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Cambient Family Office, LLC
Form ADV Part 2A – Appendix 1
(“Wrap Fee Program Brochure”)
Effective: December 26, 2025
This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the
qualifications and business practices for Cambient Family Office, LLC (“Cambient”) services when
offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be
accompanied by the Cambient Disclosure Brochure, which provides complete details on the business
practices of the Advisor. If you have any questions about the contents of this Wrap Fee Program
Brochure, please contact Cambient at (616) 330-2270 or by email at info@cambient.com.
Cambient is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”).
The information in this Wrap Fee Program 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 Wrap Fee Program Brochure provides information about Cambient to assist you in
determining whether to retain the Advisor.
Additional information about Cambient and its advisory persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching Cambient’s firm name or CRD# 335128.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 1
Item 2 – Material Changes
Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. This Wrap Fee Program Brochure discusses the Program
offered by Cambient .
Material Changes
This is the initial filing of the Wrap Fee Program Brochure.
Future Changes
From time to time, Cambient may amend this Wrap Fee Program Brochure to reflect changes in business
practices, changes in regulations or routine annual updates as required by the securities regulators. This
complete Wrap Fee Program Brochure or a Summary of Material Changes shall be provided to you
annually and if a material change occurs in the business practices of Cambient.
At any time, you may view this Wrap Fee Program Brochure at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching for Cambient’s firm name or CRD# 335128.
You may also request a copy of this Disclosure Brochure at any time, by contacting Cambient at (616)
330-2270 or by email at info@cambient.com.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 2
Item 3 – Table of Contents
Item 2 – Material Changes .......................................................................................................................... 2
Item 3 – Table of Contents ......................................................................................................................... 3
Item 4 – Services Fees and Compensation .............................................................................................. 4
Item 5 – Account Requirements and Types of Clients ............................................................................ 7
Item 6 – Portfolio Manager Selection and Evaluation ............................................................................. 8
Item 7 – Client Information Provided to Portfolio Managers ................................................................ 10
Item 8 – Client Contact with Portfolio Managers ................................................................................... 11
Item 9 – Additional Information ............................................................................................................... 11
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 3
Item 4 – Services Fees and Compensation
A. Firm Information
Cambient Family Office, LLC (“Cambient” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). Cambient is organized as a Limited Liability
Company (“LLC”) under the laws of the State of Delaware. Cambient was founded in March 2025 and
commenced operations as a registered investment advisor in May 2025. Cambient is owned and
operated by Christopher S. Witham (Chief Executive Officer).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the
advisory services provided by Cambient. For information regarding this Disclosure Brochure, please
contact Joshua K. Gibbs (Chief Compliance Officer) at (616) 330-2270.
As of July 23, 2025, Cambient’s Assets Under Management were $668,824,000, all of which are
managed on a discretionary basis.
B. Advisory Services Offered
Cambient offers investment advisory services to high-net-worth and ultra-high-net-worth individuals,
families, trusts, estates, charitable organizations, and businesses (each referred to as a “client”).
Cambient provides a range of family office services to our client families. We work closely with you to
identify your investment goals and objectives, as well as risk tolerance and financial situation in order to
develop an investment approach.
Cambient serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a
fiduciary, Cambient upholds a duty of loyalty, fairness and good faith towards each client and seeks to
mitigate potential conflicts of interest. Cambient’s fiduciary commitment is further described in the
Advisor’s Code of Ethics.
Cambient provides customized investment advisory services for its clients. This Wrap Fee Program
Brochure is provided to provide full details of the business practices and fees when selecting Cambient as
your investment advisor. This is achieved through continuous personal client contact and interaction while
providing primarily discretionary investment management and related advisory services. Cambient works
closely with each client to identify their investment goals and objectives as well as risk tolerance and
financial situation in order to create a portfolio strategy. Cambient will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to
achieve the client’s investment goals. Cambient may also utilize individual stocks, bonds, options
contracts, alternative investments or cryptocurrency to meet the needs of its clients. Cambient may retain
certain legacy investments based on portfolio fit and/or tax considerations.
