View Document Text
Bluesphere Advisors LLC
Form ADV Part 2A – Disclosure Brochure
Effective: November 18, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Bluesphere Advisors LLC (“Bluesphere” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at (610) 277-1515 or by email at info@bluesphereadvisors.com.
Bluesphere is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information to assist you in determining whether to retain the Advisor.
Additional information about Bluesphere and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 283972.
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 2 – Material Changes
Bluesphere believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Bluesphere encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material change has made to this Disclosure Brochure since the last annual amendment filing on
January 31, 2024:
• The Advisor has amended Item 5 to reflect that Ainvest Financial, Inc. has changed its name to Light
Horse Securities, Inc.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs in the business practices of Bluesphere.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 283972. You may also request a
copy of this Disclosure Brochure at any time, by contacting the Advisor at (610) 277-1515 or by email at
info@bluesphereadvisors.com.
2
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 3 – Table of Contents
Item 1 – Cover Page
1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 5
D. Wrap Fee Programs ....................................................................................................................................................... 5
E. Assets Under Management ............................................................................................................................................ 5
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 6
C. Other Fees and Expenses ............................................................................................................................................. 6
D. Advance Payment of Fees and Termination .................................................................................................................. 7
E. Compensation for Sales of Securities ............................................................................................................................ 7
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 8
A. Methods of Analysis ....................................................................................................................................................... 8
B. Risk of Loss .................................................................................................................................................................... 8
Item 9 – Disciplinary Information ......................................................................................................................... 9
Item 10 – Other Financial Industry Activities and Affiliations ........................................................................... 9
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 10
A. Code of Ethics .............................................................................................................................................................. 10
B. Personal Trading with Material Interest ........................................................................................................................ 10
C. Personal Trading in Same Securities as Clients .......................................................................................................... 10
D. Personal Trading at Same Time as Client ................................................................................................................... 10
Item 12 – Brokerage Practices ............................................................................................................................ 10
A. Recommendation of Custodian[s] ................................................................................................................................ 10
B. Aggregating and Allocating Trades .............................................................................................................................. 11
Item 13 – Review of Accounts ............................................................................................................................ 11
A. Frequency of Reviews .................................................................................................................................................. 11
B. Causes for Reviews ..................................................................................................................................................... 11
C. Review Reports ............................................................................................................................................................ 11
Item 14 – Client Referrals and Other Compensation ........................................................................................ 12
A. Compensation Received by Bluesphere ...................................................................................................................... 12
B. Client Referrals from Promoters ................................................................................................................................... 12
Item 15 – Custody ................................................................................................................................................ 12
Item 16 – Investment Discretion ......................................................................................................................... 12
Item 17 – Voting Client Securities ...................................................................................................................... 13
Item 18 – Financial Information .......................................................................................................................... 13
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 14
Privacy Policy ...................................................................................................................................................... 25
3
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 4 – Advisory Services
A. Firm Information
Bluesphere Advisors LLC (“Bluesphere” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”)
under the laws of the Commonwealth of Pennsylvania. Bluesphere was founded in May 2016 and is owned and
operated by Sanjay K. Pawar (President and Chief Executive Officer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and the advisory services provided by Bluesphere.
B. Advisory Services Offered
Bluesphere offers investment advisory services to individuals, high net worth individuals, institutions, trusts,
estates, pension and profit sharing plans, and charitable organizations. (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As such, each
recommendation made as part of the advisory services is based on the belief that the recommendation is in the
Client's best interest. Bluesphere’s fiduciary commitment to each Client is further described in the Advisor’s Code
of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation
or Interest in Client Transactions and Personal Trading.
Investment Management Services
Bluesphere provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services. Bluesphere works with each Client to identify their investment goals
and objectives as well as risk tolerance and financial situation in order to create a customized investment
strategy. Bluesphere will then construct an investment portfolio, consisting primarily of institutional mutual funds
and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize
individual stocks, individual bonds, and/or options, as appropriate, to meet the needs of its Clients. The Advisor
may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio
strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
Bluesphere’s investment approach is primarily long-term focused, but the Advisor 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. Bluesphere 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 Advisor.
