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Beacon Bridge Wealth Partners
Disclosure Brochure
BEACON BRIDGE WEALTH PARTNERS, LLC
FORM ADV PART 2A BROCHURE
Item 1 – Cover Page
1600 N. Bethlehem Pike, N200
Lower Gwynedd, PA 19002
(484) 533-6600
www.beaconbridgewealth.com
January 20, 2026
This brochure provides information about the qualifications and business practices of Beacon Bridge
Wealth Partners, LLC. If you have any questions regarding the contents of this brochure, please do not
hesitate to contact our Chief Compliance Officer, Michelle McCarthy, by telephone at (513) 832-5447 or
by email at michelle.mccarthy@dinsmorecomplianceservices.com. The information in this brochure has
not been approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Beacon Bridge Wealth Partners, LLC is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of skill
or training. Additional information about Beacon Bridge Wealth Partners, LLC (CRD 321705) is available
on the SEC’s website at http://www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Form ADV Part 2A requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser’s disclosure brochure, the
adviser is required to notify you and provide you with a description of the material changes.
The last annual update of our Firm Brochure occurred on February 13, 2025.
As part of this annual update, this Brochure was revised to reflect the following material changes:
No material changes made
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Item 3 - Table of Contents
Item 1 – Cover Page ............................................................................................................................... 1
Item 3 - Table of Contents ...................................................................................................................... 3
Item 4 - Advisory Business .................................................................................................................... 5
A. Description of the Advisory Firm ................................................................................................. 5
B. Types of Advisory Services .......................................................................................................... 5
C. Client-Tailored Advisory Services ................................................................................................ 6
D.
Information Received From Clients .............................................................................................. 7
E. Assets Under Management ........................................................................................................... 7
Item 5 - Fees and Compensation ............................................................................................................ 8
A. Financial Planning and Investment Management Services ........................................................... 8
B. Payment of Fees ............................................................................................................................ 9
C. Clients Responsible for Fees Charged by Financial Institutions and External Money Managers 9
D. Prepayment of Fees ..................................................................................................................... 10
E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients ....... 10
Item 6 - Performance-Based Fees and Side-by-Side Management ...................................................... 10
Item 7 - Types of Clients ...................................................................................................................... 10
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss .............................................. 10
A. Methods of Analysis and Risk of Loss ....................................................................................... 10
B. Material Risks Involved .............................................................................................................. 11
Item 9 – Disciplinary Information ........................................................................................................ 15
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 15
Item 11 – Code of Ethics, Participation or Interest in Client Transactions .......................................... 16
A. Description of Code of Ethics ..................................................................................................... 16
Item 12 – Brokerage Practices .............................................................................................................. 17
A. Factors Used to Select Custodians and/or Broker-Dealers ......................................................... 17
B. Trade Aggregation ...................................................................................................................... 20
Item 13 – Review of Accounts ............................................................................................................. 20
A. Periodic Reviews ........................................................................................................................ 20
B. Other Reviews and Triggering Factors ....................................................................................... 20
C. Regular Reports........................................................................................................................... 20
Item 14 – Client Referrals and Other Compensation ........................................................................... 21
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients ......................... 21
B. Compensation to Non-Supervised Persons for Client Referrals ................................................. 21
Item 15 – Custody ................................................................................................................................ 21
Item 16 – Investment Discretion .......................................................................................................... 22
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Item 17 – Voting Client Securities ....................................................................................................... 22
Item 18 – Financial Information ........................................................................................................... 22
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Item 4 - Advisory Business
A. Description of the Advisory Firm
Beacon Bridge Wealth Partners, LLC (“Beacon Bridge” or the “Firm”) is a limited liability company
organized in the State of Pennsylvania. Beacon Bridge is an investment advisory firm registered with the
United States Securities and Exchange Commission (“SEC”). Beacon Bridge is owned by Steven
Krzywicki, Jr., Megan Scott and James Schmidt.
B. Types of Advisory Services
Beacon Bridge provides personalized financial planning and discretionary and non-discretionary
investment advisory services to individuals, including high net worth individuals, and entities, including,
but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans.
Investment Management Services
Beacon Bridge offers investment management services on a discretionary basis and non-discretionary basis.
All investment advice provided is customized to each client’s investment objectives and financial needs.
The information provided by the client, together with any other information relating to the client’s overall
financial circumstances, will be used by Beacon Bridge to determine the appropriate portfolio asset
allocation and investment strategy for the client. Financial planning services also are provided, depending
on the needs of the client.
The securities utilized by Beacon Bridge for investment in client accounts mainly consist of exchange
traded funds (ETFs), but we will also invest in registered mutual funds, equity securities, corporate bonds,
REITS, private funds/alternative investments and variable annuities, among others, if we determine such
investments fit within a client’s objectives and are in the best interest of our clients.
Beacon Bridge may further recommend to clients that all or a portion of their investment portfolio be
managed on a discretionary basis by one or more unaffiliated money managers or investment platforms
(“External Managers”). The client may be required to enter into a separate agreement with the External
Manager(s), which will set forth the terms and conditions of the client’s engagement of the External
Manager. Beacon Bridge generally renders services to the client relative to the discretionary selection of
External Managers. Beacon Bridge also assists in establishing the client’s investment objectives for the
assets managed by External Managers, monitors and reviews the account performance and defines any
restrictions on the account. The investment management fees charged by the designated External Managers,
together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s
assets, are exclusive of, and in addition to, the annual advisory fee charged by Beacon Bridge.
Investment Management Services to Retirement Plans
Beacon Bridge offers discretionary and non-discretionary advisory services to qualified plans, including
401k plans. These services include, depending upon the needs of the plan client, recommending, or for
discretionary clients selecting, investment options for plans to offer to participants, ongoing monitoring of
a plan’s investment options, assisting plan fiduciaries in creating and/or updating the plan’s written
investment policy statements, working with plan service providers, and providing general investment
education to plan participants.