Cambient’s investment strategies are primarily long-term focused, but Cambient 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. Cambient 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 Cambient.
Cambient evaluates and selects investments for inclusion in client portfolios only after applying its internal
due diligence process. Cambient may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Cambient may recommend specific positions to increase sector or asset class
weightings. Cambient may recommend employing cash positions as a possible hedge against market
movement.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 4
Cambient 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.
Independent Managers - Cambient may recommend that clients utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for a portion of a
client’s investment portfolio, based on the client’s needs and objectives. Cambient will perform initial and
ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains
aligned with client’s investment objectives and overall best interests. Cambient will also assist the client in
the development of the initial policy recommendations and managing the ongoing client relationship.
Financial Planning Services
Cambient will typically provide a variety of financial planning and consulting services to clients, as part of
its wealth management services. Services are offered in several areas of a client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve preparing a
formal financial plan or rendering a specific financial consultation based on the client’s financial goals and
objectives. This planning or consulting may encompass one or more areas of need, including but not
limited to, investment planning, retirement planning, personal savings, education savings, insurance
needs, and/or other areas of a client’s financial situation.
A financial plan developed for, or financial consultation rendered to the client will usually include general
recommendations for a course of activity or specific actions to be taken by the client. For example,
recommendations may be made that the client start or revise their investment programs, commence or
alter retirement savings, establish education savings and/or charitable giving programs.
Cambient may also refer clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, Cambient will provide a written summary of
the client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, Cambient may not provide a written summary. Plans or consultations are typically
completed within six (6) months of contract date, assuming all information and documents requested are
provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of Cambient
and the interests of the client. For example, Cambient has an incentive to recommend that clients engage
Cambient for investment management services or to increase the level of investment assets with
Cambient, as it would increase the amount of advisory fees paid to Cambient. Clients are not obligated to
implement any recommendations made by Cambient or maintain an ongoing relationship with Cambient.
If the client elects to act on any of the recommendations made by the Cambient, the client is under no
obligation to implement the transaction through the Cambient.
Prior to engaging Cambient to provide investment advisory services, each client is required to enter into
one or more written agreements with Cambient that define the terms, conditions, authority and
responsibilities of the Cambient and the client. These services may include:
• Establishing an Investment Strategy – Cambient, in connection with the client, will develop a
strategy that seeks to achieve the client’s goals and objectives.
• Asset Allocation – Cambient 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 – Cambient will develop a portfolio for the client that is intended to meet the
stated goals and objectives of the client.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 5
•
Investment Management and Supervision – Cambient will provide investment management and
ongoing oversight of the client’s investment portfolio.
Statements reports will be provided to the client on at least a quarterly basis by the custodian.
As part of wealth management fees, Cambient covers securities transaction fees, wire fees, and certain
other administrative fees charged by the custodian (herein “Covered Costs”). In general, the
recommended custodian’s transaction fees only relate to certain ETFs and mutual funds. Clients are
responsible for any account closing fees charged by the custodian. Securities regulations often refer to
this combined fee structure as a “Wrap Fee Program”. The Advisor sponsors the Cambient Wrap Fee
Program.
The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the
combination of Covered Costs into a single “bundled” wealth management fee.
C. Program Costs
Advisory services provided by Cambient are offered in a wrap fee structure whereby Covered Costs are
included in the overall wealth management fee paid to Cambient. As the level of activity in a client’s
account[s] may vary from year to year, the annual cost to the client may be more or less than engaging
for advisory services where the Covered Costs are borne separately by the client. The cost of the Wrap
Fee Program varies depending on services to be provided to each client, however, the client is not
charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a
conflict of interest as Cambient is incentivized to utilize securities that do not have transaction fees. As
noted above, Cambient recommended custodian does not generally charge securities transaction fees
other than for ETFs and mutual funds. Cambient endeavors to always invest in a manner believed to be
in the client’s best interest.