Bluesphere evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Bluesphere may recommend, on occasion, redistributing investment allocations to diversify
the portfolio. Bluesphere may recommend specific positions to increase sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. Bluesphere
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 the Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Bluesphere accept or maintain custody of a Client’s funds or securities, except for limited authority
as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the investment advisory agreement. For additional information, please see Item 12 –
Brokerage Practices.
Retirement Plan Rollover Recommendations – When deemed to be in the Client’s best interest, the Advisor will
recommend that a Client roll over its retirement plan account into an account managed by the Advisor. In such
instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee
Retirement Income Security Act of 1974 (“ERISA”). Such a recommendation creates a conflict of interest as the
Advisor will earn a new (or increase its current) advisory fee as a result of the rollover. No client is under any
4
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
obligation to roll over retirement plan assets to an account managed by the Advisor.
Financial Planning Services
Bluesphere will typically provide a variety of financial planning services to individuals and families, pursuant to a
written financial planning agreement. Financial planning and consulting services, including business transition
services may also be included as a component of a Client’s investment management services in order to provide
a holistic service to certain Clients. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives.
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. Planning engagements may encompass one or
more areas of need, including, but not limited to investment planning, retirement planning, personal savings,
education savings, insurance needs and other areas of a Client’s financial situation. Financial consultation may
also encompass business transition services, such as business valuation, deal structure, transition support,
coordination of legal and accounting service providers. The Advisor also integrates a Client’s business transition
plan with a personal financial plan.
Bluesphere may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning recommendations pose a conflict between the interests of the Advisor and the interests of the
Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment
management services or to increase the level of investment assets with the Advisor, as it would increase the
amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor.
C. Client Account Management
Prior to engaging Bluesphere to provide investment advisory services, each Client is required to enter into one or
more agreements with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
● Establishing an Investment Strategy – Bluesphere, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
● Asset Allocation – Bluesphere 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 – Bluesphere will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
●
Investment Management and Supervision – Bluesphere will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Bluesphere does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Bluesphere.
E. Assets Under Management
As of December 31, 2024 Bluesphere manages approximately $445,136,606 in Client assets all of which are
managed on a discretionary basis. Clients may request more current information at any time by contacting the
Advisor.
5
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more agreements that details the responsibilities of Bluesphere and the
Client.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid either monthly or quarterly in arrears (the “billing period”), pursuant to the
terms of the investment advisory agreement. Investment advisory fees range from 0.50% to 1.75% annually,
depending on the size and complexity of the Client relationship. Relationships with multiple objectives, specific
reporting requirements, portfolio restrictions and other complexities may be charged a higher fee.
The investment advisory fee in the first billing period of service is prorated from the inception date of the
account[s] to the end of the first billing period. Fees may be negotiable at the sole discretion of the Advisor. The
Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities
held in accounts managed by Bluesphere will be independently valued by the Custodian. The Advisor will
conduct periodic reviews of the Custodian’s valuations to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However,
the Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
Bluesphere offers financial planning services either on an hourly basis, or for either a one time or ongoing annual
fixed fee. Hourly fees can range up to $300 per hour. Fixed fees range from $500 to $40,000. Fees may be
negotiable depending on the nature and complexity of each Client’s circumstances. An estimate for total hours
and costs will be provided to the Client prior to engaging Bluesphere for these services.
B. Fee Billing
Investment Management Services
Investment advisory fees will be calculated by the Advisor or its delegate and deducted from the Client’s
account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the
amount of the fees to be deducted from the Client’s account[s] for the billing period. The amount due is
calculated by applying the monthly or quarterly rate to the total assets under management with Bluesphere at the
end of the billing period. The Client acknowledges and agrees that if there is a shortfall in liquid cash or
equivalents in your Account[s], the Advisor will instruct the Custodian to liquidate the necessary positions in such
Account[s] to cover the amount of the fees under this agreement.
Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the
Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written
authorization permitting advisory fees to be deducted by Bluesphere to be paid directly from their accounts held
by the Custodian as part of the investment advisory agreement and separate account forms provided by the
Custodian.
Financial Planning Services
One-time Financial planning and consulting fees are invoiced by the Advisor upon completion of the agreed upon
deliverable[s]. Ongoing engagements are billed annually in arrears.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Bluesphere, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fees charged by the Custodian, if applicable. The Advisor's recommended custodian does not charge
securities transaction fees for ETF and equity trades provided that the Client’s accounts meet the terms and
conditions of the Custodian’s brokerage requirements. However, the Custodian typically charges for mutual funds
6
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
and other types of investments. The fees charged by Bluesphere are separate and distinct from these custody
and execution fees.
In addition, all fees paid to Bluesphere for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Bluesphere which are designed, among other things, to assist the Client in determining which products or
services are most appropriate for each Client’s financial situation and objectives. The Client may also incur other
costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees and
other fees. The Advisor does not control nor share in these fees. The Client should review both the fees charged
by the fund[s] and the fees charged by Bluesphere to fully understand the total fees to be paid.
D. Advance Payment of Fees and Termination
Investment Management Services
Bluesphere is compensated for its investment advisory services at the end of the billing period, after rendering its
services for the period. Either party may terminate the investment advisory agreement with Bluesphere, at any
time, by providing advance written notice to the other party. In addition, if the Client did not receive the Disclosure
Brochure at least 48 hours prior to entering into an agreement, the Client may also terminate the agreement
within five (5) business days of signing the Advisor’s investment advisory agreement at no cost to the Client.
After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of
termination. The Client shall be responsible for investment advisory fees up to and including the effective date of
termination. The investment advisory agreement is not transferrable without the Client’s prior consent.
Financial Planning Services
Bluesphere may be partially compensated for its financial planning services in advance. Either party may
terminate the planning agreement, at any time, by providing written notice to the other party. In addition, the
Client may terminate the agreement within five (5) business days of signing the Advisor’s financial planning
agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory
services rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Client shall be billed for actual hours logged on the planning project times the agreed upon
hourly rate or the percentage completed for a fixed fee engagement. Refunds will be given on a pro rata basis.
The financial planning agreement is not transferrable without the Client’s prior consent.
E. Compensation for Sales of Securities
Bluesphere 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.
James Harrington is also licensed as independent insurance professional. Mr. Harrington holds his insurance
license as it is necessary for his role as Professor of Risk Management and Insurance at Temple University. Mr.
Harrington does not make any engage in any sales of insurance products.
Adam Wang is also a registered representative of Light Horse Securities, Inc. (“Light Horse Securities”). Light
Horse Securities is a registered broker-dealer (CRD# 120242), member FINRA, SIPC. In Mr. Wang’s separate
capacity as a registered representative, Mr. Wang will implement securities transactions under Light Horse
Securities and not through Bluesphere. In such instances, Mr. Wang will receive commission-based
compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of
investment company products. Compensation earned by Mr. Wang in his capacity as a registered representative
is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because Mr. Wang
who is a registered representative has an incentive to effect securities transactions for the purpose of generating
commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation
provided by the Advisor nor Mr. Wang. Neither the Advisor nor Mr. Wang will earn ongoing investment advisory
fees in connection with any products or services implemented in Mr. Wang’s separate capacity as a registered
representative. Please see Item 10 – Other Financial Industry Activities and Affiliations.
7
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 6 – Performance-Based Fees and Side-By-Side Management
Bluesphere does not charge performance-based fees for its investment advisory services. The fees charged by
Bluesphere are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
Bluesphere does not manage any proprietary investment funds or limited partnerships (for example, a mutual
fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its
Clients.
