 or by email at
[email protected].
B. Advisory Services Offered
Cable Hill Partners offers investment advisory services to individuals, high net worth individuals, trusts, estates,
charitable organizations, businesses and their retirement plans (each referred to as a “Client”). It is the Adviser’s
mission to help its Clients incorporate clear, effective and comprehensive strategies designed to not only
facilitate their finances, but their lives. In partnering with Clients, Cable Hill Partners first seeks to evaluate the
Client’s current, holistic financial situation. Cable Hill Partners believes that financial planning should be the
starting point for an advisory relationship.
The Adviser serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Adviser upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Cable Hill Partners’ fiduciary commitment is further described in the Adviser’s Code of Ethics.
For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest
in Client Transactions and Personal Trading.
Investment Management Services
Cable Hill Partners provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while primarily providing discretionary investment
management services. Cable Hill Partners works with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to develop an investment strategy and financial
plan. Cable Hill Partners will then construct a portfolio, consisting of diversified mutual funds and/or exchange-
traded funds (“ETFs”) to achieve the Client’s investment goals. The Adviser may also utilize individual stocks,
individual bonds, and other types of investments, as appropriate, to meet the needs of particular Clients. Where
appropriate, the Adviser may also provide advice regarding legacy portfolio positions or other investments held
by the Client.
Cable Hill Partners’ investment approach is primarily long-term focused, but the Adviser may buy, sell or re-
allocate positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Cable Hill Partners will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Adviser.
Cable Hill Partners evaluates and selects investments for inclusion in Client portfolios only after the Investment
Committee applies its internal due diligence process. Cable Hill Partners may recommend, on occasion,
redistributing investment allocations to diversify the portfolio. Cable Hill Partners may recommend specific
positions to increase sector or asset class weightings. The Adviser may recommend employing cash positions as
a possible hedge against market movement. Cable Hill Partners may recommend selling positions for reasons
that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a
specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in
risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s
risk tolerance.
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Cable Hill Partners will provide investment management services and related services. Cable Hill Partners
accepts custody of a Client’s funds or securities through the deduction of management fees from the Client’s
account[s] at the Custodian, and in certain situations where a Supervised Person of Cable Hill Partners may have
access to a Client’s held-away account login credentials.
Retirement Accounts – When the Adviser provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Adviser is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Adviser will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Adviser will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Adviser.
Use of Independent Managers
Cable Hill Partners may periodically recommend that a Client utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio. In such instances, the Client will then enter into an advisory agreement with the
Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide investment
management and related services. Cable Hill Partners may also assist in the development of the initial policy
recommendations and managing the ongoing Client relationship. Cable Hill Partners
will perform initial and
ongoing oversight and due diligence over the selected Independent Manager[s] as part of its ongoing investment
supervisory services. The Client, prior to entering into an agreement with unaffiliated money manager[s] or
investment adviser[s], will be provided with the Adviser's Form ADV 2A (or a brochure that makes the
appropriate disclosures).
Financial Planning Services
Cable Hill Partners will typically provide a variety of financial planning services to individuals and families,
pursuant to a written financial planning agreement or as a complement to the Adviser’s investment management
services. Services are offered in several areas of a Client’s financial situation, depending on their goals,
objectives and financial situation.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including, but not limited to investment planning, retirement planning, personal
savings, education savings, trust and estate planning, insurance planning, charitable giving, small business
planning and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. Cable Hill Partners may also
refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. For certain
financial planning engagements, the Adviser will provide a written summary of the Client’s financial situation,
observations, and recommendations. For consulting or ad-hoc engagements, the Adviser may not provide a
written summary. Plans or consultations are typically completed within six months of the contract date, assuming
all information and documents requested are provided promptly. Services may be provided on a stand-alone
basis or rendered in conjunction with investment management services.
Financial planning and consulting recommendations pose a potential conflict between the interests of the Adviser
and the interests of the Client. For example, the Adviser has an incentive to recommend that Clients engage the
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Adviser for investment management services, or to increase the level of investment assets with the Adviser, as it
would increase the advisory fees paid to the Adviser. Clients are not obligated to implement any
recommendations made by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects
to act on any of the recommendations made by the Adviser, the Client is under no obligation to implement the
transaction through the Adviser.
Retirement Plan Advisory Services
Cable Hill Partners provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”)
and to the company (the “Plan Sponsor”). The Adviser’s retirement plan advisory services are designed to assist
the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Cable Hill Partners
offers discretionary management services as 3(38) Fiduciary and non-discretionary advisory services as a 3(21)
Fiduciary, in support of the Plan Sponsor.
Cable Hill Partners provides the following Plan Fiduciary Services pursuant to the terms of the Adviser’s
agreement with each Plan Sponsor:
• Plan Design Assistance
• Vendor Analysis
• Plan Participant Enrollment
• Investment Policy Statement (“IPS”)
• Investment Oversight Services (ERISA 3(21))
• Investment Management Services (ERISA 3(38))
• Plan Effectiveness Monitoring
• ERISA 404(c) Assistance
• Benchmarking Services
Certain of these services are provided by Cable Hill Partners serving in the capacity as a fiduciary under the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section
408(b)(2), the Plan Sponsor is provided with a written description of Cable Hill Partners’ fiduciary status, the specific
services to be rendered and all direct and indirect compensation the Adviser reasonably expects under the
engagement.
Cable Hill Partners also provides the following non-advisory services to the Plan and the Plan Participants, pursuant
to the terms of the Adviser’s agreement with each Plan Sponsor:
• Investment Education
• Plan Sponsor Fiduciary Education
• Periodic on-site adviser visits with staff for account updates and reviews
• Periodic Plan Participant group education opportunities
C. Client Account Management
Prior to engaging Cable Hill Partners to provide investment advisory services, each Client is required to enter into
one or more agreements with the Adviser that define the terms, conditions, authority and responsibilities of the
Adviser and the Client. These services may include:
• Establishing an Investment Strategy – Cable Hill Partners, in connection with the Client, will develop a
strategy that seeks to achieve the goals of the Client.
• Asset Allocation – Cable Hill Partners will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Cable Hill Partners will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
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• Investment Management and Supervision – Cable Hill Partners will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Cable Hill Partners does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by the Adviser.
E. Assets Under Management
As of December 31, 2023, Cable Hill Partners manages approximately $1,665,876,483 in assets under
management, $1,357,542,638 of which is on a discretionary basis and $308,333,845 on a non-discretionary
basis. Clients may request more current information at any time by contacting the Adviser.