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Asset Management Services through Pontera
When appropriate, we use a third-party platform to facilitate the discretionary management of held away
assets. This includes the utilization of Pontera’s order management system to implement asset allocation
and rebalancing strategies on behalf of the client. Accounts primarily include defined contribution plan
participant accounts, 401(k) accounts and other accounts as defined under ERISA..The platform allows us
to avoid deemed custody of client funds as defined by the Securities and Exchange Commission as we do
not have direct access to client log-in credentials to effect trades. Beacon Bridge is not affiliated with the
platform and we receive no compensation from Pontera for using their platform. A link will be provided to
the client allowing them to connect their account(s) to the platform. Once a client account(s) is connected
to the platform, Beacon Bridge will review the current asset allocations. When deemed necessary, Beacon
Bridge will rebalance the account considering client investment goals and risk tolerances. The securities
utilized by Beacon Bridge for investment in these particular client accounts are limited to the available
account options, over which Beacon Bridge has no control. Client account(s) will be reviewed at least
quarterly, and allocation changes will be made as deemed appropriate.
Finanical Planing and Consulting Services
Beacon Bridge offers personal comprehensive financial planning services to set forth goals, objectives and
implementation strategies for the client over the long-term. Depending upon individual client requirements,
the comprehensive financial plan will include recommendations for retirement planning, educational
planning, estate planning, cash flow planning, tax planning and insurance needs and analysis. Beacon
Bridge prepares and provides the financial planning client with a written comprehensive financial plan and
performs quarterly, semi-annual or annual reviews of the plan with the client, dependent on the client’s
needs in accordance with the financial planning agreement. Clients should notify us promptly anytime there
is a change in their financial situation, goals, objectives, or needs and/or if there is any change to the
financial information initially provided to us.
Clients are under no obligation to implement any of the recommendations provided in their written financial
plan. However, should a client decide to proceed with the implementation of the investment
recommendations then the client can either have Beacon Bridge implement those recommendations or
utilize the services of any investment adviser or broker-dealer of their choice.
Beacon Bridge cannot provide any guarantees or promises that a client’s financial goals and objectives
will be met.
Note for IRA and Retirement Plan Clients: When Beacon Bridge provides investment advice to you
regarding your retirement plan account or individual retirement account, Beacon Bridge is a fiduciary
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 Beacon Bridge makes money
creates some conflicts with your interests, so Beacon Bridge operates under a special rule that requires
Beacon Bridge to act in your best interest and not put Beacon Bridge’s interest ahead of yours.
C. Client-Tailored Advisory Services
Clients may impose reasonable restrictions on the management of their accounts if Beacon Bridge
determines, in its sole discretion, that the conditions would not materially impact the performance of a
management strategy or prove overly burdensome for Beacon Bridge’s management efforts.
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D. Information Received From Clients
Beacon Bridge will not assume any responsibility for the accuracy or the information provided by clients.
Beacon Bridge is not obligated to verify any information received from a client or other professionals (e.g.,
attorney, accountant) designated by a client, and Beacon Bridge is expressly authorized by the client to rely
on such information provided. Under all circumstances, clients are responsible for promptly notifying
Beacon Bridge in writing of any material changes to the client’s financial situation, investment objectives,
time horizon, or risk tolerance.
E. Assets Under Management
As of December 31, 2025 our firm manages approximately $426,622,164 in clients assets with
$421,775,524 managed on a discretionary basis and $4,846,640 managed on a non-discretionary basis.
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Item 5 - Fees and Compensation
Beacon Bridge charges fees based on a percentage of assets under management as well as fixed fees,
depending on the particular types of services to be provided. The specific fees charged by Beacon Bridge
for services provided will be set forth in each client’s Agreement.
A. Financial Planning and Investment Management Services
Fees for Financial Planning and Consulting Services
Clients that are receiving financial planning services only are charged a one time fixed fee ranging from
$2,000 to $24,000, depending on the complexity of a client’s plan and services provided. The fee for
financial planning services will be billed in accordance with the agreement with the client, and may be
billed in periodic installments until final delivery of the financial plan or otherwise fully payable upon
delivery of the financial plan. Actual fees charged are clearly outlined in the financial planning agreement
and clients receive invoices reflecting the amount of the fee due and payable. Please refer to “Additional
Information Regarding Fees” below for more detailed information regarding fees paid by Beacon Bridge
clients.
Fees for Investment Management Services
Beacon Bridge charges an annual advisory fee that is agreed upon with each client and set forth in an
agreement executed by Beacon Bridge and the client. If fixed, the advisory fee will be specified on the fee
schedule as set forth in the agreement executed by Beacon Bridge and the client. If based on a percentage
of the value of assets under management, the advisory fee for the initial month shall be paid, on a pro rata
basis, in arrears, based on the value of the net billable assets under management at the end of such initial
month. For subsequent months, the advisory fee shall be paid, in advance, based on the asset value of the
client’s accounts as of the last business day of the preceding month as provided by third-party sources, such
as pricing services, custodians, fund administrators, and client-provided sources.
Following is Beacon Bridge’s asset based fee schedule for Investment Management Services:
FEE SCHEDULE
Market Value of Assets
Max Rate
1.35%
1.25%
1.00%
0.85%
0.70%
negotiable
Up to $499,999
$500,000 to $999,999
$1,000,000 to $4,999,999
$5,000,000 to $9,999,999
$10,000,000 to $19,999,999
$20,000,000 and above
The percentage for the highest range of Managed Asset
value achieved applies to all Managed Assets, not just
Managed Assets within that range.
Notwithstanding the foregoing, Beacon Bridge and the client may choose to negotiate an annual advisory
fee that varies from the ranges and schedules set forth above. Factors upon which a different annual
advisory fee may be based include, but are not limited to, the size and nature of the relationship, the services
rendered, the nature and complexity of the products and investments involved, time commitments, and
travel requirements. The advisory fee charged by the Firm will apply to all of the client’s assets under
management, unless specifically excluded in the client agreement. The advisory fee may include the
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financial planning services described above. Although Beacon Bridge believes that its fees are competitive,
clients should understand that lower fees for comparable services may be available from other sources and
firms.
The investment advisory agreement between Beacon Bridge and the client may be terminated at will by
either Beacon Bridge or the client upon written notice. Beacon Bridge does not impose termination fees
when the client terminates the investment advisory relationship, except when agreed upon in advance.