Item 7 – Types of Clients
Bluesphere offers investment advisory services to individuals, high net worth individuals, institutions, trusts,
estates, pension and profit sharing plans, and charitable organizations. The amount of each type of client is
available on Bluesphere’s Form ADV Part 1A. Bluesphere generally does not impose a minimum size for
establishing a relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Bluesphere primarily employs fundamental and technical analysis methods in developing investment strategies
for its Clients. Research and analysis from Bluesphere are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria
are generally ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment
with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential
investment, it does not guarantee that the investment will increase in value. Assets meeting the investment
criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The
Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate.
More details on the Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, Bluesphere generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Bluesphere will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times,
Bluesphere 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.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Bluesphere will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
8
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
construction process. Bluesphere may use margin with Client accounts to manage the timing of purchases and
sales, as appropriate. Bluesphere may also employ options strategies to hedge or gain additional exposure.
Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The value of the ETFs
will fluctuate with the value of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large
bid-ask spread and low volume. Authorized participants in an ETF may change at any time; this may result in
change to the liquidity and the ability to redeem the ETF as the authorized participants control the number of
shares of the ETF. The value of an ETF fluctuates based upon the market movements and may disassociate
from the index being tracked or from the value of the underlying investments. An ETF purchased or sold at one
point in the day may have a different value than the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The value of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The value of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same value as a mutual fund purchased later that same day.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Bluesphere or its owner. Bluesphere values
the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on
any advisor or service provider that the Client engages. The backgrounds of the Advisor and Advisory Persons
are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
the Advisor’s firm name or CRD# 283972.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
As noted in Item 5, Mr. Harrington is also a licensed insurance professional. Mr. Harrington holds his insurance
license as it is necessary for his role as Professor of Risk Management and Insurance at Temple University. Mr.
Harrington does not engage in any sales of insurance products.
Broker-Dealer Affiliations
As noted in Item 5 Mr. Wang is also a registered representative of Light Horse Securities, Inc. (“Light Horse
Securities”). Light Horse Securities is a registered broker-dealer (CRD No. 120242), member FINRA, SIPC. In
his separate capacity as a registered representative, Mr. Wang will receive commissions for the implementation
of recommendations for commissionable transactions. Clients are not obligated to implement any
recommendation provided by Mr. Wang. Neither the Advisor nor Mr. Wang will earn ongoing investment advisory
fees in connection with any services implemented in Mr. Wang’s separate capacity as a registered
representative.
9
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Bluesphere has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Bluesphere (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Bluesphere and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client.
It is the obligation of Bluesphere associates to adhere not only to the specific provisions of the Code, but also to
the general principles that guide the Code. The Code covers a range of topics that address ethics and conflicts of
interest. To request a copy of the Code of Ethics, please contact the Advisor at (610) 277-1515 or by email at
info@bluesphereadvisors.com.
B. Personal Trading with Material Interest
Bluesphere allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Bluesphere does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. Bluesphere does not have a
material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Bluesphere allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted a Code, which addresses insider trading (material non-
public information controls) and personal securities reporting procedures. When trading for personal accounts,
Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the
best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client
trades, or by trading based on material non-public information. This risk is mitigated by Bluesphere requiring
reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer
(“CCO”). The Advisor has also adopted written policies and procedures to detect the misuse of material, non-
public information.
D. Personal Trading at Same Time as Client
While Bluesphere allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded
afterward. At no time will Bluesphere, or any Supervised Person of Bluesphere, transact in any security to
the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Bluesphere does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Bluesphere to direct trades to the Custodian as agreed upon in the investment advisory
agreement. Further, Bluesphere does not have the discretionary authority to negotiate commissions on behalf of
Clients on a trade-by-trade basis.