D. Fees
Wealth management fees are paid monthly in arrears pursuant to the terms of the wealth management
agreement. Wealth management fees are based on the market value of assets under management at the
end of each month. Wealth management fees range from 0.50% to 1.50% annually based on several
factors, including: the scope and complexity of the services to be provided; the level of assets to be
managed; and the overall relationship with Cambient. Relationships with multiple objectives, smaller assets
under management, specific reporting requirements, portfolio restrictions and other complexities may be
charged a higher fee.
The wealth management fee in the first month of service is prorated from the inception date of the
account[s] to the end of the first month. If assets are deposited into or withdrawn from an account after the
inception of a billing period, the fee payable with respect to such assets is prorated based on the number of
days remaining in the current billing period. Fees may be negotiable at the sole discretion of Cambient. The
client’s fees will take into consideration the aggregate assets under management with Cambient. All
securities held in accounts managed by Cambient will be independently valued by the custodian.
Certain client investment are deemed “assets under supervision”, which are non- discretionary
investments that the client has directed Cambient to monitor and include in reporting. These assets are
billed at an annual fee rate of 0.15%. Client’s wishing to use the custodian’s trustee services may pay an
additional 0.15% fee for applicable investments (payable to Fidelity Trust). Additionally, Cambient may
charge a “special asset administration fee” of $5,000 per asset for certain non-traditional investments. All
fees mentioned above are negotiable and may vary based on the client’s specific circumstances.
As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the
discretionary investment management services provided by Cambient, as part of its overall wealth
management fee.
Fee Billing
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 6
Wealth management fees are calculated by Cambient or its delegate and deducted from the client’s
account[s] at the custodian. Cambient shall send an invoice to the custodian indicating the amount of the
fees to be deducted from the client’s account[s] at the respective month. The amount due is calculated by
applying the monthly rate (annual rate divided by 12) to the total assets under management with Cambient
at the end of the month. Clients will be provided with a statement, at least quarterly, from the custodian
reflecting deduction of the wealth management fee. Clients are urged to also review the statement provided
by the custodian, as the custodian does not perform a verification of Cambient’s fees. Clients provide written
authorization permitting advisory fees to be deducted by Cambient to be paid directly from their account[s]
held by the custodian as part of the wealth management agreement and separate account forms provided
by the custodian.
Advance Payment of Fees and Termination
Cambient does not bill investment management fees in advance, but rather in arrears. Cambient may be
compensated for its investment management services at the end of the month after services are rendered.
Either party may terminate the wealth management agreement, at any time, by providing advance written
notice to the other party. The client may also terminate the wealth management agreement within five (5)
business days of signing Cambient’s 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. The client’s wealth management agreement with Cambient is non-
transferable without the client’s prior consent.
Independent Managers
Cambient may allocate a portion of a client’s investment portfolio to one or more Independent Managers
who offer specialized strategies, when appropriate. These Independent Managers charge an investment
management fee in addition to Cambient’s standard wealth management fee. The fees charged by the
Independent Managers will be disclosed to the client prior to the engagement.
One such strategy is a Direct Indexing Strategy offered through Fidelity Institutional Wealth Adviser LLC.
This strategy carries an additional fee of 0.20% on top of Cambient’s standard wealth management fee,
with approximately half of that fee paid to Cambient for supervising the strategy. This arrangement
creates a potential conflict of interest, as Cambient may be incentivized to recommend this strategy.
If Cambient determines that an Independent Manager is no longer in the client’s best interest, it has the
discretion to terminate the relationship. Termination terms are governed by the agreements between
Cambient and the respective Independent Managers.
In addition, all fees paid to Cambient for investment advisory services as part of the Wrap Fee Program
are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their
shareholders, if applicable. These fees and expenses are described in each fund’s prospectus.