B. Payment of Fees
Beacon Bridge generally deducts its advisory fee from a client’s investment account(s) held at his/her
custodian. Upon engaging Beacon Bridge to manage such account(s), a client grants Beacon Bridge this
limited authority through a written instruction to the custodian of his/her account(s). The client is
responsible for verifying the accuracy of the calculation of the advisory fee; the custodian will not determine
whether the fee is accurate or properly calculated. See Section A herewith for further information on fee
billing. A client may utilize the same procedure for financial planning or consulting fees if the client has
investment accounts held at a custodian.
Although clients generally are required to have their investment advisory fees deducted from their accounts,
in some cases, Beacon Bridge will directly bill a client for investment advisory fees if it determines that
such billing arrangement is appropriate given the circumstances.
The custodian of the client’s accounts provides each client with a statement, at least quarterly, indicating
separate line items for all amounts disbursed from the client's account(s), including any fees paid directly
to Beacon Bridge.
Clients may make additions to and withdrawals from their account at any time, subject to Beacon Bridge’s
right to terminate an account. Additions may be in cash or securities provided that the Firm reserves the
right to liquidate transferred securities or decline to accept particular securities into a client’s account.
Clients may withdraw account assets at any time on notice to Beacon Bridge, subject to the usual and
customary securities settlement procedures. However, the Firm generally designs its portfolios as long-term
investments and the withdrawal of assets may impair the achievement of a client’s investment objectives.
Beacon Bridge may consult with its clients about the options and implications of transferring securities.
Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees,
short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges)
and/or tax ramifications.
C. Clients Responsible for Fees Charged by Financial Institutions and External Money
Managers
In connection with Beacon Bridge’s management of an account, a client will incur fees and/or expenses
separate from and in addition to Beacon Bridge’s advisory fee. These additional fees may include
transaction charges and the fees/expenses charged by any custodian, subadvisor, mutual fund, ETF, separate
account manager (and the manager’s platform manager, if any), limited partnership, or other advisor,
transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges,
taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees
(where applicable), margin interest, brokerage commissions, mark-ups or mark-downs and other
transaction-related costs, electronic fund and wire fees, and any other fees that reasonably may be borne by
a brokerage account. For External Managers, clients should review each manager’s Form ADV 2A
disclosure brochure and any contract they sign with the External Manager (in a dual contract relationship).
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The client is responsible for all such fees and expenses. Please see Item 12 of this brochure regarding
brokerage practices.
D. Prepayment of Fees
As noted in Item 5(B) above, Beacon Bridge’s advisory fees generally are paid in advance. Upon the
termination of a client’s advisory relationship, Beacon Bridge will issue a refund equal to any unearned
management fee for the remainder of the month. The client may specify how he/she would like such refund
issued (i.e., a check sent directly to the client or a check sent to the client’s custodian for deposit into his/her
account).
E. Outside Compensation for the Sale of Securities or Other Investment Products to Clients
Beacon Bridge does not buy or sell securities and does not receive any compensation for securities
transactions in any client account, other than the investment advisory fees noted above. However, as further
described in Item 10, certain personnel of Beacon Bridge, in their individual capacities, are registered
representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”). In this capacity these individuals will
engage in various types of securities or investment products transactions and will receive separate and
typical compensation for doing so. In addition, representatives of Beacon Bridge, in their individual
capacities, are also are licensed as insurance professionals. Such persons earn commission-based
compensation for selling insurance products to clients.
Item 6 - Performance-Based Fees and Side-by-Side Management
Beacon Bridge does not charge performance-based fees or participate in side-by-side management.
Performance-based fees are fees that are based on a share of a capital gains or capital appreciation of a
client’s account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-based
fees. Beacon Bridge’s fees are calculated as described in Item 5 above.
Item 7 - Types of Clients
Beacon Bridge offers investment advisory services to individuals, including high net worth individuals,
families, family offices, trusts, businesses, charitable foundations, and retirement/profit-sharing plans.
Beacon Bridge does not impose a minimum portfolio size or a minimum initial investment to open an
account. However, Beacon Bridge does reserve the right to accept or decline a potential client for any
reason in its sole discretion.
Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss
A. Methods of Analysis and Risk of Loss
A primary step in Beacon Bridge’s investment strategy is getting to know the clients – to understand their
financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a
complete picture of their financial situation. To aid in this understanding, Beacon Bridge offers clients
financial planning that is highly customized and tailored. This comprehensive approach is integral to the
way that Beacon Bridge does business. Once Beacon Bridge has a true understanding of its clients’ needs
and goals, the investment process can begin, and the Firm can recommend strategies and investments that
it believes are aligned with the client’s goals and risk profile.
Beacon Bridge primarily employs fundamental analysis methods in developing investment strategies for its
clients. Research and analysis from Beacon Bridge is based on numerous sources, including third-party
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research materials and publicly-available materials, such as company annual reports, prospectuses, and
press releases.
Beacon Bridge generally employs a long-term investment strategy for its clients, as consistent with their
financial goals. At times, the Firm may also buy and sell positions that are more short-term in nature,
depending on the goals of the client and/or the fundamentals of the security, sector or asset class.
Client portfolios with similar investment objectives and asset allocation goals may own different securities
and investments. The client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term
wealth transfer objectives, time horizon and choice of custodian are all factors that influence Beacon
Bridge’s investment recommendations.
Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her
investment. A client should be willing to bear such a loss. Some investments are intended only for
sophisticated investors and can involve a high degree of risk.
B. Material Risks Involved
Investing in securities involves a significant risk of loss which clients should be prepared to bear. Beacon
Bridge’s investment recommendations are subject to various market, currency, economic, political and
business risks, and such investment decisions will not always be profitable. Clients should be aware that
there may be a loss or depreciation to the value of the client’s account. There can be no assurance that the
client’s investment objectives will be obtained and no inference to the contrary should be made.