Where Bluesphere does not exercise discretion over the selection of the Custodian, the Advisor will typically
recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the
Custodian recommended by the Advisor and will not incur any extra fee or cost from the Advisor associated with
using a custodian not recommended by Bluesphere. However, the Advisor may be limited in the services it can
provide if the recommended Custodian is not utilized. Bluesphere may recommend the Custodian based on
criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made
available to the Client, its reputation, and/or the location of the Custodian’s offices.
Bluesphere will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified
10
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
custodian”. Bluesphere maintains an institutional relationship with Schwab, whereby the Advisor receives
economic benefits from Schwab (Please see Item 14 below.)
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with the broker-dealer/custodian in exchange for research and
other services. Bluesphere does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, Bluesphere does receive certain economic benefits from its relationship with
Schwab. Please see Item 14 below.
2. Brokerage Referrals - Bluesphere does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Bluesphere will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts
are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade
of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e.,
purchase of a security into one Client account from another Client’s account[s]). Bluesphere will not be obligated
to select competitive bids on securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Bluesphere will execute its transactions
through the Custodian as directed by the Client.
Bluesphere may aggregate orders in a block trade or trades when securities are purchased or sold through the
Custodian for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or
time, the securities actually purchased or sold by the close of each business day must be allocated in a manner
that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does
not consistently advantage or disadvantage particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the Advisory Person designated
to the Client’s account[s] as well as Mr. Pawar, the CCO of Bluesphere. Formal reviews are generally conducted
at least annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A. above, each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Bluesphere if changes occur
in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional
reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
11
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Bluesphere
Participation in Institutional Advisor Platform
Bluesphere has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit,
a division of Schwab dedicated to serving independent advisory firms like Bluesphere. As a registered
investment advisor participating on the Schwab Advisor Services platform, Bluesphere receives access to
software and related support without cost because the Advisor renders investment management services to
Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and
many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of
economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to Bluesphere that may not
benefit the Client, including: educational conferences and events, consulting services and discounts for various
service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab,
which results in a conflict of interest. Bluesphere believes, however, that the selection of Schwab as Custodian is
in the best interests of its Clients.
B. Client Referrals from Promoters
Bluesphere does not engage paid promoters for Client referrals.
Item 15 – Custody
Bluesphere does not accept or maintain custody of Client accounts, except for the limited circumstances outlined
below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom Bluesphere exercises discretionary authority must hold their assets with a
"qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and
securities and must instruct Bluesphere to utilize that Custodian for securities transactions on their behalf. Clients
are encouraged to review statements provided by the Custodian and compare to any reports provided by
Bluesphere to ensure accuracy, as the Custodian does not perform this review.
Money Movement Authorization - For instances where Clients authorize Bluesphere to move funds between their
accounts, Bluesphere and the Custodian have implemented safeguards to ensure that all money movement
activities are conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
Bluesphere generally has discretionary over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed
12
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
to by Bluesphere. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of
such authority will be evidenced by the Client's execution of an investment advisory agreement containing all
applicable limitations to such authority. All discretionary trades made by Bluesphere will be in accordance with
each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Bluesphere does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements
directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client
retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Bluesphere, nor its management, have any adverse financial situations that would reasonably impair the
ability of Bluesphere to meet all obligations to its Clients. Neither Bluesphere, nor any of its Advisory Persons,
have been subject to a bankruptcy or financial compromise. Bluesphere is not required to deliver a balance sheet
along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be
performed six months or more in advance.
13
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Form ADV Part 2B – Brochure Supplement
for
Sanjay K. Pawar, CFP®, CFA®
President, Chief Executive Officer, and Chief Compliance Officer
Effective: November 18, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Sanjay K. Pawar (CRD# 4747958) in addition to the information contained in the Bluesphere Advisors LLC
(“Bluesphere” or the “Advisor”) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure
or if you have any questions about the contents of the Bluesphere Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (610) 277-1515 or by email at info@bluesphereadvisors.com.
Additional information about Mr. Pawar is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4747958.