E. Compensation
Cambient receives investment advisory fees paid by clients for participating in the Wrap Fee Program and
pays the custodian for the costs associated with the normal trading activity in client accounts. We are
incentivized to recommend this program over other programs or services: however, at this time the Wrap
Fee Program is the only program offered to our advisory clients. Your overall fees may be higher or lower
if you paid separately for investment advice, brokerage and other services. It is our policy to always act in
the best interests of our clients, and we deem the Wrap Fee Program in the best interests of our clients.
Item 5 – Account Requirements and Types of Clients
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 7
Cambient offers investment advisory services to high-net-worth individuals, families, trusts, estates,
charitable organizations, and businesses. Cambient generally does not impose a minimum relationship
size. However, its services are tailored to high-net-worth families.
Item 6 – Portfolio Manager Selection and Evaluation
Portfolio Manager Selection
Cambient serves as sponsor and as portfolio manager for the services under this Wrap Fee Program.
Related Persons
Cambient personnel serve as portfolio managers for this Wrap Fee Program. Cambient does not serve as
a portfolio manager for any third-party Wrap Fee Programs.
Performance-Based Fees
Cambient does not charge performance-based fees for its investment advisory services. The fees
charged by Cambient are as described in Item 5 above and are not based upon the capital appreciation
of the funds or securities held by any client.
Cambient 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.
Advisory Services
Cambient offers portfolio management and wealth management services as well as financial planning, to
individuals, high-net-worth individuals, families, trusts, estates, charitable organizations and businesses.
We work with our clients to determine their investment objectives and risk profile and develop a
customized investment plan based on their individual needs and goals. Cambient will utilize the financial
information provided by the client to analyze and develop strategies and solutions to assist the client in
meeting their financial goals.
Methods of Analysis
Cambient primarily employs fundamental and technical analysis methods in developing investment
strategies for its clients. Research and analysis from Cambient 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. This
criteria consists generally of 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 Cambient
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. Cambient monitors these economic indicators to determine if
adjustments to strategic allocations are appropriate.
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts to
identify market patterns and trends, which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends
may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that Cambient will be able to accurately predict such a reoccurrence.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 8
As noted above, Cambient generally employs a long-term investment strategy for its clients, as consistent
with their financial goals. Cambient 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, Cambient 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.
Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value
and clients should be prepared to bear the potential risk of loss. Cambient 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.
While the methods of analysis help Cambient in evaluating a potential investment, it does not guarantee
that the investment will increase in value. Assets meeting the investment criteria utilized in these methods
of analysis may lose value and may have negative investment performance. Cambient monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate.
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]. Cambient shall rely on the 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
Cambient 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. Cambient will work with each client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with Cambient’s investment strategies:
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 price of
the ETFs will fluctuate with the price 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 have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon
the market movements and may dissociate from the index being tracked by the ETF or the price of the
underlying investments. An ETF purchased or sold at one point in the day may have a different price than
the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are
unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with
ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the
liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the
market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact
on liquidity and the valuation of an ETF.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond
prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to
maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be
reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of
living and inflation increase at a rate that exceeds the income investment thereby decreasing the
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 9
investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument
which includes the possibility of the company defaulting on its repayment obligation, (5) rating
downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which
impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the
risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The
price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds.
The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day
will typically have the same price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option
contracts are leveraged instruments that allow the holder of a single contract to control many shares of an
underlying stock. This leverage can compound gains or losses.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a client. For example, if
securities pledged to brokers to secure a client’s margin accounts decline in value, the client could be
subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be
the subject of mandatory liquidation of the pledged securities to compensate for the decline in value.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited
liquidity. An investor could lose all or a portion of their investment. Such investments often have
concentrated positions and investments that may carry higher risks. Clients should only have a portion of
their assets in these investments.
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.
Proxy Voting
Pursuant to the Wealth Management Agreement and internal policies, Cambient Family Office, LLC votes
proxies related to securities held in certain Client accounts. Cambient or its appointed agent will also file
class actions for securities in discretionary accounts unless specifically directed otherwise in writing.