Generally, the market value of equity stocks will fluctuate with market conditions, and small- stock prices
generally will fluctuate more than large-stock prices. The market value of fixed income securities will
generally fluctuate inversely with interest rates and other market conditions prior to maturity. Fixed income
securities are obligations of the issuer to make payments of principal and/or interest on future dates, and
include, among other securities: bonds, notes and debentures issued by corporations; debt securities issued
or guaranteed by the U.S. government or one of its agencies or instrumentalities, or by a non-U.S.
government or one of its agencies or instrumentalities; municipal securities; and mortgage-backed and
asset- backed securities. These securities may pay fixed, variable, or floating rates of interest, and may
include zero coupon obligations and inflation-linked fixed income securities. The value of longer duration
fixed income securities will generally fluctuate more than shorter duration fixed income securities.
Investments in overseas markets also pose special risks, including currency fluctuation and political risks,
and it may be more volatile than that of a U.S. only investment. Such risks are generally intensified for
investments in emerging markets. In addition, there is no assurance that a mutual fund or ETF will achieve
its investment objective. Past performance of investments is no guarantee of future results.
Additional risks involved in the securities recommended by Beacon Bridge include, among others:
• Stock market risk, which is the chance that stock prices overall will decline. The market value of
equity securities will generally fluctuate with market conditions. Stock markets tend to move in
cycles, with periods of rising prices and periods of falling prices. Prices of equity securities tend
to fluctuate over the short term as a result of factors affecting the individual companies, industries
or the securities market as a whole. Equity securities generally have greater price volatility than
fixed income securities.
• Sector risk, which is the chance that significant problems will affect a particular sector, or that
returns from that sector will trail returns from the overall stock market. Daily fluctuations in
specific market sectors are often more extreme than fluctuations in the overall market.
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•
Issuer risk, which is the risk that the value of a security will decline for reasons directly related to
the issuer, such as management performance, financial leverage, and reduced demand for the
issuer's goods or services.
• Non-diversification risk, which is the risk of focusing investments in a small number of issuers,
industries or foreign currencies, including being more susceptible to risks associated with a single
economic, political or regulatory occurrence than a more diversified portfolio might be.
• Value investing risk, which is the risk that value stocks not increase in price, not issue the
anticipated stock dividends, or decline in price, either because the market fails to recognize the
stock’s intrinsic value, or because the expected value was misgauged. If the market does not
recognize that the securities are undervalued, the prices of those securities might not appreciate as
anticipated. They also may decline in price even though in theory they are already undervalued.
Value stocks are typically less volatile than growth stocks, but may lag behind growth stocks in an
up market.
• Smaller company risk, which is the risk that the value of securities issued by a smaller company
will go up or down, sometimes rapidly and unpredictably as compared to more widely held
securities. Investments in smaller companies are subject to greater levels of credit, market and
issuer risk.
•
• Foreign (non-U.S.) investment risk, which is the risk that investing in foreign securities result in
the portfolio experiencing more rapid and extreme changes in value than a portfolio that invests
exclusively in securities of U.S. companies. Risks associated with investing in foreign securities
include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value
of a security, the possibility of substantial price volatility as a result of political and economic
instability in the foreign country, less public information about issuers of securities, different
securities regulation, different accounting, auditing and financial reporting standards and less
liquidity than in the U.S. markets.
Interest rate risk, which is the chance that prices of fixed income securities decline because of rising
interest rates. Similarly, the income from fixed income securities may decline because of falling
interest rates.
• Credit risk, which is the chance that an issuer of a fixed income security will fail to pay interest
and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such
payments will cause the price of that fixed income security to decline.
• Exchange Traded Fund (ETF) risk, which is the risk of an investment in an ETF, including the
possible loss of principal. ETFs typically trade on a securities exchange and the prices of their
shares fluctuate throughout the day based on supply and demand, which may not correlate to their
net asset values. Although ETF shares will be listed on an exchange, there can be no guarantee that
an active trading market will develop or continue. Owning an ETF generally reflects the risks of
owning the underlying securities it is designed to track. ETFs are also subject to secondary market
trading risks. In addition, an ETF may not replicate exactly the performance of the index it seeks
to track for a number of reasons, including transaction costs incurred by the ETF, the temporary
unavailability of certain securities in the secondary market, or discrepancies between the ETF and
the index with respect to weighting of securities or number of securities held.
• Management risk, which is the risk that the investment techniques and risk analyses applied by
Beacon Bridge may not produce the desired results and that legislative, regulatory, or tax
developments, affect the investment techniques available to Beacon Bridge. There is no guarantee
that a client’s investment objectives will be achieved.
• Real Estate risk, which is the risk that an investor’s investments in Real Estate Investment Trusts
(“REITs”) or real estate-linked derivative instruments will subject the investor to risks similar to
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•
those associated with direct ownership of real estate, including losses from casualty or
condemnation, and changes in local and general economic conditions, supply and demand, interest
rates, zoning laws, regulatory limitations on rents, property taxes and operating expenses. An
investment in REITs or real estate-linked derivative instruments subject the investor to
management and tax risks.
Investment Companies (“Mutual Funds”) risk, when an investor invests in mutual funds, the
investor will bear additional expenses based on his/her pro rata share of the mutual fund’s
operating expenses, including the management fees. The risk of owning a mutual fund generally
reflects the risks of owning the underlying investments the mutual fund holds.
• Commodity risk, generally commodity prices fluctuate for many reasons, including changes in
market and economic conditions or political circumstances (especially of key energy-producing
and consuming countries), the impact of weather on demand, levels of domestic production and
imported commodities, energy conservation, domestic and foreign governmental regulation
(agricultural, trade, fiscal, monetary and exchange control), international politics, policies of
OPEC, taxation and the availability of local, intrastate and interstate transportation systems and
the emotions of the marketplace. The risk of loss in trading commodities can be substantial.
• Cybersecurity risk, which is the risk related to unauthorized access to the systems and networks of
Beacon Bridge and its service providers. The computer systems, networks and devices used by
Beacon Bridge and service providers to us and our clients to carry out routine business operations
employ a variety of protections designed to prevent damage or interruption from computer viruses,
network failures, computer and telecommunication failures, infiltration by unauthorized persons
and security breaches. Despite the various protections utilized, systems, networks or devices
potentially can be breached. A client could be negatively impacted as a result of a cybersecurity
breach. Cybersecurity breaches can include unauthorized access to systems, networks or devices;
infection from computer viruses or other malicious software code; and attacks that shut down,
disable, slow or otherwise disrupt operations, business processes or website access or functionality.