14
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 2 – Educational Background and Business Experience
Sanjay K. Pawar, born in 1973, is dedicated to advising Clients of Bluesphere in his role as the President, Chief
Executive Officer, and Chief Compliance Officer. Mr. Pawar attended the Institute of Cost Accountants of India
and graduated in 1996. Mr. Pawar also attended Institute of Chartered Accountants of India and graduated in
2003. Mr. Pawar earned his MBA in Finance from St. Joseph's University in 2005. Additional information
regarding Mr. Pawar’s employment history is included below.
Employment History:
06/2016 to Present
President, Chief Executive Officer, and Chief Compliance Officer, Bluesphere
Advisors LLC
President, Pawar Consulting LLC
09/2015 to 01/2016
Financial Advisor, Ameriprise Financial Services, Inc.
08/2005 to 06/2016
Adjunct Professor, Saint Joseph’s University
08/2005 to 05/2008
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® marks (collectively, the
“CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
obtained CFP® certification in the United States.
●
●
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to
real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
●
equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services
in the best interests of their clients.
15
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
Chartered Financial Analyst® (“CFA®”)
The Chartered Financial Analyst (“CFA”) charter is a professional designation established in 1962 and awarded
by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over
two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical
and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio
management and wealth planning. In addition, CFA charter holders must have at least four years of acceptable
professional experience in the investment decision-making process and must commit to abide by, and annually
reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. Chartered
Financial Analyst and CFA are trademarks owned by CFA Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Pawar. Mr. Pawar has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Pawar.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Pawar.
However, we do encourage you to independently view the background of Mr. Pawar on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4747958.
Item 4 – Other Business Activities
Mr. Pawar is dedicated to the investment advisory activities of Bluesphere Clients. Mr. Pawar does not
participate in any other business activities.
Item 5 – Additional Compensation
Mr. Pawar is dedicated to the investment advisory activities of Bluesphere Clients. Mr. Pawar does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Pawar serves as the President and Chief Executive Officer as well as the Chief Compliance Officer of
Bluesphere. Mr. Pawar can be reached at (610) 277-1515.
Bluesphere has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bluesphere. Further, Bluesphere is subject to regulatory
oversight by various agencies. These agencies require registration by Bluesphere and its Supervised Persons.
As a registered entity, Bluesphere is subject to examinations by regulators, which may be announced or
unannounced. Bluesphere is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
16
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Form ADV Part 2B – Brochure Supplement
for
David R. Ritrovato, CFP®
Financial Advisor
Effective: November 18, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
David R. Ritrovato (CRD# 2017743) in addition to the information contained in the Bluesphere Advisors LLC
(“Bluesphere” or the “Advisor”) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure
or if you have any questions about the contents of the Bluesphere Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (610) 277-1515 or by email at info@bluesphereadvisors.com.
Additional information about Mr. Ritrovato is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2017743.
17
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 2 – Educational Background and Business Experience
David R. Ritrovato, born in 1957, is dedicated to advising Clients of Bluesphere as a Financial Advisor. Mr.
Ritrovato earned his B.S. from Philadelphia University in 1979. Mr. Ritrovato then went on to earn his MBA from
Philadelphia University in 1985. Additional information regarding Mr. Ritrovato’s employment history is included
below.
Employment History:
Financial Advisor, Bluesphere Advisors LLC
06/2016 to Present
Financial Advisor, Ameriprise Financial Services, Inc.
08/2005 to 06/2016
01/1995 to 08/2005
Investment Advisor Representative, American Express Financial Advisors
(Company bought by Ameriprise Financial Services, Inc.)
08/1991 to 01/1995
Investment Advisor Representative, IDS Life Insurance Company
(Company bought by American Express Financial Advisors)
Investment Advisor Representative, ARA Services, Inc.
02/1986 to 01/1991
Certified Financial Planner ("CFP®")
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® marks (collectively, the
“CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners
to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high
standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients. Currently, more than 62,000 individuals have
obtained CFP® certification in the United States.