We have engaged Broadridge Investor Communication Solutions Inc. to provide an internet-based proxy
voting platform. We have established voting guidelines to ensure Client proxies are voted appropriately
and in the best interests of Clients. Clients may contact their advisor with questions pertaining to proxy
procedures and proposals. Clients affirm that Cambient Family Office may delegate authority to vote
proxies, including on matters relating to class actions, bankruptcies or reorganizations, to independent
managers and unaffiliated investment managers that are selected by Cambient Family Office where
discretionary investment authority has been delegated to manage a portion of the Client’s assets. In such
circumstances, proxy voting will be governed by each such manager’s proxy voting policies and
procedures.
Item 7 – Client Information Provided to Portfolio Managers
As the sole portfolio manager of the Wrap Fee Program, Cambient does not communicate client
information to any third-party portfolio managers.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 10
Item 8 – Client Contact with Portfolio Managers
Cambient is a full-service investment management advisory firm. Clients always have direct access to the
Portfolio Managers at Cambient.
Item 9 – Additional Information
Disciplinary Information and Other Financial Industry Activities and Affiliations
As a registered investment advisor, Cambient is required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of our firm or the integrity of our
management. Cambient encourages clients to perform the requisite due diligence on any advisor or
service provider that the client engages. The backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching
Cambient’s firm name or CRD# 335128.
Other Financial Activities and Affiliations
Cambient’s management persons are not registered, nor do any management persons have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer. Cambient’s
management persons are not registered, nor do any management persons have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading Adviser, or an
associated person of the foregoing entities.
Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
Cambient has implemented a Code of Ethics that defines its fiduciary commitment to each client. This
Code of Ethics applies to all persons subject to Cambient’s compliance program (our “Supervised
Persons”). The Code was developed to provide general ethical guidelines and specific instructions
regarding Cambient’s duties to each client. Cambient and its Supervised Persons owe a duty of loyalty,
fairness and good faith towards each client. It is the obligation of Cambient’s Supervised Persons 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 employee ethics and conflicts of interest. To
request a copy of the Code, please contact Cambient at (616) 330-2270.
Personal Trading with Material Interest
Cambient allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of clients. Cambient does not act as principal in any transactions and does
not act as the general partner of a fund or advise an investment company. Cambient does not have a
material interest in any securities traded in client accounts.
Personal Trading in Same Securities as Clients
Cambient 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, Cambient has adopted the Code to address insider
trading (material non-public information controls); gifts and entertainment; outside business activities and
personal securities reporting.. 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 Cambient requiring reporting of personal
securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or
delegate.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 11
Personal Trading at Same Time as Client
While Cambient 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 afterwards. At no time will Cambient, or any Supervised Person of Cambient,
transact in any security to the detriment of any client.
Brokerage Practices
Recommendation of Custodian[s]
Cambient will generally recommend that clients establish their account[s] at Fidelity Clearing and Custody
Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial
Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), a FINRA-registered broker-
dealer and member SIPC. Fidelity will serve as the client’s “qualified custodian.” Cambient maintains an
institutional relationship with Fidelity, whereby Cambient receives economic benefits from Fidelity.
Cambient currently only works with clients who use Fidelity for their custodian and brokerage.
Cambient has established an institutional relationship with Fidelity to assist in managing client account[s].
Access to the Fidelity platform is provided at no charge to Cambient. The Fidelity platform includes
brokerage, custody, administrative support, record keeping, technology and related services designed to
support registered investment advisors like Cambient in serving clients. These services are intended to
serve the best interests of Cambient’s clients.
Following are additional details regarding the brokerage practices of Cambient:
1. Soft Dollars - Cambient does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, Cambient receives certain economic benefits from the custodian.
2. Brokerage Referrals - Cambient currently does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
Fidelity is providing Cambient with financial support to cover certain types of expenses related to the
launch of the firm. Additional details about this arrangement can be found below in the “Participation in
Institutional Advisor Platform.