Cybersecurity breaches cause disruptions and impact business operations, potentially resulting in
financial losses to a client; impediments to trading; the inability by us and other service providers
to transact business; violations of applicable privacy and other laws; regulatory fines, penalties,
reputational damage, reimbursement or other compensation costs, or other compliance costs; as
well as the inadvertent release of confidential information. Similar adverse consequences could
result from cybersecurity breaches affecting issues of securities in which a client invests;
governmental and other regulatory authorities; exchange and other financial market operators,
banks, brokers, dealers and other financial institutions; and other parties. In addition, substantial
costs may be incurred by those entities in order to prevent any cybersecurity breaches in the future.
• Alternative Investments / Private Funds risk, investing in alternative investments is speculative,
not suitable for all clients, and intended for experienced and sophisticated investors who are
willing to bear the high economic risks of the investment, which can include:
•
•
•
•
•
•
loss of all or a substantial portion of the investment due to leveraging, short-selling or other
speculative investment practices;
lack of liquidity in that there may be no secondary market for the investment and none
expected to develop;
volatility of returns;
restrictions on transferring interests in the investment;
potential lack of diversification and resulting higher risk due to concentration of trading
authority when a single adviser is utilized;
absence of information regarding valuations and pricing;
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•
•
•
delays in tax reporting;
less regulation and higher fees than mutual funds;
risks associated with the operations, personnel, and processes of the manager of the funds
investing in alternative investments.
• Closed-End Funds risk, Closed-end funds typically use a high degree of leverage. They may be
diversified or non-diversified. Risks associated with closed-end fund investments include
liquidity risk, credit risk, volatility and the risk of magnified losses resulting from the use of
leverage. Additionally, closed-end funds may trade below their net asset value.
• Structured Notes risk -
• Complexity. Structured notes are complex financial instruments. Clients should understand
the reference asset(s) or index(es) and determine how the note’s payoff structure incorporates
such reference asset(s) or index(es) in calculating the note’s performance. This payoff
calculation may include leverage multiplied on the performance of the reference asset or index,
protection from losses should the reference asset or index produce negative returns, and fees.
Structured notes may have complicated payoff structures that can make it difficult for clients
to accurately assess their value, risk and potential for growth through the term of the structured
note. Determining the performance of each note can be complex and this calculation can vary
significantly from note to note depending on the structure. Notes can be structured in a wide
variety of ways. Payoff structures can be leveraged, inverse, or inverse-leveraged, which may
result in larger returns or losses. Clients should carefully read the prospectus for a structured
note to fully understand how the payoff on a note will be calculated and discuss these issues
with Beacon Bridge.
•
• Market risk. Some structured notes provide for the repayment of principal at maturity, which
is often referred to as “principal protection.” This principal protection is subject to the credit
risk of the issuing financial institution. Many structured notes do not offer this feature. For
structured notes that do not offer principal protection, the performance of the linked asset or
index may cause clients to lose some, or all, of their principal. Depending on the nature of the
linked asset or index, the market risk of the structured note may include changes in equity or
commodity prices, changes in interest rates or foreign exchange rates, and/or market volatility.
Issuance price and note value. The price of a structured note at issuance will likely be higher
than the fair value of the structured note on the date of issuance. Issuers now generally disclose
an estimated value of the structured note on the cover page of the offering prospectus, allowing
investors to gauge the difference between the issuer’s estimated value of the note and the
issuance price. The estimated value of the notes is likely lower than the issuance price of the
note to investors because issuers include the costs for selling, structuring and/or hedging the
exposure on the note in the initial price of their notes. After issuance, structured notes may not
be re-sold on a daily basis and thus may be difficult to value given their complexity.
• Liquidity. The ability to trade or sell structured notes in a secondary market is often very
limited, as structured notes (other than exchange-traded notes known as ETNs) are not listed
for trading on securities exchanges. As a result, the only potential buyer for a structured note
may be the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor
of the structured note. In addition, issuers often specifically disclaim their intention to
repurchase or make markets in the notes they issue. Clients should, therefore, be prepared to
hold a structured note to its maturity date, or risk selling the note at a discount to its value at
the time of sale.
• Credit risk. Structured notes are unsecured debt obligations of the issuer, meaning that the
issuer is obligated to make payments on the notes as promised. These promises, including any
principal protection, are only as good as the financial health of the structured note issuer. If
the structured note issuer defaults on these obligations, investors may lose some, or all, of the
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principal amount they invested in the structured notes as well as any other payments that may
be due on the structured notes.
There also are risks surrounding various insurance products that are recommended to Beacon Bridge clients
from time to time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any
insurance product, clients should carefully read the policy and applicable disclosure documents.
Clients are advised that they should only commit assets for management that can be invested for the long
term, that volatility from investing can occur, and that all investing is subject to risk. Beacon Bridge does
not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of
loss that clients should be prepared to bear.
Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss.
Use of External Managers
Beacon Bridge may select certain External Managers to manage a portion of its clients’ assets. In these
situations, the success of such recommendations relies to a great extent on the External Managers’ ability to
successfully implement their investment strategies. In addition, Beacon Bridge generally may not have the
ability to supervise the External Managers on a day-to-day basis.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary
events that would be material to a client’s evaluation of the adviser and the integrity of the adviser’s
management. Beacon Bridge has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
As mentioned above in Item 5, certain representatives of Beacon Bridge are also registered
representatives with PKS. PKS is a registered broker-dealer and member of FINRA. In this capacity,
such representatives of Beacon Bridge offer securities or alternative investments and receive normal
and customary fees or commissions as a result of these transactions. In addition, these individuals
receive additional ongoing 12b-1 fees for mutual fund purchases from the mutual fund company during the
period that the client maintains the mutual fund investment. As a result of this relationship, PKS has access
to certain confidential information (e.g., financial information, investment objectives, transactions and
holdings) about clients, even if a client does not establish an account through PKS. If you would like a
copy of the PKS privacy policy, please contact Beacon Bridge as described on the cover page of this
brochure.