●
●
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s
financial planning subject areas include insurance planning and risk management, employee benefits
planning, investment planning, income tax planning, retirement planning, and estate planning;
Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered
in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s
ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to
real world circumstances;
● Experience – Complete at least three years of full-time financial planning-related experience (or the
●
equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements in
order to maintain the right to continue to use the CFP® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including two
hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional
Conduct. The Standards prominently require that CFP® professionals provide financial planning services
at a fiduciary standard of care. This means CFP® professionals must provide financial planning services
in the best interests of their clients.
18
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
CFP® professionals who fail to comply with the above standards and requirements may be subject
to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their
CFP® certification.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Ritrovato. Mr. Ritrovato has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Ritrovato.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Ritrovato.
However, we do encourage you to independently view the background of Mr. Ritrovato on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 2017743.
Item 4 – Other Business Activities
Mr. Ritrovato is dedicated to the investment advisory activities of Bluesphere’s Clients. Mr. Ritrovato does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Ritrovato is dedicated to the investment advisory activities of Bluesphere’s Clients. Mr. Ritrovato does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Ritrovato serves as a Financial Advisor with Bluesphere and is supervised by Sanjay Pawar, the Chief
Compliance Officer. Mr. Pawar can be reached at (610) 277-1515.
Bluesphere has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bluesphere. Further, Bluesphere is subject to regulatory
oversight by various agencies. These agencies require registration by Bluesphere and its Supervised Persons.
As a registered entity, Bluesphere is subject to examinations by regulators, which may be announced or
unannounced. Bluesphere is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
19
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Form ADV Part 2B – Brochure Supplement
for
James D. Harrington, CFA
Senior Investment Advisor
Effective: November 18, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
James D. Harrington (CRD# 4461935) in addition to the information contained in the Bluesphere Advisors LLC
(“Bluesphere” or the “Advisor”) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure
or if you have any questions about the contents of the Bluesphere Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (610) 277-1515 or by email at info@bluesphereadvisors.com.
Additional information about Mr. Harrington is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4461935.
20
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 2 – Educational Background and Business Experience
James D. Harrington, born in 1953, is dedicated to advising Clients of Bluesphere as a Senior Investment
Advisor. Mr. Harrington earned an MBA from the University of Georgia in 1982. Mr. Harrington also earned a
BBA from Pennsylvania State University in 1980. Additional information regarding Mr. Harrington’s employment
history is included below.
Employment History:
Senior Investment Advisor, Bluesphere Advisors LLC
Senior Advisor, StoneToro Wealth Management LLC
Advisory Representative, Bluestone Capital Management, LLC
Registered Representative, Dautrich Seiler Financial Services, Inc.
Investment Advisor Representative, Retirement Advisors, Inc.
Principal, West Chester Capital Advisors, Inc.
Senior Vice President, W.P. Stewart Asset Management Inc.
Chief Investment Officer, Brinker Capital Inc.
07/2018 to Present
01/2015 to 07/2018
01/2010 to 12/2014
02/2010 to 05/2012
05/2010 to 07/2010
01/2009 to 03/2010
09/2007 to 10/2009
11/2000 to 08/2007
Chartered Financial Analyst (“CFA®”)
The Chartered Financial Analyst (“CFA®”) charter is a professional designation established in 1962 and awarded
by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over
two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical
and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio
management and wealth planning. In addition, CFA® charterholders must have at least four years of acceptable
professional experience in the investment decision-making process and must commit to abide by, and annually
reaffirm, their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a
trademark owned by CFA® Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Harrington. Mr. Harrington has
never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Harrington.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Harrington.
However, we do encourage you to independently view the background of Mr. Harrington on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 4461935.
Item 4 – Other Business Activities
Mr. Harrington is dedicated to the investment advisory activities of Bluesphere’s Clients. Mr. Harrington does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Harrington is dedicated to the investment advisory activities of Bluesphere’s Clients. Mr. Harrington does not
receive any additional forms of compensation.