3. Directed Brokerage- Cambient currently does not allow directed brokerage on behalf on clients.
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. Cambient will execute its
transactions through the custodian as authorized by the client. Cambient may aggregate orders in a block
trade or trades when securities are purchased or sold through the custodian for multiple (discretionary)
accounts in the same trading day. 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 any particular clients’ accounts.
Review of Accounts
Frequency of Reviews
Securities in client accounts are monitored on a regular and continuous basis by Advisor Persons of
Cambient and periodically by the CCO. Formal reviews are generally conducted at least annually or more
frequently depending on the needs of the client.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
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Causes for Reviews
In addition to the investment monitoring, 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 Cambient 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.
Review Reports
Cambient will provide clients with periodic reports upon request and clients have access to a portal to
review account balances and activity on demand. These reports are not a substitute for the statements
received directly from the account custodian. You should compare the reports we provide with those
provided by the custodian.
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Participation in Institutional Advisor Platform
Cambient has established an institutional relationship with Fidelity to assist in managing client account[s].
As part of the arrangement, Fidelity also makes available to Cambient, at no additional charge, certain
research and brokerage services, including research services obtained by Fidelity directly from independent
research companies. Cambient may also receive additional services and support from Fidelity. As a result of
receiving such services, Cambient may have an incentive to continue to use or expand the use of Fidelity's
services. Cambient examined this potential conflict of interest when it chose to enter into the relationship
with Fidelity and has determined that the relationship is in the best interests of its clients and satisfies its
client obligations, including its duty to seek best execution. Cambient receives access to software and
related support without cost because Cambient renders wealth management services to clients that
maintain assets at Fidelity. The software and related systems support may benefit Cambient, but not its
clients directly. In fulfilling its duties to its clients, Cambient 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 Cambient's recommendation over one that
does not furnish similar software, systems support, or services.
In addition, Cambient is receiving economic benefits from Fidelity limited to covering certain costs for
services related to the launch of Cambient. These benefits create a conflict of interest because they
incentivized Cambient to utilize Fidelity’s services over other custodians who may not provide similar
benefits. Cambient reviewed these conflicts and determined that the custodial relationship is in the best
interests of its clients and consistent with its duty to seek best execution. Clients should understand that
these economic benefits accrue to Cambient and do not directly reduce the fees charged to clients.
Client Referrals from Solicitors
Cambient does not compensate, either directly or indirectly, any persons who are not supervised persons,
for client referrals.
Custody
When you establish a relationship with our firm for investment management services, your assets will be
maintained by a bank, broker -dealer, mutual fund transfer agent or other such institution deemed a
‘qualified custodian’ by the SEC. We rely on the custodian to price and value assets, execute and clear
transactions, maintain custody of assets in your account and perform other custodial functions. Cambient
does not maintain physical possession of any client account assets.
Cambient has the ability to debit advisory fees from client accounts and is therefore considered to have
custody of client assets. In addition, Cambient is deemed to have custody due to its authority over certain
accounts to distribute assets subject to a third-party standing letter of authorization (“SLOAs”).
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
Page 13
Clients will receive account statements from their account custodian on at least a quarterly basis.
Investment Discretion
Cambient generally has discretion 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 to by Cambient. 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 a wealth
management agreement containing all applicable limitations to such authority. All discretionary trades
made by Cambient will be in accordance with each client's investment objectives and goals.
Financial Information
Neither Cambient, nor its management, have any adverse financial situations that would reasonably
impair the ability of Cambient to meet all obligations to its clients. Neither Cambient, nor any of its
Advisory Persons, have been subject to bankruptcy or financial compromise. Cambient is not required to
deliver a balance sheet along with this Disclosure Brochure as Cambient does not collect advance fees of
$1,200 or more for services to be performed six months or more in the future.
Cambient Family Office, LLC
4690 E. Fulton Street, Suite 203, Ada, Michigan 49301
Phone: (616) 330-2270 | Website: https://cambient.com
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