Clients should be aware that the receipt of additional compensation itself creates an inherent conflict of
interest, and may affect the judgment of these individuals when making recommendations. Beacon Bridge
and PKS are separate, nonaffiliated entities. Nevertheless, to the extent that a Beacon Bridge representative
recommends the purchase of securities or other investment products where the representative receives
commissions for doing so, a conflict of interest exists because the representative is incentivized to make
recommendations based on the compensation received rather than on a client’s needs. Beacon Bridge has
adopted certain procedures designed to mitigate the effects of this conflict. As part of Beacon Bridges’s
fiduciary duty to clients, Beacon Bridge and its representatives endeavor at all times to put the interests of
clients first, and recommendations will only be made to the extent that they are reasonably believed to be
in the best interests of clients. Additionally, the conflicts presented by this relationship are disclosed to
clients through this brochure, client agreement and/or verbally prior to or at the time of entering into an
Agreement. Clients are not obligated to implement recommended transactions through any Beacon Bridge
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representative or any particular broker-dealer. Clients have the option to purchase any recommended
investment through broker-dealers other than PKS.
Beacon Bridge clients should understand that lower fees and/or commissions for comparable services may
be available from other broker-dealers.
Advisory persons of Beacon Bridge are licensed as insurance professionals. Such persons earn
commission-based compensation for selling insurance products to clients. Insurance commissions earned
by advisory persons who are insurance professionals are separate from and in addition to Beacon Bridge’s
advisory fee. In addition, Beacon Bridge has an arrangement with RetireOne, an unaffiliated retirement
solutions firm offering fee based insurance and annuity products as a recommendation to certain Beacon
Bridge clients. . Beacon Bridge can offer advisory services to the client for these products. No Beacon
Bridge personnel will accept any referral fee or commission from RetireOne on any of these products These
practices present a conflict of interest as an advisory person who is an insurance professional has an
incentive to recommend insurance products or otherwise make a referral for the sale of insurance products
for the purpose of generating commissions rather than solely based on client needs. Beacon Bridge
addresses this conflict through disclosure and strives to make recommendations or referrals which are in
the best interests of its clients. Clients are under no obligation to purchase insurance products through any
person affiliated with Beacon Bridge, RetireOne, or any other person or entity recommended by Beacon
Bridge. Beacon Bridge clients should understand that lower fees and/or commissions for comparable
services may be available from other insurance providers.
Recommendation of External Managers
Beacon Bridge may recommend that clients use External Managers based on clients’ needs and suitability.
Beacon Bridge does not receive separate compensation, directly or indirectly, from such External Managers
for recommending that clients use their services. Beacon Bridge does not have any other business
relationships with the recommended External Managers.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions
A. Description of Code of Ethics
Beacon Bridge has a Code of Ethics (the “Code”) which requires Beacon Bridge’s employees (“supervised
persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients.
Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest,
outside business activities, gifts and entertainment, compliance with insider trading laws and policies and
procedures governing personal securities trading by supervised persons.
Personal securities transactions of supervised persons present potential conflicts of interest with the price
obtained in client securities transactions or the investment opportunity available to clients. The Code
addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a
client and requiring, with certain exceptions, supervised persons to report their personal securities holdings
and transactions to Beacon Bridge for review by the Firm’s Chief Compliance Officer. The Code also
requires supervised persons to obtain pre-approval of certain investments, including initial public offerings
and limited offerings.
Beacon Bridge will provide a copy of the Code of Ethics to any client or prospective client upon request.
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Item 12 – Brokerage Practices
A. Factors Used to Select Custodians and/or Broker-Dealers
Beacon Bridge generally recommends that its investment management clients utilize the custody and
brokerage services of an unaffiliated broker/dealer custodians (a “BD/Custodian”) with which Beacon
Bridge has an institutional relationship. Currently, this includes Charles Schwab and Co., Inc (“Schwab”),
a FINRA-registered broker-dealer, member SIPC, which is a “qualified custodian” as that term is described
in Rule 206(4)-2 of the Advisers Act. Each BD/Custodian provides custody of securities, trade execution,
and clearance and settlement of transactions placed on behalf of clients by Beacon Bridge. If your accounts
are custodied at Schwab, Schwab will hold your assets in a brokerage account and buy and sell securities
when we instruct them to. Clients will pay fees to Schwab for custody and the execution of securities
transactions in their accounts.
In making BD/Custodian recommendations, Beacon Bridge will consider a number of judgmental factors,
including, without limitation: 1) clearance and settlement capabilities; 2) quality of confirmations and
account statements; 3) the ability of the BD/Custodian to settle the trade promptly and accurately; 4) the
financial standing, reputation and integrity of the BD/Custodian; 5) the BD/Custodian’s access to markets,
research capabilities, market knowledge, and any “value added” characteristics; 6) Beacon Bridge’s past
experience with the BD/Custodian; and 7) Beacon Bridge’s past experience with similar trades.
Recognizing the value of these factors, clients may pay a brokerage commission in excess of that which
another broker might have charged for effecting the same transaction.
In exchange for using the services of Schwab, Beacon Bridge may receive, without cost, computer software
and related systems support that allows Beacon Bridge to monitor and service its clients’ accounts
maintained with Schwab. Schwab also makes available to the Firm products and services that benefit the
Firm but may not directly benefit the client or the client’s account. These products and services assist
Beacon Bridge in managing and administering client accounts. They include investment research, both
Schwab’s own and that of third parties. Beacon Bridge may use this research to service all or some
substantial number of client 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; and
•
assist with back-office functions, recordkeeping, and client reporting.
•
Schwab also offers other services intended to help us manage and further develop our business enterprise.
These services include:
educational conferences and events;
•
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technology, compliance, legal, and business consulting;
•
• publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants, and insurance providers.
•
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to the Firm. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Schwab may also provide the Firm with other benefits such as
occasional business entertainment of Firm personnel.
The benefits received by Beacon Bridge through its participation in the Schwab custodial platform do not
depend on the amount of brokerage transactions directed to Schwab. In addition, there is no corresponding
commitment made by Beacon Bridge to Schwab to invest any specific amount or percentage of client assets
in any specific mutual funds, securities or other investment products as a result of participation in the
program. While as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation that
clients maintain their assets in accounts at Schwab will be based in part on the benefit to Beacon Bridge of
the availability of some of the foregoing products and services and not solely on the nature, cost or quality
of custody and brokerage services provided by Schwab. The receipt of these benefits creates a potential
conflict of interest and may indirectly influence Beacon Bridge’s choice of Schwab for custody and
brokerage services.