21
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 6 – Supervision
Mr. Harrington serves as a Senior Investment Advisor of Bluesphere and is supervised by Sanjay Pawar, the
Chief Compliance Officer. Sanjay Pawar can be reached at (610) 277-1515.
Bluesphere has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bluesphere. Further, Bluesphere is subject to regulatory
oversight by various agencies. These agencies require registration by Bluesphere and its Supervised Persons.
As a registered entity, Bluesphere is subject to examinations by regulators, which may be announced or
unannounced. Bluesphere is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
22
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Form ADV Part 2B – Brochure Supplement
for
Xing (Adam) N. Wang
Financial Advisor
Effective: November 18, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Adam N. Wang (CRD# 5326713) in addition to the information contained in the Bluesphere Advisors LLC
(“Bluesphere” or the “Advisor”, CRD# 283972) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Bluesphere Disclosure Brochure or
this Brochure Supplement, please contact the Advisor at (610) 277-1515 or by email at
info@bluesphereadvisors.com.
Additional information about Mr. Wang is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5326713.
23
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Item 2 – Educational Background and Business Experience
Adam N. Wang, born in 1980, is dedicated to advising Clients of Bluesphere as a Financial Advisor. Mr. Wang
earned an MBA in Finance from Saint Joseph's University in 2005. Mr. Wang also earned a BS - Mathematic and
Computer Science from Salem State University in 2003. Mr. Wang also earned a BS from Boston College.
Additional information regarding Mr. Wang’s employment history is included below.
Employment History:
Financial Advisor, Bluesphere Advisors LLC
CEO, Light Horse Securities, Inc.
President / CEO, Score Priority Corp
CEO, WhoTrades FX LLC
Asian Desk Manager, FOREX Direct Dealer
09/2020 to Present
08/2021 to Present
12/2015 to 08/2021
07/2011 to 12/2015
01/2009 to 07/2011
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Wang. Mr. Wang has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Wang.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Wang.
However, we do encourage you to independently view the background of Mr. Wang on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
5326713.
Item 4 – Other Business Activities
Broker-Dealer Affiliation
Mr. Wang is also a registered representative of Light Horse Securities, Inc. (“Light Horse Securities”). Light Horse
Securities is a registered broker-dealer (CRD# 120242), member FINRA, SIPC. In Mr. Wang’s separate capacity
as a registered representative, Mr. Wang will receive commissions for the implementation of recommendations
for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr.
Wang. Neither the Advisor nor Mr. Wang will earn ongoing investment advisory fees in connection with any
products or services implemented in Mr. Wang’s separate capacity as a registered representative. Mr. Wang
spends approximately 10% of his time per month in his role as a registered representative of Light Horse
Securities.
Item 5 – Additional Compensation
Mr. Wang has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Wang serves as a Financial Advisor of Bluesphere and is supervised by Sanjay Pawar, the Chief Compliance
Officer. Mr. Pawar can be reached at (610) 277-1515.
Bluesphere has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bluesphere. Further, Bluesphere is subject to regulatory
oversight by various agencies. These agencies require registration by Bluesphere and its Supervised Persons.
As a registered entity, Bluesphere is subject to examinations by regulators, which may be announced or
unannounced. Bluesphere is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
24
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
Privacy Policy
Effective: November 18, 2025
Our Commitment to You
Bluesphere Advisors LLC (“Bluesphere” or the “Advisor”) is committed to safeguarding the use of personal
information of our Client’s (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Bluesphere (also referred to as "we",
"our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Bluesphere does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
25
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes
Bluesphere does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Bluesphere or
the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
Bluesphere does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy, and will provide you with a revised Policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of the Advisor’s current Privacy Policy by
contacting the Advisor at (610) 277-1515.
26
Bluesphere Advisors LLC
2108 Dekalb Pike, East Norriton, PA 19401
Phone: (610) 277-1515 | http://www.bluesphereadvisors.com