Beacon Bridge will periodically review its arrangements with the BD/Custodians and other broker-dealers
against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of
its clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full range of a broker-
dealer’s services, including, but not limited to, the following:
•
a broker-dealer’s trading expertise, including its ability to complete trades, execute and
settle difficult trades, obtain liquidity to minimize market impact and accommodate
unusual market conditions, maintain anonymity, and account for its trade errors and correct
them in a satisfactory manner;
•
a broker-dealer’s infrastructure, including order-entry systems, adequate lines of
communication, timely order execution reports, an efficient and accurate clearance and
settlement process, and capacity to accommodate unusual trading volume;
•
a broker-dealer’s ability to minimize total trading costs while maintaining its financial
health, such as whether a broker-dealer can maintain and commit adequate capital when
necessary to complete trades, respond during volatile market periods, and minimize the
number of incomplete trades;
•
a broker-dealer’s ability to provide research and execution services, including advice as to
the value or advisability of investing in or selling securities, analyses and reports
concerning such matters as companies, industries, economic trends and political factors, or
services incidental to executing securities trades, including clearance, settlement and
custody; and
•
a broker-dealer’s ability to provide services to accommodate special transaction needs,
such as the broker-dealer’s ability to execute and account for client-directed arrangements
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and soft dollar arrangements, participate in underwriting syndicates, and obtain initial
public offering shares.
Beacon Bridge’s clients may utilize qualified custodians other than Schwab for certain accounts and assets,
particularly where clients have a previous relationship with such qualified custodians.
Brokerage for Client Referrals
Beacon Bridge does not select or recommend BD/Custodians based solely on whether or not it may receive
client referrals from a BD/Custodian or third party.
Client-Directed Brokerage
Generally, in the absence of specific instructions to the contrary, for brokerage accounts that clients engage
Beacon Bridge to manage on a discretionary basis, Beacon Bridge has full discretion with respect to
securities transactions placed in the accounts. This discretion includes the authority, without prior notice to
the client, to buy and sell securities for the client’s account and establish and affect securities transactions
through the BD/Custodian of the client’s account or other broker-dealers selected by Beacon Bridge. In
selecting a broker-dealer to execute a client’s securities transactions, Beacon Bridge seeks prompt execution
of orders at favorable prices.
A client, however, may instruct Beacon Bridge to custody his/her account at a specific broker-dealer and/or
direct some or all of his/her brokerage transactions to a specific broker-dealer. In directing brokerage
transactions, a client should consider whether the commission expenses, execution, clearance, settlement
capabilities, and custodian fees, if any, are comparable to those that would result if Beacon Bridge exercised
its discretion in selecting the broker-dealer to execute the transactions. Directing brokerage to a particular
broker-dealer may involve the following disadvantages to a directed brokerage client:
• Beacon Bridge’s ability to negotiate commission rates and other terms on behalf of such clients
could be impaired;
•
such clients could be denied the benefit of Beacon Bridge’s experience in selecting broker-dealers
that are able to efficiently execute difficult trades;
• opportunities to obtain lower transaction costs and better prices by aggregating (batching) the
client’s orders with orders for other clients could be limited; and
•
the client could receive less favorable prices on securities transactions because Beacon Bridge may
place transaction orders for directed brokerage clients after placing batched transaction orders for
other clients.
In addition to accounts managed by Beacon Bridge on a discretionary basis where the client has directed
the brokerage of his/her account(s), certain institutional accounts may be managed by Beacon Bridge on a
non-discretionary basis and are held at custodians selected by the institutional client. The decision to use a
particular custodian and/or broker-dealer generally resides with the institutional client. Beacon Bridge
endeavors to understand the trading and execution capabilities of any such custodian and/or broker-dealer,
as well as its costs and fees. Beacon Bridge may assist the institutional client in facilitating trading and
other instructions to the custodian and/or broker-dealer in carrying out Beacon Bridge’s investment
recommendations.
Trade Errors
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Beacon Bridge’s goal is to execute trades seamlessly and in the best interests of the client. In the event a
trade error occurs, Beacon Bridge endeavors to identify the error in a timely manner, correct the error so
that the client’s account is in the position it would have been had the error not occurred, and, after evaluating
the error, assess what action(s) might be necessary to prevent a recurrence of similar errors in the future.
Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab,
or another BD, as the case may be. In the event an error is made in a client account custodied elsewhere,
Beacon Bridge works directly with the broker in question to take corrective action. In all cases, Beacon
Bridge will take the appropriate measures to return the client’s account to its intended position.
B. Trade Aggregation
To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities,
including securities in which the Firm’s supervised persons may invest, the Firm will generally do so in a
fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance
provided by the staff of the SEC and consistent with policies and procedures established by the Firm.
Item 13 – Review of Accounts
A. Periodic Reviews
Financial Planning and Consulting Services Account Reviews
Upon completion of the initial financial plan, ongoing annual review services are established, if provided
for in the client agreement. Generally, we meet with our clients on an annual basis; however, more frequent
reviews are not uncommon. The nature of the annual review is to evaluate the client’s progress from the
previous year based on their goals and objectives. Beacon Bridge will collaborate with the client to update
their financial information (i.e. insurance, investments, assets, income and expenses) and craft their yearly
financial planning reports. Financial planning reports are written and may consist of a net worth statement,
cash flow statement, estimated tax projections, education analysis, retirement analysis, insurance needs
analysis, estate tax calculation, and an investment analysis. Reviews are conducted by an advisor of Beacon
Bridge who is appropriately licensed to provide financial planning services.
Investment Management Account Reviews
While investment management accounts are monitored on an ongoing basis, Beacon Bridge’s investment
adviser representatives seek to have at least one annual meeting with each client to conduct a formal review
of the clients’ accounts. Accounts are reviewed for consistency with the investment strategy and other
parameters set forth for the account and to determine if any adjustments need to be made.
B. Other Reviews and Triggering Factors
In addition to the periodic reviews described above, reviews may be triggered by changes in an account
holder’s personal, tax or financial status. Other events that may trigger a review of an account are material
changes in market conditions as well as macroeconomic and company- specific events. Clients are
encouraged to notify Beacon Bridge of any changes in his/her personal financial situation that might affect
his/her investment needs, objectives, or time horizon.
C. Regular Reports
Written brokerage statements are generated no less than quarterly and are sent directly from the qualified
custodian. These reports list the account positions, activity in the account over the covered period, and other
related information. Clients are also sent confirmations following each brokerage account transaction unless
confirmations have been waived.
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Beacon Bridge may also determine to provide account statements and other reporting to clients on a periodic
basis. Beacon Bridge also provides account reports during client meetings.
Clients are urged to carefully review all custodial account statements and compare them to any statements
and reports provided by Beacon Bridge. Beacon Bridge statements and reports may vary from custodial
statements based on accounting procedures, reporting dates, or valuation methodologies of certain
securities.
Item 14 – Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients
Beacon Bridge does not receive benefits from third parties for providing investment advice to clients.
B. Compensation to Non-Supervised Persons for Client Referrals
Beacon Bridge seeks to enter into agreements with individuals and organizations, some of whom may be
affiliated or unaffiliated with Beacon Bridge for the referral of clients to us. All such agreements will be in
writing and comply with the applicable state and federal regulations. If a client is introduced to Beacon
Bridge by a solicitor, Beacon Bridge will pay that solicitor a fee in accordance with the applicable federal
and state securities law requirements. While the specific terms of each agreement may differ, generally, the
compensation will be based upon Beacon Bridge’s engagement of new clients and the retention of those
clients and would be calculated using a varying percentage of the fees paid to Beacon Bridge by such clients
until the account is closed by written authorization from the client. Any such fee shall be paid solely from
Beacon Bridge’s fees, and shall not result in any additional charge to the client.
Each prospective client who is referred to Beacon Bridge under such an arrangement will receive a copy of
this Brochure and a separate written disclosure document disclosing the nature of the relationship between
the third party solicitor and Beacon Bridge and the compensation that will be paid by us to the third party.
The solicitor is required to obtain the client’s signature acknowledging receipt of this Brochure and the
solicitor’s written disclosure statement. In any case, applicable state laws may require these persons to
become licensed either as representatives of Beacon Bridge or as an independent investment adviser.
Beacon Bridge will request that our clients acknowledge this arrangement prior to acceptance of the clients’
account.
Item 15 – Custody
All clients must utilize a “qualified custodian” as detailed in Item 12. Clients are required to engage the
custodian to retain their funds and securities and direct Beacon Bridge to utilize the custodian for the client’s
securities transactions. Beacon Bridge’s agreement with clients and/or the clients’ separate agreements with
the B/D Custodian may authorize Beacon Bridge through such BD/Custodian to debit the clients’ accounts
for the amount of Beacon Bridge’s fee and to directly remit that fee to Beacon Bridge in accordance with
applicable custody rules.
Beacon Bridge is also deemed to have constructive custody over those client accounts where it is able to
deduct fees directly from the account. Additionally, certain clients have signed, and can in the future, sign
a Standing Letter of Authorization (SLOA) that gives the firm the authority to transfer funds to a third‐
party as directed by the client in the SLOA. In these cases, the Firm has constructive custody of those
assets. Firms with custody must take the following steps: 1. Ensure clients’ managed assets are maintained
by a qualified custodian; 2. Have a reasonable belief, after due inquiry, that the qualified custodian will
deliver an account statement directly to the client at least quarterly; 3. Confirm that account statements from
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the custodian contain all transactions that took place in the client’s account during the period covered and
reflect the deduction of advisory fees; and 4. Obtain a surprise audit by an independent accountant on the
clients’ accounts for which the advisory firm is deemed to have custody. However, the rules governing the
direct debit of client fees and SLOAs exempts the Firm from the surprise audit rules if certain conditions
(in addition to steps 1 through 3 above) are met. Those conditions are as follows: 1. When debiting fees
from client accounts, the firm must receive written authorization from clients permitting advisory fees to
be deducted from the client’s account. 2. In the case of SLOAs, the Firm must: (i) confirm that the name
and address of the third party is included in the SLOA, (ii) document that the third‐party receiving the
transfer is not related to the firm, and (ii) ensure that certain requirements are being performed by the
qualified custodian.
The BD/Custodian recommended by Beacon Bridge has agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount of management fees paid
directly to Beacon Bridge. The Firm encourages clients to review the official statements provided by the
custodian, and to compare such statements with any reports or other statements received from Beacon
Bridge. For more information about custodians and brokerage practices, see “Item 12 - Brokerage
Practices.”
Item 16 – Investment Discretion
Clients have the option of providing Beacon Bridge with investment discretion on their behalf, pursuant to
a grant of a limited power of attorney contained in Beacon Bridge’s client agreement. By granting Beacon
Bridge investment discretion, a client authorizes Beacon Bridge to direct securities transactions and
determine which securities are bought and sold, the total amount to be bought and sold, and the costs at
which the transactions will be effected. Clients may impose reasonable limitations in the form of specific
constraints on any of these areas of discretion with the consent and written acknowledgement of Beacon
Bridge if Beacon Bridge determines, in its sole discretion, that the conditions would not materially impact
the performance of a management strategy or prove overly burdensome for Beacon Bridge. See also Item
4(C), Client-Tailored Advisory Services.
Item 17 – Voting Client Securities
Beacon Bridge does not accept the authority to and does not vote proxies on behalf of clients. Clients retain
the responsibility for receiving and voting proxies for all and any securities maintained in client portfolios.
Item 18 – Financial Information
Beacon Bridge is not required to disclose any financial information pursuant to this item due to the
following:
a) Beacon Bridge does not require or solicit the prepayment of more than $1,200 in fees six
months or more in advance of rendering services;
b) Beacon Bridge is unaware of any financial condition that is reasonably likely to impair its
ability to meet its contractual commitments relating to its discretionary authority over
certain client accounts; and
c) Beacon Bridge has never been the subject of a bankruptcy petition.
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